UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
NORTHERN DIVISION
FEDERAL TRADE COMMISSION, Plaintiff,
v.
PHILIP D. MILLER dba NEW START, Defendants
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).
3. Venue in the United States District Court for the District of
Maryland, Northern Division, is proper under 28 U.S.C. § 1391 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 et
seq. 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
SNIPPETS:
UNITED STATES DISTRICT COURT
FEDERAL TRADE COMMISSION, Plaintiff,
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
the Federal Trade Commission for its Complaint alleges:
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.
Venue in the United States District Court for the District of Maryland, Northern Division, is
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
At all times material to this complaint, acting alone or in concert with others, defendant
At all times relevant to this complaint, defendant has maintained a course of trade in the
Since at least July, 1998, defendant has advertised, promoted, offered for sale, and sold
Defendant claims that by following the program outlined in his manual consumers can establish
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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