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1
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DECISION & ORDER
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EXTRACTED KEY WORDS
COMMISSION UNSOLICITED COMMERCIAL E-MAIL FEDERAL TRADE COMMISSION LLC BUSINESS PROMOTIONS SALE BOND COMPLAINT REPRESENTATION ACT LIMITED LIABILITY COMPANY VIOLATION SUCCESSORS CONSUMER ADVERTISING ENTERPRISES INTERNET PROMOTIONS CONNECTICUT OFFERING LOUIS SALATTO PRINCIPALS DIRECTS MANNER EVIDENCE EMPLOYMENT DISTRIBUTION PROVISIONS FTC |
9723149
B258752
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
Commissioners:
Robert Pitofsky
Sheila F. Anthony
Mozelle W. Thompson
Orson Swindle
In the Matter of
LS ENTERPRISES, LLC, a limited liability company, also doing business
as FREEPROMO.COM, ENTERPRISE PUBLICATIONS, and LRS PUBLICATIONS, and
INTERNET PROMOTIONS, LLC, a limited liability company, also doing
business as CYBERPROMOTERS.COM, and LOUIS SALATTO, individually and as
the principal member of the limited liability companies.
DOCKET NO. C-3884
DECISION AND ORDER
The Federal Trade Commission having initiated an investigation of
certain acts and practices of the respondents named in the caption
hereof, and the respondents having been furnished thereafter with a
copy of a draft of complaint that the Boston Regional Office proposed
to present to the Commission for its consideration and which, if
issued by the Commission, would charge the respondents with violations
of the Federal Trade Commission Act; and
The respondents and counsel for the Commission having thereafter
executed an agreement containing a consent order, an admission by the
respondents of all the jurisdictional facts set forth in the aforesaid
draft of complaint, a statement that the signing of said agreement is
for settlement purposes only and does not constitute an admission by
the respondents that the law has been violated as alleged in such
complaint, and waivers and other provisions as required by the
Commission's Rules; and
The Commission having thereafter considered the matter and having
determined that it had reason to believe that the respondents have
violated the said Act, and that complaint should issue stating its
charges in that respect, and having thereupon accepted the executed
consent agreement and placed such agreement on the public record for a
period of sixty (60) days, now in further conformity with the
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2
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COMPLAINT
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EXTRACTED KEY WORDS
BUSINESS INTERNET ACT LIMITED LIABILITY COMPANY ENTERPRISES REPRESENTATIONS SET PARAGRAPH PROMOTION MANUALS FEDERAL TRADE COMMISSION LLC MYSTERY SHOPPER UNSOLICITED COMMERCIAL E-MAIL CONSUMERS ENTERPRISE PUBLICATIONS PRINCIPAL MEMBER CONNECTICUT LIMITED LIABILITY DISSEMINATING LOUIS SALATTO MYSTERY SHOPPING ADVERTISEMENTS IMPLICATION MISLEADING REASONABLE BASIS ASSIGNMENTS UNITED STATES LRS PUBLICATIONS RECIPIENT LISTS MERCHANDISE |
9723149
B258752
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In the Matter of
LS ENTERPRISES, LLC, a limited liability company, also doing business
as FREEPROMO.COM, ENTERPRISE PUBLICATIONS, and LRS PUBLICATIONS, and
INTERNET PROMOTIONS, LLC, a limited liability company, also doing
business as CYBERPROMOTERS.COM, and LOUIS SALATTO, individually and as
the principal member of the limited liability companies.
DOCKET NO. C-3884
COMPLAINT
The Federal Trade Commission, having reason to believe that LS
Enterprises, LLC, a limited liability company, also doing business as
Freepromo.com, Enterprise Publications, and LRS Publications; Internet
Promotions, LLC, a limited liability company, also doing business as
Cyberpromoters.com; and Louis Salatto, individually and as the
principal member of the limited liability companies ("respondents"),
have violated the provisions of the Federal Trade Commission Act, and
it appearing to the Commission that this proceeding is in the public
interest, alleges:
1. Respondent LS Enterprises, LLC is a Connecticut limited liability
company with its principal office or place of business at 1204 Main
Street, Suite 380, Branford, Connecticut 06405.
2. Respondent Internet Promotions, LLC is a Connecticut limited
liability company with its principal office or place of business at
1204 Main Street, Suite 380, Branford, Connecticut 06405.
3. Respondent Louis Salatto is the principal member of LS Enterprises,
LLC and Internet Promotions, LLC. Individually or in concert with
others, he formulates, directs, or controls the policies, acts, or
practices of the companies, including the acts or practices alleged in
this complaint. His place of residence is 13 Branhaven Drive, East
Haven, Connecticut 06513.
4. Respondents have advertised, offered for sale, sold, and
distributed products and services to the public, including: a service
whereby respondents will assist in disseminating unsolicited
commercial electronic mail ("E-Mail") on behalf of other companies or
individuals who are trying to sell their own products or services;
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3
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ANALYSIS
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EXTRACTED KEY WORDS
UCE PROMOTION CONSUMERS SALE REPRESENTATION EARNINGS COMPLAINT CHARGES PROPOSED CONSENT ORDER MYSTERY SHOPPERS COMMISSION AGREEMENT SOLD WORK-AT-HOME RECEIVING MISREPRESENTATIONS EMPLOYMENT OPPORTUNITIES AMOUNT COMPETENT RELIABLE EVIDENCE COMPLIANCE INTERNET SELLING MAILING LISTS BUSINESS OPPORTUNITIES PUBLIC RECORD RECEPTIVITY ACTS PURCHASER |
ANALYSIS OF PROPOSED CONSENT ORDER
TO AID PUBLIC COMMENT
_________________________________________________________________
The Federal Trade Commission has accepted an agreement to a proposed
consent order from LS Enterprises, LLC, Internet Promotions, LLC, and
Louis Salatto. The proposed respondents promoted and sold various
products and services through the Internet via unsolicited commercial
E-Mail ("UCE"). In particular, the proposed respondents promoted and
sold UCE products and services, whereby the proposed respondents
offered to assist in sending bulk UCE on behalf of other companies or
individuals who were selling products or services, and sold UCE
software and mailing lists so that other companies or individuals
could send their own bulk UCE. The proposed respondents also promoted
and sold various work-at-home and business opportunities via UCE.
The proposed consent order has been placed on the public record for
sixty (60) days for reception of comments by interested persons.
Comments received during this period will become part of the public
record. After sixty (60) days, the Commission will again review the
agreement and the comments received and will decide whether it should
withdraw from the agreement and take other appropriate action or make
final the agreement's proposed order.
The Commission's complaint alleges several unfair or deceptive acts or
practices related to the proposed respondents' promotion and sale of
various products and services via UCE. The complaint charges that,
with respect to the promotion and sale of UCE products and services,
the proposed respondents: falsely represented that they acted as an
E-Mail Internet Service Provider; falsely represented their experience
in providing UCE services; made false and unsubstantiated earnings
claims for purchasers of their UCE products and services; and made
false and unsubstantiated claims about the receptivity of consumers on
their E-Mail recipient lists towards receiving UCE.
The complaint further charges that the proposed respondents made
several false or unsubstantiated claims in the promotion and sale of
various work-at-home and business opportunities via UCE. The complaint
charges that in a promotion concerning setting consumers up with jobs
as "mystery shoppers," the proposed respondents: falsely represented
that they acted as contractors for major corporations to hire
consumers to work as "mystery shoppers," have hired thousands of
consumers to work as "mystery shoppers," have actual job openings for
"mystery shoppers" all over the country, and will give consumers as
many "mystery shopper" assignments from the proposed respondents as
they want or need; and made false and unsubstantiated earnings and
free merchandise claims. The complaint also charges that in a general
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4
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AGREEMENT CONTAINING CONSENT
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EXTRACTED KEY WORDS
FEDERAL TRADE COMMISSION LLC COMPLAINT BUSINESS INTERNET PROMOTIONS REPRESENTATION LIMITED LIABILITY PROPOSED RESPONDENTS LIMITED LIABILITY COMPANY PRINCIPAL MEMBER ENTERPRISES LOUIS SALATTO AGREEMENT ACT DRAFT COMPLAINT COMMERCIAL E-MAIL PRODUCT UNSOLICITED COMMERCIAL E-MAIL LIMITED LIABILITY COMPANIES UNITED STATES ENTERPRISE PUBLICATIONS CONSENT ORDER SUCCESSORS PRACTICES ADVERTISING RELIABLE SCIENTIFIC EVIDENCE DISTRIBUTION LRS PUBLICATIONS VIOLATION FTC ACT |
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In the Matter of
LS ENTERPRISES, LLC, a limited liability company, also doing business
as FREEPROMO.COM, ENTERPRISE PUBLICATIONS, and LRS PUBLICATIONS, and
INTERNET PROMOTIONS, LLC, a limited liability company, also doing
business as CYBERPROMOTERS.COM, and
LOUIS SALATTO, individually and as the principal member of the limited
liability company.
FILE NO. 972-3149
AGREEMENT CONTAINING CONSENT ORDER
The Federal Trade Commission has conducted an investigation of certain
acts and practices of LS Enterprises, LLC, a limited liability
company, also doing business as Freepromo.com, Enterprise
Publications, and LRS Publications; Internet Promotions. LLC, a
limited liability company, also doing business as Cyberpromoters.com;
and Louis Salatto, individually and as the principal member of the
limited liability companies ("proposed respondents"). Proposed
respondents, having been represented by counsel, are willing to enter
into an agreement containing a consent order resolving the allegations
contained in the attached draft complaint. Therefore,
IT IS HEREBY AGREED by and between LS Enterprises, LLC, by its duly
authorized principal member, Internet Promotions, LLC, by its duly
authorized principal member, and Louis Salatto, individually and as
the principal member of the limited liability companies, and counsel
for the Federal Trade Commission that:
1.a. Proposed respondent LS Enterprises, LLC is a Connecticut limited
liability company with its principal office or place of business at
1204 Main Street, Suite 380, Branford, Connecticut 06405.
1.b. Proposed respondent Internet Promotions, LLC is a Connecticut
limited liability company with its principal office or place of
business at 1204 Main Street, Suite 380, Branford, Connecticut 06405.
1.c. Proposed respondent Louis Salatto is the principal member of LS
Enterprises, LLC and Internet Promotions, LLC. Individually or in
concert with others, he formulates, directs, or controls the policies,
acts, or practices of the companies. His place of residence is 13
Branhaven Drive, East Haven, Connecticut 06513.
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