UNITED STATES DISTRICT COURT .
FORTHIt NORTHERN DISTRI~ OF ILLINtiIS
EASTEFW DMSION .
CI;ERK,
FED= TRADE COMMISSION,
Plaintiff,
V.
QT, lNC., Q-RAY, COMPANY,
BIGMETAL JNC., QUE TE PARK,
&.a ANDREW Q. PARK,
and JUNG JO0 PARR,
Defendants.
COMPLAINT FOR INJUNCI'l-VE AND OTHER EOUITABLE RELIEF
Plaintiff, the Federal Trade Commission (`l?K" or " Conmission"), thou@ its
undersigned attorneys, alleges e follows:
1. . The l?fC brings this action p-ant to Section 13(b) of the Federal Tiade
con;mission Act C'FI% Act"), 15 U.S.C. 4 53(b), to seeure temporary, preliminsay and
injunctive relief and other equitable relief against QT, Inc.; Q-Ray, Company, Bio-Metal, Inc.,
.
and their officers, Que Te Pa& (stk.a Andrew Q. Park) and Jung Joo Park, for mgaging in
deceptive acts or practiv and false advertising & connection with the advertising, marketing,
and sale of a purported pain-relief product called the Q-Ray Ionized Bracelet ("Q-Ray Bra&q
in viohtion'of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. 66 45(a) and 52.
JURISDICl'ION AND VENU&
2- This Coutt @s jurisdiction over this matter pursuant to 15 U.S.C. 59 45(a), 52,
and 53(b) and 28 USC: $5 1331,1337(a) and 1345.
SNIPPETS:
QT, lNC., Q-RAY, COMPANY,
BIGMETAL JNC., QUE TE PARK,
injunctive relief and other equitable relief against QT, Inc.;
and sale of a purported pain-relief product called the Q-Ray Ionized Bracelet ("Q-Ray Bra&q
in viohtion'of Sections 5and 12 of the FTC Act, 15 U.S.C. 66 45and 52.
and 53and 28 USC:
Venue in the United States District Court for the Northern District &Illinois is
false advertisements for f& drugs, devices, services, or cosmetics in or affecting commerce.
The FTC is authorized to initiate federal district court proceedings, by its own attorneys, to
enjoin violations of the FTC Act and to secure such equitable relief as may be appropriate in
Inc., is au Illinois corporation with its principal office or place of business at 680 Fargo
or has transacted business in this District, and throughout the United States, through the
others, Mr. Park has formulated, directed, controlled or participated in the acts and
Bracelet te the public, using advertisements in print media and the Internet and on cable
To induce consumers to purchase the Q-Ray Bracelet,
Had back pain for 5 years.
life, don't believe it.
just send your Q-Ray back for a full refund of your purchase price.
DR. TERMANINh After two and a half- almost two years of wearing the Q-Ray
DR. JAMES CHRISTIANSBN: Very true, very accurate, very reliable.
and also directs customers to the Defendants' website, www.qrav.com, to order.
did not receive the same Q-Ray 30-Day Satisfaction Guarantee that was advertisec`iu
These online purchasers instead received only a 3Oday "limited
Defend&s' law violations have injured consumers and will continue to injure
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