UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
UNITED STATES OF AMERICA,
Plaintiff,
v.
DAVID STORY, individually and doing business as NETWORK PUBLICATIONS,
Defendant.
CIVIL NO.
COMPLAINT FOR CIVIL PENALTIES, INJUNCTIVE, AND OTHER RELIEF
Plaintiff, the United States of America, acting upon notification and
authorization to the Attorney General by the Federal Trade Commission
("Commission"), for its complaint alleges that:
1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A),
13(b), 16(a), and 19 of the Federal Trade Commission Act ("FTC Act"),
15 U.S.C. §§ 45(a)(1), 45 (m)(1)(A), 53(b), 56(a), and 57b, and
Section 410(b) of the Credit Repair Organizations Act, 15 U.S.C.
§ 1679h(b), to obtain monetary civil penalties, consumer redress and
injunctive and other relief for Defendant's violations of Section
404(a)(2) of the Credit Repair Organizations Act, 15 U.S.C.
1679b(a)(2); and consumer redress and injunctive and other relief for
Defendant's violations of Section 5(a)(1) of the FTC Act, 15 U.S.C.
§ 45(a)(1).
JURISDICTION AND VENUE
2. This Court has jurisdiction of this matter pursuant to 28 U.S.C.
§§ 1331, 1337(a), 1345, 1355 and pursuant to 15 U.S.C. §§ 45(m)(1)(A),
53(b), 56(a), 57b, and 1679h(b)(2). This action arises under 15 U.S.C.
§§ 45(a)(1) and 1679h(b).
3. Venue in this district is proper under 15 U.S.C. § 53(b) and under
28 U.S.C. § 1391(b) and 1395(a).
DEFENDANT
4. Defendant David Story is an individual doing business as Network
Publications, with his office and principal place of business located
at 11103 Visalia Drive, Dallas, Texas 75228. Defendant transacts or
has transacted business in this District. At all times material to
this complaint, acting alone or in concert with others, he has
SNIPPETS:
UNITED STATES DISTRICT COURT
DAVID STORY, individually and doing business as NETWORK PUBLICATIONS,
COMPLAINT FOR CIVIL PENALTIES, INJUNCTIVE, AND OTHER RELIEF
Plaintiff, the United States of America, acting upon notification and authorization to the
Plaintiff brings this action under Sections 5, 5, 13, 16, and 19 of the Federal Trade
and consumer redress and injunctive and other relief for Defendant's violations of Section
Defendant transacts or has transacted business in this District.
At all times material to this complaint, acting alone or in concert with others, he has
At all times relevant to this complaint, Defendant has maintained a substantial course of
Defendant has claimed that he can improve consumers' credit histories, credit records, or
The document suggests that consumers apply for a Dun & Bradstreet number and to use that
Pursuant to Section 410of the Credit Repair Organizations Act, 15 U.S.C. § 1679h, any
CIVIL PENALTIES, CONSUMER REDRESS AND INJUNCTION
Each sale or attempted sale, since the effective date of the Credit Repair Organizations Act,
Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 1990, 28 U.S.C. § 2461,
Assistant Attorney General Civil Division
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