UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. ____________ - Civ - __________________
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)
FEDERAL TRADE COMMISSION, )
)
Plaintiff, )
)
v. )
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GREETING CARDS OF AMERICA, INC., )
a Florida corporation; )
)
GERALD TOWBIN, )
also known as Alex Carr and John Grant, )
individually and as owner and operator of )
Greeting Cards of America; )
)
SUSAN TOWBIN, )
also known as Mary Grant and Sandy Grant, )
individually and as an officer of Greeting )
Cards of America; )
)
AMERICAN EAGLE PLACEMENTS, )
a Georgia company; and )
)
FORREST ADAMS, )
individually and as the owner and officer of )
American Eagle Placements, )
)
Defendants. )
)
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"), for its complaint
GREETING CARDS OF AMERICA, INC., GERALD TOWBIN, SUSAN TOWBIN,
Page 1 of 13
AMERICAN EAGLE PLACEMENTS, and FORREST ADAMS (collectively, "Defendants") alleges:
1. The FTC brings this action under Sections 5(a), 13(b) and 19 of the FTC Act, 15 U.S.C.
SNIPPETS:
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
GREETING CARDS OF AMERICA, INC., GERALD TOWBIN, SUSAN TOWBIN,
AMERICAN EAGLE PLACEMENTS, and FORREST ADAMS (collectively, "Defendants") alleges:
The FTC brings this action under Sections 5, 13and 19 of the FTC Act, 15 U.S.C.
Requirements and Prohibitions Concerning Franchising and Business Opportunity Ventures"
Venue in the United States District Court for the Southern District of Florida is proper
unfair or deceptive acts or practices in or affecting commerce, as well as enforcement of the
Franchise Rule, 16 C.F.R. § 436.
proceedings, by its own attorneys, to enjoin violations of the FTC Act in order to secure such
Defendant Greeting Cards of America, Inc., is a Florida corporation with its principal
GCA transacts or has transacted business
Defendant Gerald Towbin is the owner and operator of Greeting Cards of America,
He transacts or has transacted business in the Southern
Defendant Susan Towbin is an officer of Greeting Cards of America,
Defendant American Eagle Placements is a Georgia company with its
Defendant Forrest Adams is the owner and an officer of American Eagle Placements.
offered and sold business ventures involving greeting cards and display racks for the cards.
venture purchasers that, in exchange for a payment, ranging from $5,000 to $50,000,
profitable locations or sites for business venture purchasers' greeting cards and display
materials to prospective purchasers.
sample greeting cards, promotional brochures and pamphlets, and a disclosure document (the
The basic disclosure document in Defendants GCA, Gerald Towbin, and Susan Towbin's
the basic disclosure document fails to correctly identify the directors and executive
the disclosure document sent to consumers listed Ron Chocolaad as the CEO
John Grant and Mary or Sandy Grant, who are purportedly purchasers from Chicago, Illinois.
or visual earnings or profit representation ("earnings claim") it makes to a prospective
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