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1
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COMPLAINT
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EXTRACTED KEY WORDS
DONATIONS ACT CONSUMER CLIENT SOLICITING DONATIONS TELEMARKETERS FTC ACT PRACTICES CAI RELIEF VIOLATION AGENTS DONORS COURT TRANSACTS FLORIDA COMMISSION TAPS REPRESENTING TRANSACTED BUSINESS NON-PROFIT SOUTHERN DISTRICT DECEPTIVE ACT INJUNCTION COMPLAINT PLAINTIFF IMPLICATION CONTRACTS COMMERCE |
14 2003 1:18PM HP LflSERJET 3200
JJNITED. STATES DISTRICT COUkT
SOUTHEIRN DISTRICT OF FLORIDA
FEDERAL TRADE COMMISSION, . CIV-MARRII:
Plaintiff
Defendants /
,
Plaintiff, the Federal Trade Commission ("FTC"`or "Commission"), for its Complaint
alleges:
1. The Commission brings this action under Section 13(b) of the Federal Trade
Commission Act (V'T'C Act"), 15 U.S.C. 0 53(b), to obtain a permanent injunction and
preliminary injunctive relief against the defendants to prevent them f&n engaging in deceptive
acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. $45(a), and to obtain
other equitable relief, including rescission, restitution and disgorgernent as is necessary to
injury to consumers and the public interest re&Iting fkom defendants' violations of the FTC
2. Subject matter jurisdiction is conferred upon this Court by 15 U.S.C. @45(a) and
53(b) and by28 U.S.C. $0 1331, 1337(a), and 1345.
3. Venue in the Southern District of Florida is proper under 15 U.S.C. $53(b) and
28 U.S.C. $3 1391(b) and (c).
THEPARTIES
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