DEBRA A. VALENTINE
General Counsel
ANN F. WEINTRAUB (AW 3080)
MICHAEL J. BLOOM (MB 7732)
RHONDA J. MCLEAN (RM 9140)
Attorneys for Plaintiff
Federal Trade Commission
150 William Street, Suite 1300
New York, NY 10038
(212) 264-1226
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK
FEDERAL TRADE COMMISSION Plaintiff,
v.
MICHAEL LYONS, individually and doing business as Lyons Publishing,
Defendant.
Civil Action No.
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).
SNIPPETS:
Attorneys for Plaintiff Federal Trade Commission
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK
MICHAEL LYONS, individually and doing business as Lyons Publishing,
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
The Commission brings this action under Sections 13and 19 of the Federal Trade Commission
Section 404of the Credit Repair Organizations Act, 15 U.S.C.
Plaintiff, the Federal Trade Commission, is an independent agency of the United States
The Commission is charged, inter alia, with enforcement of Section 5of the FTC Act, 15 U.S.C.
The Commission is authorized to initiate federal district court proceedings, by its own
Defendant Michael Lyons does business as Lyons Publishing and is a principal of these
At all times relevant to this complaint, defendant has maintained a substantial course of
Since at least December 1998, defendant has advertised, promoted, offered for sale, and sold
Defendant has claimed that consumers can improve their credit histories, credit records, or
Learn how to use the Credit Bureaus to get a TOTALLY NEW-CLEAN credit file.
Sections 13and 19 of the FTC Act, 15 U.S.C. §§ 53and 57b, and Section 410of the Credit Repair
remedial measures.
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