UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
FORT WAYNE DIVISION
FEDERAL TRADE COMMISSION, Plaintiff,
v.
OMNI ADVERTISING, INC., a corporation, - and - CHRISTOPHER EHRHORN,
also d/b/a FRI, INC., AMERICAN DEPUTY SHERIFFS' ASSOCIATION, DISABLED
FIREFIGHTERS, individually and as an officer of the corporate
defendant, - and - STACEY STANLEY, also d/b/a FRI, INC., AMERICAN
DEPUTY SHERIFFS' ASSOCIATION, DISABLED FIREFIGHTERS, individually and
as an officer of the corporate defendant, Defendants.
CIVIL NO.
COMPLAINT FOR INJUNCTIVE
AND OTHER EQUITABLE RELIEF
JUDGE
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 obtain
preliminary and permanent injunctive relief against the defendants to
prevent them from engaging in deceptive acts or practices in violation
of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and to obtain other
equitable relief, including rescission, restitution and disgorgement,
as is necessary to redress injury to consumers and the public interest
resulting from defendants' violations of the FTC Act.
JURISDICTION AND VENUE
2. Subject matter jurisdiction is conferred upon this Court by 15
U.S.C. §§ 45(a) and 53(b) and 28 U.S.C. §§ 1331, 1337(a), and 1345.
3. Venue in the United States District Court for the Northern District
of Indiana is proper under 15 U.S.C. § 53(b), as amended by the FTC
Act Amendments of 1994, Pub. L. No. 103-312, 108 Stat. 1691, and 28
U.S.C. § 1391(b) and (c).
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
SNIPPETS:
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
FEDERAL TRADE COMMISSION, Plaintiff,
OMNI ADVERTISING, INC., a corporation, - and - CHRISTOPHER EHRHORN, also d/b/a FRI, INC.,
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 ("FTC
nts' violations of the FTC Act.
The Commission enforces Section 5of the FTC Act, 15 U.S.C. § 45, which prohibits deceptive
The Commission may initiate federal district court proceedings to enjoin violations of the
Defendant Omni Advertising,
Its principal place of business was at 3206 Mallard Cove, Fort Wayne, Indiana, 46804.
Fire Prevention Coloring Book;
Defendant Christopher Ehrhorn is an officer of the defendant corporation referred to herein.
Defendants solicit businesses and other organizations to either advertise in, or support or
In numerous instances, defendants contact an organization and misrepresent that the
Defendants also represent that advertising in or supporting or contributing to their
Defendants often represent that the publication that contains the organization's
Contrary to defendants' representations, paying defendants does not provide organizations
Defendants reinforce the misrepresentation that the organization has ordered the
Section 13of the FTC Act, 15 U.S.C. § 53, empowers this Court to issue a permanent injunction
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