UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
MARK A. REIBER, d/b/a CREDIT REPORT COUNSELORS,
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 the Credit
Repair Organizations Act, 15 U.S.C. § 1679-1679j; 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). Venue in this Court is proper under
S.D. Ohio L.R. 3.3.
DEFENDANT
4. Defendant Mark A. Reiber is an individual with his office and
principal place of business located at 10979 Reed Hartman Hwy, Suite
107, Cincinnati, Ohio 45242. Defendant Reiber does business as Credit
SNIPPETS:
UNITED STATES DISTRICT COURT
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
Act, 15 U.S.C. § 45.
This Court has jurisdiction of this matter pursuant to 28 U.S.C. §§ 1331, 1337, 1345, 1355
Defendant Reiber does business as Credit Report Counselors.
At all times relevant to this complaint, Defendant has maintained a substantial course of
DEFENDANT'S BUSINESS PRACTICES
Defendant has telemarketed, advertised, promoted, offered for sale, and sold credit repair
Defendant has offered services to remove negative information from, or improve, consumers'
Consumers have contacted Defendant by telephone and have been told by Defendant's
Defendant has made such representations to consumers even where such negative information was
Pursuant to Section 410of the Credit Repair Organizations Act, 15 U.S.C. § 1679h, any
In connection with his operation as a credit repair organization, as that term is defined in
m consumers' credit reports.
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,
Of Counsel: FOR THE UNITED STATES OF AMERICA:
Assistant Attorney General Civil Division
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