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1
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Government Exhibit # 1ST AMENDED COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PRACTICES CONSUMERS VIOLATION TRADE COMMISSION UNITED STATES DISTRICT FEDERAL TRADE COMMISSION RELIEF ABDOMINALS ABTRONIC DEVICE LAS VEGAS CONSUMER REDRESS ADVERTISEMENTS MUSCLES REPRESENTATIONS EXERCISES MAIL ORDER RULE INFOMERCIALS ATTORNEYS EQUITABLE RELIEF CONNECTION ADVERTISING AFFECTING COMMERCE TIMES RELEVANT CCI COMPLAINT ABDOMINAL AREA FEMALE TORSO |
1 KEITH FENTONMILLER
DAVID P. FRANKEL
2 EDWARD GLENNON
KIAL YOUNG
3 Attorneys for Plaintiff,
FEDERAL TRADE COMMISSION
4 600 Pennsylvania Ave., N.W.
Washington, D.C. 20580
5 Tel: (202) 326-2263/2812/3126/3525
Fax: (202) 326-3259
6
LOCAL COUNSEL:
7 DANIEL G. BOGDEN
United States Attorney
8 District of Nevada
By: BLAINE WELSH
9 Nevada Bar # 4790
Assistant U.S. Attorney
10 333 Las Vegas Boulevard, South, Suite 5000
Las Vegas, Nevada 89101
11 Tel: (702) 388-6534
Fax: (702) 388-6787
12
UNITED STATES DISTRICT COURT
13 DISTRICT OF NEVADA
14 )
FEDERAL TRADE COMMISSION, )
15 ))
16 Plaintiff, ))
17 v. )Docket
)
18 HUDSON BERKLEY CORPORATION, d/b/a )
HUDSON BERKELEY, INC., )
19 MATTHIAS GRANIC, )
BISMARCK LABS CORPORATION, d/b/a )
20 BLC BISMARCK LABS CORPORATION, )
TMI TRICOM MARKETING, INC., )
21 CCI CAD CAM INDUSTRIES LTD., INC., )
BERND EBERT, and OLIVER BRAUN, )
22 )
Defendants. )
23 )
24 FIRST AMENDED COMPLAINT
FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
25
Plaintiff, the Federal Trade Commission ("FTC" or "Commission") through its
26
SNIPPETS:
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2
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EXHIBIT 9
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EXTRACTED KEY WORDS
GEL PADS QUALITY FIRM ABS CLUB ORIGINAL ABTRONICTM BELT COMPUTER UNIT BATTERIES MANUFACTURING COMFORT THERAPY ADAPTER EXHIBIT MAINTENANCE NEOPRENE ENERGY REGULAR MEMBER USAGE FRIENDS RECOMMEND BOTTLES SLIMMING FIRMING GEL DISCOUNT REGULAR PRICE SHIPPING DOOR CANCEL FUTURE SHIPMENTS ANYTIME |
d . .* .% 0
IMPORTANT! NEWS MUST READ
Your AbTronicTM System in the carry bag includes:
1 x Microprocessor unit, blue, please snap onto the Neoprene
1 x Long Lasting Silicon Graphite Neoprene-Center Piece
1 x Belt long (to fit Neoprene Center Piece around the
1 x Belt short (free gift) (to fit Neoprene Center Piece
2 x Batteries (1 spare as a free gift)
1 x 4 oz. AbTronicTM Firming and Toning Gel (free Gift,
velvet blister insert, inside the bag)
1 x Instruction Manual
1 x Accelerated-Weight-Loss-Plan Booklet (free Gift)
1 x Butterfly Stick on Gel Pad (NEW, Free Bonus)
Congratulations, on purchasing the one and only Original
smart Electronic-Exercise System specifically designed to support
Athletic Enhancement and Body Building.
You have chosen the most advanced and best quality unit that
enjoy many years to come. Unlike any other system on the
original AbTronic TM has the unique patent pending Neoprene
was designed in Germany. It is made from a graphite silver
can not peel, crack or tear like those other belts that only
surface painted on or cheap,aluminum foil glued on.
Thanks to its unique space age compound the AbTronicTM is the
comfortable to wear and it will save you a lot of money and
you don't have to buy new belts again and again as you would
these other systems.
With your new original AbTronic TM you can rest assured that
and safest system for your body and health. Thanks to its
design you can also choose from the many accessories available
your AbTronicTM system. Without the need to buy any new
inexpensively convert your original AbTronic TM to a totally
the most advanced system to target cellulite or to a
ones used by many Chiropractors and Clinics
0 x NEW: Included as a bonus is this exclusive
"Butterfly" Gel pad that converts your AbTronicTM
to a totally wireless massage svstem.
Just snap the AbTronicTM unit directly onto this
butterfly pad and place the self adhesive Gel Pad
on any area you want to treat. Enjoy a relaxing
SNIPPETS:
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3
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EXHIBIT 8
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EXTRACTED KEY WORDS
BELT ABS BATTERY TAP MASSAGE CONTRACTIONS EXERCISE HINT NEOPRENE UPPER SWITCH GEL ABTRONICTM THIGH INTENSITY TISSUE WIII GEL PAD LED LIGHTS EPILEPSY MRNUTES TONING GEL POSTURE CRUNCH CRAZE MUSCLE GROUP CONTRACT TIGHTENS BUTTERFLY PADS BELT PLACEMENT LOW INTENSITY |
Exhibit 8 '
IMPORTANT! SEE RESULTS QUICKLY!!
Please read the complete instruction manual before you use the
Your Fitness System comes with the effective Extra
located underneath the black velvet inside your bag. It is specifically
enhance the effects of your workout and it contains
an
Extra Strength Formula to be most efficient.
1. HOW IT WORKS
The AbTronic"" is not your ordinary massager.
electronic stimulation to contract and release
your own muscles moving. Do NOT expect any
at all
When you switch the unit on, the LED light WIII come on, Indicating
AbTronic`"' is working properly. After you have placed the belt and
directly onto the area you want to work on, you should switch the unit on. When
LED light starts flashinq, the stimulation WIII be on. You will
ensation.
Adjust intensrty by pressing the High/Low buttons
increases or decreases the intensity by one notch.
0 z HINT! In order to obtain proper muscle contractions, you need to use plenty
of conductive AbTronicrh gel on the two areas to the left and right
sticker on the inside of the AbTronic-"' neoprene
and comfort always put a qenerous dab of the FIRMING
two contact areas.
- DO NOT USE WATER ONLY '
- DO NOT BEND your Neoprene Center
- Do your first exercise on your UPPER
NOT over your belly button.
2. HOW TO ACHIEVE MAXIMUM RESULTS
The AbTronic-" will work on some muscles that probably
before. The AbTronic-"' really works and delivers on
you. However, consistency is the key to a younger
days don't forget to use your AbTronic"" every day.
Same like you can't go to the Gym for the first trme and expect
abs the next day, It will take a little time to reclarm that proper
people will see noticeable results within 4 weeks.
let the AbTronic"" do the work for you. It is good for you: it's easy, very
and
SNIPPETS:
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6
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PRACTICES CONSUMERS VIOLATION TRADE COMMISSION UNITED STATES COMPLAINT EQUITABLE RELIEF FEDERAL TRADE COMMISSION DISTRICT BLC ABDOMINALS ABTRONIC DEVICE EXERCISE CONSUMER REDRESS ABDOMINAL MUSCLES ADVERTISEMENTS ORDER RULE REPRESENTATIONS ATTORNEYS PLAINTIFF CONNECTION ADVERTISING AFFECTING COMMERCE INFOMERCIALS ABDOMINAL AREA FEMALE TORSO PARAGRAPH FITNESS SYSTEM |
1 WILLIAM E. KOVACIC
General Counsel
2
KEITH FENTONMILLER
3 EDWARD GLENNON
KIAL YOUNG
4 Attorneys for Plaintiff,
FEDERAL TRADE COMMISSION
5 601 Pennsylvania Ave., N.W.
Mail Drop S-4002
6 Washington, D.C. 20580
Tel: (202) 326-2263
7 Fax: (202) 326-3259
8 LOCAL COUNSEL:
DANIEL G. BOGDEN
9 United States Attorney
District of Nevada
10 By: BLAINE WELSH
Nevada Bar # 4790
11 Assistant U.S. Attorney
333 Las Vegas Boulevard, South, Suite 5000
12 Las Vegas, Nevada 89101
Tel: (702) 388-6534
13 Fax: (702) 388-6787
14 UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
15 )
16 FEDERAL TRADE COMMISSION, ))
17 )
Plaintiff, )
18 )
v. )
19 )
HUDSON BERKLEY CORPORATION, d/b/a )
20 HUDSON BERKELEY, INC., )
MATTHIAS GRANIC, )
21 BISMARCK LABS CORPORATION, d/b/a )
BLC BISMARCK LABS CORPORATION, )
22 TMI TRICOM MARKETING, INC., )
CCI CAD CAM INDUSTRIES LTD., INC., and )
23 BERND EBERT, ))
24 Defendants. )
)
25
26 COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
SNIPPETS:
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7
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EXHIBIT 6
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EXTRACTED KEY WORDS
ABTRONICTM CARD EASY PAYMENTS ONE-STOP-SHOP CUSTOMER SERVICE AIR COMFORTABLE TONING DEVICE BELT MUSCLE EXERCISE-SYSTEM SUPPORT BODY ATHLETIC ENHANCEMENT PRIZES BODY BUILDING WINNER SIMPLEST TONING GEL INSTANTWIN APPLIANCES ABTRONICTM SYSTEM EXERCISE BAKEWARE COMPUTERS CONTRACTIONS TROUBLE VIEWING VIDEO NEOPRENE FIRM ABS CLUB INTENSITY RECOMMEND |
Gww.80"Owebmall.com - The Best One-Stop-Shop To Buy As Seen on TV
Page 1 of 2
New Products 1
1 Customer Service
b*/elcome to
ormation Thursday - March 07.2002
AbTronic
The smart Electronic-
Exercise-System specifically
f designed to support Body
Toning, Athletic Enhancement
and Body Building. The
winner simplest, smallest and most
comfortable toning device
ever! Order yours-today for
Appliances
. .-. --...-I-. "XI. -.-- .l-.l..-.l. - ^ ^
four easy payments of $29.95
Automotive
-1"11--- -.-.-, "-,-~.-""_."..
plus s&h.
Bakeware
4 payments
BeaLlt)!
More Info...
I"II.-.II"IIIX.-"III -,., -,ll." ,-I,II1,,.-,l,
","-." .,,_,.,.
of $29.95
E3ookslMagazines
" " .-,., _ ^ __ ^ ,^ ^I _._ _ .^ " "-
SNIPPETS:
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8
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EXHIBIT 4
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EXTRACTED KEY WORDS
MARYLAND FITNESS SYSTEM THIGHS ARMS TRANSCRIPTION GUARANTEE PAD FIRMING GEL MATTER ABTRONIC ELECTRONIC FITNESS TAPE ABS BUNS BELTS FIT WARRANTY WEIGHT LOSS LIFETIME WARRANTY SETTINGS EASY PAYMENTS ABTRONIC ADVANCED WEIGHT WEIGHT LOSS BOOK SPARE LONG-LASTING BATTERY ABTRONIC SLIM STRENGTH FORMULA PURCHASE HANDSOME TRAVELING BAG ABSOLUTELY FREE |
1 OFFICIAL TRANSCRIPT PROCEEDING 2 FEDERAL TRADE COMMISSION 3 4 5 6 MATTER NO. 0223145 7 8 TITLE ABTRONIC ELECTRONIC FITNESS SYSTEM 9 10 DATE RECORDED: JANUARY 23, 2002 11 TRANSCRIBED: FEBRUARY 14, 2002 12 13 PAGES 1 THROUGH 9 14 15 16 17 VIDEOTAPE 18 ABTRONIC FITNESS SYSTEM COMMERCIAL 19 20 21 22 23 24 25SNIPPETS: |
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9
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EXHIBIT 2
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EXTRACTED KEY WORDS
MARYLAND WALDORF ABS MUSCLES ELECTRONICS STOMACH FLOOR WORKOUT SIT-UPS EXERCISE CONTRACTION INCHES ABDOMINALS SWEAT PURCHASE WEIGHT LOSS BOOKLET MUSCLE TONE TIGHTENS MUSCLES CONTRACT SECOND SHORTER BELT INTENSITY LEVELS ELECTRONIC DREAM MACHINE GUARANTEE SPECIAL ABTRONIC SLIM WATCHING TELEVISION PAYMENTS NORMAL PRICE PROFESSIONAL ATHLETES MUSCLE STIMULATION |
1 OFFICIAL TRANSCRIPT PROCEEDING 2 FEDERAL TRADE COMMISSION 3 4 5 6 MATTER NO. 0223145 7 8 TITLE ABTRONIC ELECTRONIC FITNESS SYSTEM 9 10 DATE RECORDED: APRIL 30, 2001 11 TRANSCRIBED: FEBRUARY 14, 2002 12 13 PAGES 1 THROUGH 44 14 15 16 17 VIDEOTAPE 18 ABTRONIC FITNESS SYSTEM INFOMERCIAL 19 20 21 22 23 24 25SNIPPETS: |
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