IN THE UNITED STATES DISTRICT COURT
                    FOR THE NORTHERN DISTRICT OF GEORGIA
                              ATLANTA DIVISION

                    UNITED STATES OF AMERICA, Plaintiff,

                                     v.

     PERIMETER CREDIT, L.L.C. and ACCOUNT PORTFOLIOS, INC., Defendants.

                              Civil Action 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(m)(1)(A), 9, 13(b),
       and 16(a) of the Federal Trade Commission Act ("FTC Act"), 15
       U.S.C. §§ 45(m)(1)(A), 49, 53(b), and 56(a), and Section 814 of
       the Fair Debt Collection Practices Act ("FDCPA"), 15 U.S.C.
       1692l, to obtain monetary civil penalties and injunctive or other
       relief for Defendants' violations of the FDCPA.

                           JURISDICTION AND VENUE
    2. This Court has jurisdiction over this action pursuant to 28 U.S.C.
       §§ 331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45
       (m)(1)(A), 49, 53(b), 56(a), and 1692l.
    3. Venue in the Northern District of Georgia is proper under 28
       U.S.C. §§ 1391(b)-(c) and 1395(a).

                                 DEFENDANTS
    4. Defendant Account Portfolios, Inc. ("API") is a corporation, with
       its principal place of business at 5000 Riverdale Court, Atlanta,
       Georgia 30337-6074. Defendant Perimeter Credit, L.L.C.
       ("Perimeter"), a subsidiary of API, is a limited liability company
       with its principal place of business at 3300 Northeast Expressway,
       Atlanta, Georgia 30341. API has control over the hiring, firing,
       compensation, and training for the employees of Perimeter. At all
       times relevant to this Complaint, API and Perimeter have
       transacted business in the Northern District of Georgia.
    5. API and Perimeter are debt collectors, as the term "debt
       collector" is defined in Section 803(6) of the FDCPA, 15 U.S.C.
       § 1692a(6).
    6. The activities of Defendants forming the basis of this Complaint
       concern the collection of debts from consumers, as the terms
       "debt" and "consumer" are defined in Sections 803(3) and 803(5) of
       the FDCPA, 15 U.S.C. §§ 1692a(3) and 1692a(5).

                    IN THE UNITED STATES DISTRICT COURT
                    FOR THE NORTHERN DISTRICT OF GEORGIA
                              ATLANTA DIVISION

                    UNITED STATES OF AMERICA, Plaintiff,

                                     v.

     PERIMETER CREDIT, L.L.C. and ACCOUNT PORTFOLIOS, INC., Defendants.

                              Civil Action No.

                               CONSENT DECREE

   WHEREAS, Plaintiff, the United States of America, has commenced this
   action by filing the Complaint herein; Defendants have waived service
   of the Summons and Complaint; the parties have been represented by the
   attorneys whose names appear hereafter; and the parties have agreed to
   settlement of this action upon the following terms and conditions,
   without adjudication of any issue of fact or law and without
   Defendants admitting liability for any of the matters alleged in the
   Complaint;

   THEREFORE, on the joint motion of Plaintiff and Defendants, it is
   hereby ORDERED, ADJUDGED, AND DECREED as follows:
    1. This Court has Jurisdiction of the subject matter herein and of
       the parties hereto.
    2. The Complaint states a claim upon which relief may be granted
       under Sections 5(m)(1)(A), 9, 13(b), and 16(a) of the Federal
       Trade Commission Act ("FTC Act"), 15 U.S.C. § § 45(m)(1)(A), 49,
       53(b), and 56(a); and Section 814 of the Fair Debt Collection
       Practices Act ("FDCPA"), 15 U.S.C. § 16921.
    3. For purposes of this Consent Decree ("Decree"), the definitions
       set forth in the FDCPA, 15 U.S.C.§ 1692a, shall apply.

                               CIVIL PENALTY
    4. Defendants, their successors and assigns, shall pay to Plaintiff,
       pursuant to Section 5(m)(1)(A) of the FTC Act, 15 U.S.C.
       § 45(m)(1)(A), a civil penalty in the amount of $300,000.00 due
       and payable on or before the fifth day following the entry of this
       Decree. This payment shall be made by electronic fund transfer in
       accordance with procedures specified by the Office of Consumer
       Litigation, Civil Division, United States Department of Justice,
       Washington, D.C. 20530.
    5. In the event of any default in payment, which default continues
       for ten (10) days beyond the due date of payment, the entire
       unpaid penalty, together with interest, as computed under 28
       U.S.C. § 1961 from the date of default until the date of payment,