UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
_______________________________________________
)
FEDERAL TRADE COMMISSION, ))
Plaintiff, ))
v. )))
NATIONAL CRAFTERS, CORP., ) Case No.
and )
THOMAS FELIX DIAZ, JR., )))
Defendants ))
_______________________________________________ )
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"), for its complaint
alleges:
1. The Commission brings this action under Section 13(b) of the Federal Trade Commission
Act ("FTC Act"), 15 U.S.C. § 53(b), against Defendants, NATIONAL CRAFTERS, CORP.
("NATIONAL CRAFTERS") and THOMAS FELIX DIAZ, JR. ("DIAZ"), to obtain preliminary and
permanent injunctive relief against Defendants to prevent them from engaging in deceptive acts or
in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and to obtain other equitable
Page 1 of 8
including rescission of contracts, restitution, and disgorgement, as is necessary to redress
consumers and the public interest resulting from Defendants' violations of the FTC Act.
JURISDICTION AND VENUE
2. Subject matter jurisdiction is conferred upon this Court by 15 U.S.C. §§ 45(a) & 53(b), and
28 U.S.C. §§ 1331, 1337(a), and 1345.
3. Venue in this district is proper under 28 U.S.C. §§ 1391(b) and (c), and 15 U.S.C. § 53(b),
SNIPPETS:
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission, for its complaint
Act, 15 U.S.C. § 53, against Defendants, NATIONAL CRAFTERS, CORP.
consumers and the public interest resulting from Defendants' violations of the FTC Act.
FTC Act, 15 U.S.C. § 45, which prohibits unfair or deceptive acts or practices in or affecting
The FTC is authorized to initiate federal district court proceedings to enjoin violations of
Defendant NATIONAL CRAFTERS, CORP., is a Florida corporation with its principal
transacts or has transacted business in the Southern District of Florida.
He resides, transacts, or has transacted business in the Southern
of trade, in or affecting commerce, as "commerce" is defined in Section 4 of the FTC Act, 15
Through one or more of these marketing vehicles,
assemblers to invest by representing that Defendants need workers to assemble handcrafted or
American beaded bracelets in the workers' own homes for Defendants, and that Defendants will
Through one or more of these marketing vehicles, Defendants induce prospective work-at-home
deposit for the materials and instructions needed to assemble the bracelets.
Few, if any, of Defendants' work-at-home assemblers ever realize the earnings promised
work-at-home opportunities and soliciting consumers to pay money to become work-at-home
and other injury as a result of Defendants' deceptive acts or practices,
|
