UCJITED  STA'J'ES  DISTRICT                           COURT 
                                       NORTHERN  DISTRICT  OF  GEORGIA                             
                                                                                                   
                                                                 1
                                                                 1              Civ.  No.
FEDERAL  TWX                      COmTSSION,

           Plaintiff,

       v.

ALYON  TECmOLOGIESr                       INC.,
           a  Delaware              corporation;

TELCOLLECT,  INC.,
           a  New  York  corporation;
           and

STEPWANE  TOUBOUL,
           individually                and  as  an
           officer          of  Alyon
           Technologies,                 Inc.,

       Defendants.

           Plaintiff,               the  Federal          Trade  Commission                      

`CommissioW)                 ,  for  its           complaint            alleges:

           1.          The  Commission               brings            this       action       

and  19  of  the  Federal                     Trade  Commission                          Act  ("FTC

'~5  53(b)  and  sib,                  and  the  Telephone                       Disclosure        

Resolution                Act  of  1992  (Yt'DDRAN),                      15  U.S.C.            $ 

secure            a  permanent           injunction,              preliminary                 

rescission                of  contracts,              restitution,                  disgorgement,  
                                                                                   I
equitable              relief        for  defendants'                   unfair            or 

practices              in  violation               of  Section            5(a)  of  the  FTC  Act, 


§  45(a),               and  the  FTC's                   Trade        Regulation