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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT FTC ACT CHAIN LETTER RECRUIT PRACTICES VIOLATION COMMISSION CONSUMERS SCHEME INTERNET RELIEF DECEPTIVE ACTS FEDERAL TRADE COURT COMPLAINT EQUITABLE RELIEF REPRESENTATIONS DISTRICT AFFECTING COMMERCE SPAM DISGORGEMENT REDRESS STATUTE BULK SPAM NUMEROUS INSTANCES INTERNET ADS SUBSTANTIAL INCOME MONEY PARAGRAPH |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. _________________ Civ. _______________
______________________________________________________)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. ))
DARIO VA, ))
Defendant. )
______________________________________________________)
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for its Complaint
alleges as follows:
1. The Commission brings this action under Section 13(b) of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. § 53(b), to obtain permanent injunctive relief against
the defendant to prevent him from engaging in deceptive acts or practices in violation of
Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and to obtain other equitable relief, including
rescission, restitution, and disgorgement, as is necessary in order to redress injury to consumers
and the public interest resulting from the defendant's violations of the FTC Act.
JURISDICTION AND VENUE
2. Subject matter jurisdiction is conferred upon this Court by 15 U.S.C. § 53(b) and
28 U.S.C. §§1331, 1337(a), and 1345.
3. Venue in the United States District Court for the Southern District of Florida is
proper under 15 U.S.C. § 53(b) and 28 U.S.C. §§ 1391(b) and (c).
PLAINTIFF
4. Plaintiff, the Federal Trade Commission, is an independent agency of the United
States Government created by statute. 15 U.S.C. §§ 41 et seq. The Commission enforces
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2
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STIPULATED FINAL JUDGMENT
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EXTRACTED KEY WORDS
PARTICIPATING COMMISSION MARKETING PROGRAM FTC PERMANENT ACT HEREBY ENTRY COURT FEDERAL TRADE COMMISSION DARIO EMPLOYEES AGENTS RECRUITS PERSONAL SERVICE SALES PURSUANT SCHEME JUDGEMENT PERMANENT INJUNCTION TRADE COMMISSION MATTER DISTRICT PURPOSES MULTI-LEVEL MARKETING PROGRAM PAYMENT OFFICERS ACTIVE CONCERT PARAGRAPH |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. _________________ Civ. _______________
______________________________________________________)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. ))
DARIO VA, ))
Defendant. )
______________________________________________________)
STIPULATED FINAL JUDGMENT AND ORDER
FOR A PERMANENT INJUNCTION
Plaintiff, Federal Trade Commission ("Commission"), has filed a Complaint for
permanent injunction and other relief in this matter pursuant to Section 13(b) of the Federal
Trade Commission Act ("FTC Act"), 15 U.S.C. § 53(b), charging defendant Dario Va with
violations of Section 5 of the FTC Act, 15 U.S.C. § 45(a). The parties have agreed to entry of
this Stipulated Final Judgment and Order for Permanent Injunction ("Order") by this Court to
resolve all matters in dispute in this action without trial. Pursuant to agreement and stipulation,
IT IS HEREBY ORDERED, ADJUDGED AND AGREED as follows:
FINDINGS
1.
1. This Court has jurisdiction over the subject matter of this case and over the defendant;
2. The Complaint states claims upon which relief may be granted against the defendant
under Sections 5(a) of the FTC Act, as amended, 15 U.S.C. §§ 45(a);
3. Venue in this district is proper under 28 U.S.C. §§ 1391(b) and (c) and 15 U.S.C. § 53(b);
4. The acts and practices of the defendant were or are in or affecting commerce, as
"commerce" is defined in Section 4 of the FTC Act, 15 U.S.C. § 44;
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