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8 UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
9 AT SEATTLE
10 FEDERAL TRADE COMMISSION,
11 Civil No.
Plaintiff,
12 v.
13 DILLON SHERIF, A.K.A. NURALDIN SHAREEF COMPLAINT FOR
KARIM, DILLON SHAREEF, AND DILLON INJUNCTIVE AND OTHER
14 NARIMAN, D.B.A. ALS, GCI, GRAND EQUITABLE RELIEF
ALLIANCE SERVICE ("GAS"), PBI, POWER
15 BALL SERVICES ("PBS"), ROYAL
ENTERPRISES, AND ROYAL MARKETING
16 GROUP ("RMG");
MELISSA C. ROBINSON, D.B.A. ROYAL
17 MAJESTY SERVICES ("RMS"), ROYAL
INTERNATIONAL SERVICES ("RIS"), ROYAL
18 ENTERPRISES, AND MUTUAL AMERICAN;
SAUL SOMERSTEIN, A.K.A.
19 SAUL SOMERS, D.B.A. IMPERIAL MARKETING
SERVICE ("IMS"), ALLIANCE MARKETING
20 SERVICE ("AMS"), RMG, AND WORLD
MARKETING SERVICE ("WMS");
21 Defendants,
22 and
23 NARIMAN SABRI MIKDAD, A.K.A. NARIMAN
SHERIF;
24 AMINA MOHAMAD,
25 Relief Defendants.
26 Plaintiff Federal Trade Commission ("FTC" or "Commission") for its Complaint
27 1. The FTC brings this action under Sections 13(b) and 19 of the Federal
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FEDERAL TRADE
SNIPPETS:
ENTERPRISES, AND ROYAL MARKETING
23 NARIMAN SABRI MIKDAD, A.K.A. NARIMAN SHERIF;
Commission Act, 15 U.S.C. §§ 53and 57b, and the Telemarketing and
Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. § 6101 et seq., to
equitable relief for defendants' deceptive acts or practices in violation of Section 5of the
Act, 15 U.S.C. § 45, and the FTC's Trade Regulation Rule entitled "Telemarketing Sales
The Commission also seeks disgorgement, plus prejudgment interest,
20 The Commission may initiate federal district court proceedings by its own attorneys to
21 violations of the FTC Act and the TSR and to secure such equitable relief as may be
including restitution for injured consumers.
He has transacted business throughout the United States.
Sherif has transferred to Mohamad, for no apparent consideration, valuable assets in stock,
21 offering for sale, or sale, through telemarketing, of foreign lottery tickets or
22 connection with charging fees for promised winnings, in or affecting commerce, as
have convinced them to pay defendants substantial amounts of money.
consumers who purchase are likely or guaranteed to win large amounts of money.
that their winnings will far exceed this cost.
to win a large cash award if the consumer purchases lottery tickets from,
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