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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT FTC ACT CHAIN LETTER RECRUIT VIOLATION COMMISSION PRACTICES CONSUMERS SCHEME INTERNET RELIEF COURT DECEPTIVE ACTS FEDERAL TRADE DISTRICT COMPLAINT EQUITABLE RELIEF REPRESENTATIONS AFFECTING COMMERCE DEFENDANT PACHECO DISGORGEMENT REDRESS RHODE ISLAND STATUTE BULK SPAM INTERNET ADS MONEY SUBSTANTIAL INCOME PARAGRAPH |
UNITED STATES DISTRICT COURT
DISTRICT OF RHODE ISLAND
______________________________________________________)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. ) Civil No.
)
FERNANDO PACHECO, also known as )
FRANK PACHECO, )
individually and doing business as )
E-SOLUTIONS and )
E-SOLUTIONS 101 ))
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 District of Rhode Island 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
SNIPPETS:
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2
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STIPULATED FINAL JUDGMENT
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EXTRACTED KEY WORDS
PARTICIPATING MARKETING PROGRAM COMMISSION FTC PERMANENT COURT ACT HEREBY UNITED STATES FERNANDO PACHECO ENTRY EMPLOYEES AGENTS RECRUITS PERSONAL SERVICE PURSUANT SALES SCHEME DISTRICT STIPULATION JUDGEMENT PERMANENT INJUNCTION MATTER PURPOSES MULTI-LEVEL MARKETING PROGRAM PAYMENT OFFICERS ACTIVE CONCERT PARAGRAPH |
UNITED STATES DISTRICT COURT
DISTRICT OF RHODE ISLAND
______________________________________________________)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. ) Civil No.
)
FERNANDO PACHECO, also known as )
FRANK PACHECO, )
individually and doing business as )
E-SOLUTIONS and )
E-SOLUTIONS 101 ))
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 Fernando F.
Pacheco 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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