IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
FEDERAL TRADE COMMISSION, Plaintiff,
v.
DR. CLARK RESEARCH ASSOCIATION, a corporation,
DR. CLARK BEHANDLUNGZENTRUM GMbH, d/b/a DR. CLARK ZENTRUM, a
corporation, and
DAVID P. AMREIN, individually and as an officer of both corporations,
Defendants.
Civ. No.
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "the Commission")
for its complaint alleges:
1. This is an action under Sections 5(a), 12, 13(b) and 15 of the
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a), 52,
53(b) and 55, in connection with the marketing and sale to the public
of various products, including the Super-Zapper Deluxe, Syncrometer,
the Dr. Clark's New 21 Day Program for Advanced Cancers, and the
Complete Herbal Parasite Program, (also called the Herbal Parasite
Cleanse).
JURISDICTION AND VENUE
2. This Court has subject matter jurisdiction over this matter
pursuant to 15 U.S.C. §§ 45(a), 52, 53(b) and 55, and 28 U.S.C.
§§ 1331, 1337(a) and 1345.
3. This Court has personal jurisdiction over the defendants pursuant
to 15 U.S.C. § 53(b).
4. Venue in the Northern District of Ohio is proper under 15 U.S.C.
§ 53(b) and 28 U.S.C. §§ 1391(b), (c), and (d).
PLAINTIFF
5. Plaintiff Federal Trade Commission is an independent agency of the
United States government created by statute. 15 U.S.C. §§ 41-58. The
Commission enforces Sections 5(a), 52, and 55 of the FTC Act, which
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
FEDERAL TRADE COMMISSION, Plaintiff,
DR. CLARK RESEARCH ASSOCIATION, a corporation, DR. CLARK BEHANDLUNGZENTRUM GMbH, d/b/a DR.
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF
the Federal Trade Commission ("FTC" or "the Commission") for its complaint alleges:
This is an action under Sections 5, 12, 13and 15 of the Federal Trade Commission Act, 15
This Court has subject matter jurisdiction over this matter pursuant to 15 U.S.C. §§ 45, 52,
This Court has personal jurisdiction over the defendants pursuant to 15 U.S.C. § 53.
Plaintiff Federal Trade Commission is an independent agency of the United States government
The Commission may initiate federal district court proceedings to enjoin violations of the
Defendant Dr. Clark Research Association is a California corporation which lists its address
Defendant DCRA has engaged in marketing, advertising, and selling activities for its products
Since at least 1999, defendants have engaged in a plan, program or campaign to sell the Dr.
e "devices" within the meaning of Sections 12 and 15 of the FTC Act, 15 U.S.C. §§ 52 and 55.
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