 |
 |
|
|
|
|
|
|
|
| | | |
|
|
|
|
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
1
.
AMENDED COMPLAINT
|
EXTRACTED KEY WORDS
LICENSE INTERNET ACT CONSUMERS COUNTRY FTC ACT VIOLATIONS IDP PRACTICES RELIEF UNITED STATES INTERNATIONAL DRIVERS AUTHORIZATION BUSINESS COURT ABRAHAM COMMISSION CAROLINE PLAINTIFF DISTRICT REPRESENTATIVES CONVENTION CREDIT CARD RESIDENTS GOVERNMENT DECEPTIVE ACTS CONTRACTS EQUITABLE RELIEF INTERNET WEBSITES |
UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF THE DISTRICT OF COLUMBIA
FEDERAL TRADE COMMISSION, Plaintiff,
v.
MOUNTAIN VIEW SYSTEMS, LTD.;
WHEELIE INTERNATIONAL LIMITED;
ALADDIN TRAVEL INC. doing business as Aladdin Financial Management and
University Systems;
S.C. HYACINTH S.R.L.;
JASON MATTHIEU ABRAHAM, also known as Yaakov Abraham;
CAROLINE SHALLON, also known as Caroline Abraham also known as Chaya
Rochel Abraham;
CHARLES FOGEL also known as Charlie Lewis;
Defendants. Case No. 1:03-CV-OOO21-RMC
AMENDED COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff Federal Trade Commission ("Commission"), by its undersigned
attorneys, for its complaint alleges:
1. The Commission brings this action under Section 13(b) of the FTC
Act, 15 U.S.C. § 53(b), to secure preliminary and permanent injunctive
relief, rescission of contracts, restitution, disgorgement, and other
equitable relief for defendant(s)' deceptive and unfair acts and
practices
in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
JURISDICTION AND VENUE
2. This Court has subject matter jurisdiction over Plaintiff's claims
pursuant to 28 U.S.C. §§ 1331(a), 1337(a), and 1345, and 15 U.S.C.
45(a) and 53(b).
3. Venue in the District of the District of Columbia is proper under
28 U.S.C.
§ 1391(d) and 15 U.S.C. § 53(b).
PLAINTIFF
4. Plaintiff Federal Trade Commission is an independent agency of the
United States
government created by the FTC Act, 15 U.S.C. §§ 41-58. The Commission
enforces the FTC Act, which prohibits unfair or deceptive acts or
practices in or affecting commerce. The Commission is authorized to
initiate federal district court proceedings by its own attorneys, to
SNIPPETS:
|
|
|
| | | |
|
|
