COMPLT52.DOJ

                    IN THE UNITED STATES DISTRICT COURT
                    FOR THE EASTERN DISTRICT OF NEW YORK

                   UNITED STATES OF AMERICA, Plaintiff,

                                     v.

           GLOBAL TOY DISTRIBUTORS, INC., a New York Corporation;
   RICHARD D. PATETTA, individually and as an officer of the corporation;
                                    and
               GEORGE J. McDERMOTT, individually, Defendants.

                          Civil Action No. CV-97-

              COMPLAINT FOR CIVIL PENALTIES, CONSUMER REDRESS,
              PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF

   Plaintiff, the United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("FTC" or "the Commission"), pursuant to Section 16(a)(1) of the
   Federal Trade Commission Act ("FTC Act"). 15 U.S.C. § 56(a)(1), for
   its complaint alleges:

   1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A),
   13(b), 16(a) and 19 of the FTC Act, 15 U.S.C. § § 45(a)(1),
   45(m)(1)(A), 53(b), 56(a) and 57b, to secure civil penalties, consumer
   redress, a permanent injunction and other equitable relief for
   defendants' violations of the FTC's Trade Regulation Rule entitled
   "Disclosure Requirements and Prohibitions Concerning Franchising and
   Business Opportunity Ventures" ("the Franchise Rule" or "the Rule"),
   16 C.F.R. Part 436.

                           JURISDICTION AND VENUE

   2. This Court has jurisdiction over this matter pursuant to 28 U.S.C.
   §§ 1331, 1337(a), 1345 and 1355, and 15 U.S.C. § § 45(m)(1)(A), 53(b),
   56(a) and 57b. This action arises under 15 U.S.C. § 45(a)(1).

   3. Venue in the Eastern District of New York is proper under 28 U.S.C.
   § § 1391(b) and (c) and 1395(a), and 15 U.S.C. § 53(b).

                                 DEFENDANTS

   4. Defendant Global Toy Distributors, Inc. ("Global"), a New York
   corporation with its principal place of business at 843-B Father
   Capadanno Boulevard, Staten Island, New York 10305, promotes and sells