IN THE UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF COLORADO

                             Civil Action No.

                    FEDERAL TRADE COMMISSION, Plaintiff,

                                     v.

         MEHMET AKCA (a/k/a MATT AKCA), also d/b/a AKCA, Defendant.

            COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF

   Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for
   its Complaint alleges:

   1. The Commission brings this action under Sections 13(b) and 19 of
   the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 53(b) and
   57b, and Section 410(b) of the Credit Repair Organizations Act, 15
   U.S.C. § 1679h(b), to obtain preliminary and permanent injunctive
   relief, restitution, rescission, disgorgement, and other equitable
   relief for Defendant's deceptive acts or practices in connection with
   the sale and offering for sale of credit repair products in violation
   of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and Section
   404(a)(2) of the Credit Repair Organizations Act, 15 U.S.C.
   1679b(a)(2).
   JURISDICTION AND VENUE

   2. This Court has jurisdiction of this matter pursuant to 28 U.S.C.
   1331, 1337(a), and 1345, and 15 U.S.C. §§ 53(b), 57b, and 1679h(b).

   3. Venue in the District of Colorado is proper under 28 U.S.C.
   § 1391(b) and 15 U.S.C. § 53(b).

                                THE PARTIES

   4. Plaintiff, the Federal Trade Commission, is an independent agency
   of the United States Government created by statute. 15 U.S.C.
   §§ 41-58. The Commission is charged, inter alia, with enforcement of
   Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair
   or deceptive acts or practices in or affecting commerce. The
   Commission also enforces the Credit Repair Organizations Act. 15
   U.S.C. §§ 1679h(a). The Commission is authorized to initiate federal
   district court proceedings, by its own attorneys, to enjoin violations
   of the FTC Act and the Credit Repair Organizations Act in order to
   secure such equitable relief, including consumer redress, as may be
   appropriate in each case. 15 U.S.C. §§ 53(b), 57b, and 1679h(b).