UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
FEDERAL TRADE COMMISSION,
Plaintiff,
v.
PARA-LINK INTERNATIONAL, INC., CIVIL NO.
a Florida corporation,
AAA FAMILY CENTERS, INC., a Florida COMPLAINT FOR INJUNCTION
corporation, AND OTHER EQUITABLE
RELIEF
THE LIBERTY GROUP OF AMERICA,
INC., a Florida corporation,
DEBORAH R. DOLEN, individually and
as an officer of PARA-LINK
INTERNATIONAL, INC.,
MATTHEW SEE, individually and as an
officer of THE LIBERTY GROUP OF
AMERICA, INC., and
JUDY GRAVES, individually and as an
officer of PARA-LINK
INTERNATIONAL, INC.,
Defendants.
Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"), for its
complaint alleges:
1. The FTC brings this action under Sections 5(a) and 13(b) of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a) and 53(b), to obtain temporary,
preliminary, and permanent injunctive relief, rescission of contracts, restitution,
disgorgement, appointment of a receiver, and other equitable relief for defendants'
violations of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
Page 1 of 12
JURISDICTION AND VENUE
SNIPPETS:
INC., a Florida corporation,
individually and as an officer of PARA-LINK
Plaintiff, the Federal Trade Commission, for its complaint alleges:
Commission Act, 15 U.S.C. §§ 45and 53, to obtain temporary,
preliminary, and permanent injunctive relief, rescission of contracts, restitution,
violations of Section 5of the FTC Act,
Venue in the United States District Court for the Middle District of Florida is proper
prohibits unfair or deceptive acts or practices in or affecting commerce.
attorneys, to enjoin violations of the FTC Act in order to secure such equitable relief as
1, Sarasota, FL 34243, advertises, promotes, and sells paralegal training and employment
Para-Link also does business under the name, The National Association of Independent
transacts or has transacted business in the Middle District of Florida.
"Internet" means a worldwide system of linked computer networks that use a common protocol to
lure potential purchasers into buying a work-at-home kit for prices ranging from $395$495
Once consumers pass defendants' qualifying tests, they are then eligible to receive case
Defendants' Web sites promise that kit buyers will "make serious money" and boast "you are
a training video; over 88 sample forms, including forms for creating a simple divorce or
In numerous instances, consumers fail to receive their kits in a timely fashion, and are
To pass the tests (and therefore qualify for case referrals), defendants require that kit
Section 5of the FTC Act, 15 U.S.C. § 45, provides that "unfair or deceptive acts
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