Counsel Submitting and Utah State Bar Number
Attorney For
Address
Telephone
UNITED STATES DISTRICT COURT
DISTRICT OF UTAH, CIVIL DIVISION
UNITED STATES OF AMERICA, )
)
PLAINTIFF, )
)
v. )
)
TURNKEY VENDING, INC., a Utah corporation, )
)
and )
)
MICHAEL S. BURNETT, individually and as an officer )
of the corporation, )
)
DEFENDANTS. )
)
Name of Case Case No.
Title of Document
Magistrate Judge's Name
COMPLAINT FOR CIVIL PENALTIES, CONSUMER REDRESS,
PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
Page 1 of 8
Plaintiff, the United States of America, acting upon notification and authorization to the
General by the Federal Trade Commission ("FTC" or "the Commission"), pursuant to Section 16(a)(1)
of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 56(a)(1), for its complaint alleges:
SNIPPETS:
Counsel Submitting and Utah State Bar Number
COMPLAINT FOR CIVIL PENALTIES, CONSUMER REDRESS,
Plaintiff, the United States of America, acting upon notification and authorization to the
General by the Federal Trade Commission,
a permanent injunction and other equitable relief for defendants' violations of the FTC's
Regulation Rule entitled "Disclosure Requirements and Prohibitions Concerning Franchising and
Opportunity Ventures" (the "Franchise Rule" or the "Rule"), 16 C.F.R. Part 436, and Section
FTC Act, 15 U.S.C. § 45.
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
Venue in the United States District Court for the District of Utah is proper under 28
Defendant Turnkey Vending, Inc., a Utah corporation with its principal place
course of trade in the offering for sale and sale of tabletop vending game business ventures,
commerce, as "commerce" is defined in Section 4 of the FTC Act, 15 U.S.C. § 44.
consumers to call defendants' toll-free telephone number to learn more about the opportunity.
business venture and the actual earnings of prior purchasers.
basis for the earnings claims at the time that they were made, and/or failed to disclose that
which constitute a reasonable basis for the claims,
have a reasonable basis for any oral, written, or visual earnings claim it makes, 16
the earnings claim is available to prospective franchisees,
In connection with the offering of franchises, as "franchise" is defined in Section 436.2
Section 19 of the FTC Act, 15 U.S.C. § 57b, authorizes this Court to grant such relief as
This Court, in the exercise of its equitable jurisdiction, may award ancillary relief to
|
