UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
' FEDERAL TRADE COMMISSION and 1
1
COMMONWEALTH OF VIRGINIA, ex rel. )
MARK L. EARLEY, Attorney General of Virginia, ) 1
Plaintiffs, ) 1
V. ) )
MED RESORTS INTERNATIONAL, INC., a )
Virginia corporation; 1
)
WORLD CONNECTIONS, INC., d/b/a World )
Connections Travel, a Virginia corporation; ) Civ. No.
1
MEDITERRANEAN RESORTS, INC., a District of )
Columbia corporation; 1
)
DESTINATIONS UNLIMITED OF DELAWARE, )
INC., d/b/a Destinations Unlimited, a Delaware )
corporation; ) 1
BAY FINANCIAL SERVICES, INC., a Florida )
corporation; ) )
V-PAC, INC., a Nevada corporation; 1
1
J. GEORGE CLAVEAU; and 1
1
MARIANNE BORDEN-MYERS, ) 1
Defendants. 1
)
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
Plaintiffs, the Federal Trade Commission ("FTC" or "the Commission"), and the
Commonwealth of Virginia ex rel. Mark L. Earley, Attorney General of Virginia ("the
Commonwealth of Virginia") for their complaint allege:
1. The FTC brings this action under Sections 13(b) and 19 of the Federal
Commission Act (`FTC Act"), 15 U.S.C. $8 53(b) and 57b, to secure preliminary and
injunctive relief, restitution, rescission or reformation of contracts, disgorgement, and
equitable relief for Defendants' deceptive acts or practices in violation of Section
SNIPPETS:
Plaintiffs, the Federal Trade Commission, and the
Commonwealth of Virginia") for their complaint allege:
The FTC brings this action under Sections 13and 19 of the Federal Trade
Commission Act, 15 U.S.C. $8 53and 57b, to secure preliminary and permanent
injunctive relief, restitution, rescission or reformation of contracts, disgorgement, and
equitable relief for Defendants' deceptive acts or practices in violation of Section 5of the
Act, 15 U.S.C. 0 45, and the FTC's Trade Regulation Rule on Preservation of Consumers'
Claims and Defenses ("Holder in Due Course Rule"),
Protection Act, Virginia Code Ann.
permanent injunctive relief, consumer restitution, and other equitable relief, and
attorneys, to enjoin violations of the FTC Act and violations of the Holder in Due Course
Mark L. Earley is the duly elected and qualified Attorney General acting for plaintiff
Clearwater, Florida 34624, and four sales locations, including 1430 Branding Lane, Suite 125,
Med Resorts transacts or has transacted business in the Northern
World Connections transacts or has transacted business in the Northern
deceive consumers throughout the United States into purchasing vacation club memberships.
travel agents or airlines.
Med Resorts' sales representatives typically show consumers copies of the resort
In numerous instances since at least 1983, in connection with the advertising,
memberships cannot purchase airline tickets from Defendants at costs substantially below those
consumer redress, rescission, restitution and disgorgement of profits resulting from
|
