IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FEDERAL TRADE COMMISSION,
Plaintiff,
V.
KEVIN TRUDEAU individually,
Defendant.
Civil Action No
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for
its complaint alleges as follows:
1. The Commission brings this action under section 13(b) of the
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 53(b), to secure
preliminary and permanent injunctive relief, rescission of contracts,
restitution, disgorgement, and other equitable relief for defendants'
unfair and deceptive acts and practices in violation of Sections 5(a)
and 12 of the FTC Act, 15 U.S.C. § § 45(a) and 52.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this matter under 28 U.S.C.
1331, 1337(a), and 1345, and under 15 U.S.C. § § 45(a)(1) and 53(b).
3. Venue in the United States District Court for the Northern District
of Illinois is proper under 28 U.S.C. § § 1391(b) and (c) and 15
U.S.C. § 53(b).
PLAINTIFF
4. Plaintiff, the Federal Trade Commission, is an independent agency
of the United States Government created by statute. 15 U.S.C. § 41 et
seq. The Commission is charged, inter alia, with enforcement of
Sections 5(a) and 12 of the FTC Act, 15 U.S.C. § § 45(a) and 52.
Section 5(a) of the FTC Act prohibits unfair or deceptive acts or
practices in or affecting commerce. 15 U.S.C.§ 45(a). Section 12 of
the FTC Act prohibits the dissemination or the causing to be
disseminated of any false advertisement in order to induce the
purchase of food, drugs, devices, or cosmetics. The Commission is
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission, for its complaint alleges as follows:
The Commission brings this action under section 13of the Federal Trade Commission Act, 15
Venue in the United States District Court for the Northern District of Illinois is proper
Plaintiff, the Federal Trade Commission, is an independent agency of the United States
The Commission is charged, inter alia, with enforcement of Sections 5and 12 of the FTC Act,
Section 5of the FTC Act prohibits unfair or deceptive acts or practices in or affecting
Defendant Kevin Trudeau is a former employee of Mega Systems International, Inc., an
At all times pertinent to this complaint, defendant has resided or transacted business in
At all times relevant to this complaint, defendant Kevin Trudeau has maintained a substantial
FTC Act, 15 U.S.C. § 44.
Defendant's advertisements include, but are not limited to, program-length radio and
Since at least 1993 through 1996, defendant Kevin Trudeau participated in the advertising,
(Complaint Exhibit A)
Since at least 1993 through 1995, defendant Kevin Trudeau participated in the advertising,
Since at least 1994 through 1995, defendant Kevin Trudeau participated in the advertising,
Since at least 1992 through 1996, defendant Kevin Trudeau participated in the advertising,
Through the use of the statements referred to in Paragraphs 9 and 10, and others not
Sable Hair Farming System will stop, prevent, cure, relieve, reverse or reduce hair loss.
Absent injunctive relief by this Court, defendants are likely to continue to injure consumers
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