UNITED STATES DISTRICT COtJRT
EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
fWY - 7 2003
DAWD J. MALAND, CLERK
%my
IF`EDERAL TRADE cO~SSION,
hidiff,
V. Civil Action No. 4: c&Y 179
THE COLLEGE ADVANTAGE, INC.,
also doing business as College Funding
Center,
ALAN E. BARON,
C FUNDING GROUP, LLC, also doing
business as College Funding Group, and
EDWARD F. JACOBS,
Defendants.
COMPLAINT FOR PERMANENT INJUNCTION AND
OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for its complaint
against The College Advantage, Inc., doing business as College Funding Center, Alan E.
Baron, C Funding Group, LLC, doing business as College Funding Group, and Edward F.
Jacobs ("defendants"), alleges:
1. The Commission brings this action under Sections 5(a) and 13(b) of the
Pagelof 11
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. $6 45(a) and 53(b), to obtain
preliminary and permanent injunctive relief, rescission or reformation of contracts,
SNIPPETS:
also doing business as College Funding Center,
C FUNDING GROUP, LLC, also doing business as College Funding Group, and
Plaintiff, the Federal Trade Commission, for its complaint
Federal Trade Commission Act, 15 U.S.C. $6 45and 53, to obtain
preliminary and permanent injunctive relief, rescission or reformation of contracts,
restitution, disgorgement, and other equitable relief for defendants' deceptive acts or
the marketing of its college financial aid assistance program.
Plaintiff Federal Trade Commission is an independent agency of the United
charged, inter alia, with enforcement of Section 5of the FTC Act, 15 U.S.C. 9 45,
which prohibits unfair or deceptive acts or practices in or affecting commerce.
Commission is authorized to initiate federal district court proceedings, by its own attorneys,
including restitution for injured consumers.
corporation, with its principal place of business at 2828 West Parker, Plano, Texas 75026.
College Advantage conducts business under the name College Funding Center.
Advantage operates a college financial aid assistance program whose primary function is to
secure the tids for students to attend college.
At all times material to this complaint, acting alone or in concert with others, he has
Baron transacts or has transacted business in the Eastern District of Texas.
Defendant C Funding Croup, LLC is a Texas corporation, with its principal
This invitation letter contains numerous representations, including, but not
Consumers who wish to participate in the program must sign a contract and
defendants refuse to honor their 100% refund guarantee,
misleading and constitute deceptive acts or practices in violation of Section Sof the FTC
injunctions, consumer redress, rescission, restitution, disgorgement of profits resulting from
The Court, in the exercise of its equitable jurisdiction, may award other
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