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<clarkassn.htm>News Release ||| <../../index.htm>Quackwatch Home Page

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

FEDERAL TRADE COMMISSION, Plaintiff,

v.

DR. CLARK RESEARCH ASSOCIATION, a corporation,

DR. CLARK BEHANDLUNGZENTRUM GMbH, d/b/a DR. CLARK ZENTRUM, a corporation, and

DAVID P. AMREIN, individually and as an officer of both corporations,

Defendants.

Civ No. 1:03CV0054

COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF

Plaintiff, the Federal Trade Commission ( " FTC " or " the Commission " ) for its

complaint alleges:

1. This is an action under Sections 5(a), 12, 13(B) and 15 of the Federal

Trade Commission Act ( " FTC Act " ), 15 U.S.C. §§ 45(a), 52, 53(B) and 55, in

connection with the marketing and sale to the public of various products,

including the Super-Zapper Deluxe, Syncrometer, the Dr. 's New 21 Day

Program for Advanced Cancers, and the Complete Herbal Parasite Program,

(also called the Herbal Parasite Cleanse).

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction over this matter pursuant to

15 U.S.C. §§ 45(a), 52, 53(B) and 55, and 28 U.S.C. §§ 1331, 1337(a) and 1345.

3. This Court has personal jurisdiction over the defendants pursuant to 15

U.S.C. § 53(B).

4. Venue in the Northern District of Ohio is proper under 15 U.S.C. § 53(B)

and 28 U.S.C. §§ 1391(B), ©, and (d).

PLAINTIFF

5. Plaintiff Federal Trade Commission is an independent agency of the

United States government created by statute. 15 U.S.C. §§ 41-58. The

Commission enforces Sections 5(a), 52, and 55 of the FTC Act, which

prohibit unfair or deceptive acts or practices, including false

advertising, in or affecting commerce. The Commission may initiate federal

district court proceedings to enjoin violations of the FTC Act and to

secure such equitable relief as may be appropriate in each case, including

restitution for injured consumers. 15 U.S.C. § 53(B).

DEFENDANTS

6. Defendant Dr. Research Association ( " DCRA " ) is a California

corporation which lists its address at 8135 Engineer Road, #2748, San

Diego, California 92111. The affairs of defendant DCRA are controlled

entirely by the other two defendants. Defendant DCRA has engaged in

marketing, advertising, and selling activities for its products directed to

consumers in the Northern District of Ohio and throughout the United States.

7. Defendant Dr. Behandlungzentrum GMbH ( " DCZ " ) is a corporation

existing under the laws of Switzerland with its official domicile at

Bielstrasse 12, CH-3053 Munchenbuchsee, Switzerland. It has also used the

address of Sonnhaldenstrasse 30, 6052 Hergiswil, Switzerland. It does

business as Dr. Zentrum. Defendant DCZ has engaged in marketing,

advertising, and selling activities for its products directed to consumers

in the Northern District of Ohio and throughout the United States.

8. Defendant P. Amrein is a citizen and resident of Switzerland whose

business addresses are the same as those of the other two defendants. He is

the sole officer and director of both DCRA and DCZ. At all times material

to this Complaint, acting alone or in concert with others, defendant Amrein

has formulated, directed, controlled or participated in the acts and

practices of DCRA and DCZ, including the acts and practices set forth in

this Complaint. Acting through DCRA and DCZ, defendant Amrein has engaged

in marketing, advertising, and selling activities for the products offered

by DCRA and DCZ directed to consumers in the Northern District of Ohio and

throughout the United States.

9. All Defendants have directly solicited business over the Internet and by

other means from consumers in the Northern District of Ohio and throughout

the U.S. by posting web sites for their products directed at U.S.

consumers, by directing advertisements for their products toward U.S.

consumers, and by enabling users throughout the United States to purchase

products online from their web sites.

COMMERCE

10. At all times relevant to this complaint, Defendants have maintained a

substantial course of trade in or affecting commerce, as " commerce " is

defined in Section 4 of the FTC Act, 15 U.S.C. § 44.

DEFENDANTS' COURSE OF CONDUCT

11. Since at least 1999, defendants have engaged in a plan, program or

campaign to sell the Dr. 's New 21 Day Program for Advanced Cancers,

the Complete Herbal Parasite Program (also called the Herbal Parasite

Cleanse and which contains common cloves, black walnut hulls and wormwood

and other products that are or contain " foods or drugs " within the meaning

of Sections 12 and 15 of the FTC Act, 15 U.S.C. §§ 52 and 55 -- and the

Super-Zapper Deluxe, the Syncrometer and other products that are " devices "

within the meaning of Sections 12 and 15 of the FTC Act, 15 U.S.C. §§ 52

and 55.

12. To induce consumers to purchase the products named in Paragraph 11

above, defendants have disseminated or caused to be disseminated, via the

Internet and other means, advertisements and ordering information for the

above-described products, including, but not necessarily limited to, the

attached Plaintiff's Exhibits ( " PXs " ) 1 through 12. These advertisements

contain the following statements that were found at defendants'

interconnected Internet websites, which they name " www..com " and

" www..net: "

----------

Electricity can now be used...

....to kill bacteria, viruses and parasites in minutes, not days or weeks as

antibiotics require.

If you have been suffering from a chronic infection or have cancer, or

AIDS, learn to build the electronic device that will stop it immediately or

buy one [link to web page www..net/utilities/b & p.htm]. It is safe

and without side effects and does not interfere with any treatment you are

now on. (From: " The Cure for all Diseases " , after cover; copyright notice

[link to web page www.net/utilities/copyright.htm]) .

.......

Any positively offset [DC] frequency kills all bacteria, viruses and

parasites simultaneously given sufficient voltage (5 to 10 volts), duration

(seven minutes), and frequency (anything from 10 Hz to 500'000 Hz).

But it takes more than one treatment. It takes three treatments to kill

everything. Why? The first zapping kills viruses, bacteria and parasites.

But a few minutes later, bacteria and viruses (different ones) often recur.

I conclude they had been infecting the parasites, and killing the parasites

released them. The second zapping kills the released viruses and bacteria,

but soon a few viruses appear again. They must have been infecting some of

the last bacteria. After a third zapping I never find any viruses, bacteria

or parasites, even hours later. (From: " The Cure for All Diseases " , p.

13ff.; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order a Zapper

Order the book

Order other products

[link to web page www..net/utilities/b & p.htm]

PX 1, from www..net

----------

Dr. 's Plate Zapping Technique

New Zapping Technique: Plate Zapping

Dr. Hulda 's zapper has not changed since its invention - or rather

discovery? - in 1994. It is reliable and can achieve dramatic results, as

confirmed by hundreds of testimonials. But a good researcher is never quite

satisfied with what is good - because there may always be better or faster

results. As detailed in " The Cure for All Advanced Cancers " , Dr. Hulda

has been working a lot with supplements, vitamins and minerals, and

ozonization; recently she has focused more on essential oils among others.

Now she has found it time to re-examine the zapper concept and find ways to

zap even more effectively.

PCBS PREVENT EFFECTIVE ZAPPING

Most patients get fast results from using Dr. Hulda 's zapper. But

with some patients, the success was limited. Dr. found out that those

patients had PCBs preventing the zapper from being effective. Besides this,

PCBs are another factor reducing immunity, besides benzene, asbestos and

lanthanides that were elaborated on in earlier issues of the Bulletin.

PCBs are found in commercial soaps and pesticides (which may occur in

treated wood in homes; produce). The source must be found and eliminated as

always. Then, PCBs can be eliminated from the body by taking ozonated olive

oil (see separate article on ozonization), which takes 2-3 weeks.

PLATE ZAPPING: COMBINING ZAPPER AND SYNCROMETER TECHNIQUES

Then, Dr. made many experiments with different zapper techniques.

They are not actually changes in the zapper circuit, but much rather

additions to the existing zapper circuit. But Dr. was only ready to

talk about one of the new zapper techniques, which she calls plate zapping,

while the others have not progressed enough and been tested enough to be

released.

The Syncrometer uses test plates to test for pathogens and substances in

the human body. It is a simple oscillating circuit with a 1000 Hz base

frequency which is modulated by the frequencies that are fed into the

circuit by the capacitor plates.

It is also possible to narrow the search for toxins and pathogens down to a

specific organ in the body by placing an organ slide on the second test

plate (the " anatomy plate " , therefore).

Now, Dr. has used this technique with the zapper: She simply

connected two test plates to the zapper circuit. It does not matter where

the capacitors are fed into the circuit, but Dr. stresses they should

be on the " hot " side (the red on the Super Zapper DeLuxe).

The plates can now be used to narrow the zapping down to an organ or a

pathogen. This is very specific zapping and has proven to be much more

effective for the organ or pathogen on the slide (while being less

effective for the others). It is also possible to place organs and

pathogens on the plates at the same time; as well as placing several organs

and pathogens on the plates ( " loading the plates " ) - but then the effect

gets more diluted again.

Finally, it has become possible to zap the intestines with the plate

zapping technique. The intestines have been shielded from regular zapper

current. But they can't resist plate zapping current. " Almost all our

cancer patients now find parasites in their stool " , Dr. said on our

last visit to her office, and she showed us little baggies with textbook

examples of parasites from the patients. " I have the patients bring them to

the office. If they find no parasites I know we are missing something " .

SUMMARY

What is plate zapping? -- It means using the zapper with capacitor plates

attached. On the plates you can put slides of anatomy or pathogens to

specifically zap the organ or the pathogen that is on the plate.

Who is plate zapping for? -- Any patient could use it, but since you need

the slides its costs makes it appear more suitable for advanced patients.

How can you plate zap? -- Take Syncrometer plates (or make your own plates

with aluminum foil and cardboard), and connect them to the zapper, for

example with a double alligator clip lead. Make sure you attach it to the

" hot " side (usually red). You can also get plates and a ready made

connection cable on the order form here. You need slides of whatever

pathogens or organs you want to zap specifically. Dr. has initiated a

special digestive kit, because now it is possible to zap the digestive

tract also. You can get slide kits on the order form or single slides from

a biological supply company.

PX 2, from www..net

----------

Welcome to the Dr. Hulda Cancer Page

Dear Visitor

You came here to find out more about Dr. Hulda 's approach to Cancer.

Dr. Hulda is the researcher who claims: " Cancer can now be cured! "

I can imagine that the first things you are interested to know is

Who is Dr. Hulda ?

What are her findings about Cancer?

How have those findings been corroborated?

...........................

Dr. 's work is based on bio-feedback testing (the Syncrometer),

with which she determines the ACTUAL CAUSES of cancer and other health

conditions. Knowing the cause will open the door to prevention and

treatment. For this purpose Dr. Hulda uses a large number of

approaches in natural medicine, but ALL TARGETED AT THE EXACT CAUSE of the

conditions.

............................

In her first book about cancer " The Cure for All Cancers " , Dr. Hulda

examined the EXACT CAUSES of malignancy, i.e. cancer. In an update 1998 she

added the make-up of a tumor, which comes before a malignant tumor mass. In

her second cancer book, " The Cure for All Advanced Cancers " , Dr.

mapped out a lot more steps from a healthy individual to a person with

cancer. It includes a lot more information about tumors, low immunity and

how to shrink tumors. The " 21 Day Program " is laid out in this book. Her

third book about cancer is called the " Syncrometer Science Laboratory

Manual " . It contains the most advanced procedures for shrinking tumors, the

" Mostly Zapping Program " .

.............................

How have those findings been corroborated?

Dr. Hulda has treated over 2,000 cancer patients in the last 15

years. Her techniques have evolved from rather crude to an exact science

during this time. While she used to have all kinds of cancer patients, she

now takes terminal cases only -- she feels the others can do it out of the

book.

You may ask why no university has confirmed her work yet. The reason is

simple, it has not been tested. It is one of the goals of this Association

to do this kind of clinical work. We have started with some research about

Dr. 's zapper first. I have visited and communicated with many

research institutes, and it is very hard to find one that is both qualified

and interested in cooperating for such a research effort. Finally, the

money for such studies is not easily found.

But consider this: The chance of a " spontaneous remission " of terminal

cancer is 1:60,000. That means that out of 60,000 cases one will live. You

can imagine that it does not take many cases to make this statistically

relevant. It would be like watching a person walk over water and ask for a

research study about it to prove it was statistically relevant.

And testimonials we do have galore. You can find them here:

http://www..net/testimonials/testiframe.htm , and this is only a

small fraction of the many we have in our files!

PX 3 from www..net

----------

Cancer Testimonial #0016

Two and half years ago I got terminal liver cancer (primary) and was given

2 to 6months to live. First I used Breuss and after three months Dr.

's cancer cures for the next 15 months. I am 59 years old, feel great

and looking for a job. I had hepatitis B for a long time and my liver was

badly damaged. Many people diagnosed with cancer after me are dead, killed

by orthodox methods. I didn't use any of them. My story was on TV channel

7, Today Tonight program verifying all CAT scans . Also, I could guarantee

with my life that no cancer patient would die from cancer using Dr. 's

treatments. This was not a fluke. I am an engineer for atomic and nuclear

physics and I could understand and compare both treatments. I have all CAT

scans and I would do everything possible to help Dr. . Without her

treatment I would not be alive.

For any help please do not hesitate to call or write.

Yours Sincerely,

V.

PX 4, from www..net

----------

Dr. 's New 21 Day Program for Advanced Cancers

The 21 day program is described in detail in Dr. 's new book " The Cure

for All Advanced Cancers " . Caution: It is intended for severely ill

patients and not for prevention purposes.

We have seen amazing results in hopeless cases with this program that are

nothing short of miraculous. But bear in mind that

1. the dental clean-up and other clean-ups are still the core of the therapy;

2. no therapy in medicine works in 100% of the cases, and be it just for

lack of correct application;

3. the best results are only possible if Syncrometer testing is available.

Excellent results are possible without if a radical approach is chosen, but

Syncrometer testing definitely makes improved care possible.

PX 5, from www..net

----------

Cancer can now be CURED, not just treated

We are not accustomed to thinking about a cure for cancer. We think of

remission as the only possibility. But this book is not about remission. It

is about a cure. This is possible because in 1990 I discovered the true

cause of cancer. The cause is a certain parasite, for which I have found

evidence in every cancer case regardless of the type of cancer. So lung

cancer is not caused by smoking, colon cancer is not caused by a

low-roughage diet, breast cancer is not caused by a fatty diet, retinal

blastoma is not caused by a rare gene, and pancreatic cancer is not caused

by alcohol consumption. Although these are all contributing factors, they

are not THE cause. Once the true cause was found the cure became obvious.

But would it work? I set a goal of 100 cases to be cured of cancer before

publishing my findings. That mark was passed in December, 1992. The

discovery of the cause and cure of all cancers has stood the test of time

and here it is! (From: " The Cure for all Cancers " , after cover; copyright

notice)

PX 6, from www..net

----------

You may not have time...

....to read this entire book first if you have cancer and are scheduled for

surgery, chemotherapy or radiation treatment. You may wish to skip the

first pages which describe how cancer develops.

Go directly to the cancer curing recipe and order your supplies [link to

web page www..net/utilities/b & p.htm]. Using the herbal recipe [link

to web page www..net/disease/p_cleanse.htm] together with the zapper

[link to web page www..net/disease/zapper.htm] is best. It only

takes days to be cured of cancer regardless of the type you have. It does

not matter how far progressed the cancer is, you can still stop it in 5 days.

After you have stopped the cancer, you can turn your attention to getting

well. Read the case histories to see how easy it is to stop even terminal

cancer. Learn from them to avoid mistakes.

Does this mean you can cancel your date for surgery, radiation or

chemotherapy? YES! After curing your cancer with this recipe it cannot come

back. This is not a treatment for cancer: It is a cure! But if you do not

wish to make your doctor angry, you could follow her or his wishes, too. Be

careful not to lose any vital anatomical parts in surgery though, because

you may need them later when you are healthy!

Remember that oncologists are kind, sensitive, compassionate people. They

want the best for you. They have no way of knowing about the true cause and

cure of cancer since it has not been published for them. I chose to publish

it for you first so that it would come to your attention faster. (From:

" The Cure for all Cancers " , after cover; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order your supplies

Order the book

[link to web page www..net/utilities/b & p.htm]

PX 7, from www..net

----------

The Basis of the Discoveries

I have indicated throughout this book the existence of pollutants in food

and other products. These pollutants were identified using a testing device

of my invention known as the Syncrometer. Complete instructions for

building and using this device are contained in this book. Therefore anyone

can repeat the tests described and verify the data.

The Syncrometer is more accurate and versatile than the best existing

testing methods. A method for determining the degree of precision is also

presented. However at this point it only yields positive or negative

results, it does not quantify. The chance of a false positive or a false

negative is about 5%, which can be lessened by test repetition.

PX 8, from www..net

----------

53 CURED Cases the First Year

Cure, not treatment, is the subject of this book. In 1991 I discovered the

source of HIV. Once the source became clear the cure became obvious. But

would it work? After curing 53 cases in a row, all who used this method, I

could wait no longer to present these findings. Since that time many more

have been cured, too many to be added to this book[*]. Most important is

adding yourself to that list! (From: " The Cure for HIV/AIDS " , after cover;

copyright notice [link to web page www..net/utilities/copyright.htm].

[* In the most recent edition of the book five cases verified by PCR lab

testing for HIV have been added.]

PX 9, from www..net

----------

You may not have time...

....to read this entire book first if you are sick with AIDS. You may wish

to skip the part about how HIV infection is caused and go directly to the

HIV Curing Recipe. Order your supplies [link to web page

www..net/utilities/b & p.htm]. Follow the recipe exactly; it was

carefully worked out for you. It takes 5 days to be cured of HIV regardless

of how ill you are. After you have eliminated the virus, you can turn your

attention to getting well from AIDS. Read the case histories to see how

easy it is to stop even terminal AIDS. Learn from them to avoid mistakes.

Or you may zap [link to web page www..net/disease/zapper.htm] the

virus with electricity for 7 minutes and eliminate it that way. Build or

purchase [link to web page www..net/utilities/b & p.htm] a zapper

immediately. Using the herbal recipe [link to web page

www..net/disease/p_cleanse.htm] along with the zapper is best.

Does this mean you can cancel your appointment with your clinical doctor?

No, it does not. Although you will not need HIV-specific drugs after you

test negative, you may need antibiotics and life support systems for your

AIDS. It could take you two years to get completely well.

Remember that doctors are kind, sensitive, compassionate people. They want

the best for you. They have no way of knowing about the true cause and cure

of HIV/AIDS since it has not been published for them. I chose to publish it

for you first so that it would come to your attention faster. (From: " The

Cure for HIV/AIDS " , after cover; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order your supplies

Order the book

[link to web page www..net/utilities/b & p.htm]

PX 10, from www..net

----------

The promise

Step into a new world.

A world without chronic diseases.

Step out of your old world.

It has kept you a prisoner.

Try something new.

The prison has no walls. It has only lines. Lines that mark the ground

around you. Inside the lines are your old ideas. Outside are new ideas that

invite you to step over and escape your prison. Dare to try these new ideas

and your illness promises to recede. In a few weeks it can be gone. (From:

" The Cure for all Diseases " , p.1; copyright notice [link to web page

www..net/utilities/copyright.htm].

PX 11, from www..net

----------

Only Two Health Problems

No matter how long and confusing the list of symptoms a person has, from

chronic fatigue to infertility to mental problems, I am sure to find only

two things wrong: they have in them pollutants and/or parasites. I never

find lack of exercise, vitamin deficiencies, hormone levels or anything

else to be a primary causative factor. So the solution to good health is

obvious:

Problem: Simplest Cure:

Parasites Electronic and herbal treatment

Pollution Avoidance

It's a valiant quest: The quest for health. With optimism in one hand and

determination in the other, you too can work the miracles for yourself that

my clients accomplished in the case histories.

More good news is that it is not expensive. The cost will range from a few

hundred dollars to only a few thousand in order to eliminate both problems

and cure your chronic diseases.

(From: " The Cure for all Diseases " , p.2f.; copyright notice .[link to web

page www..net/utilities/copyright.htm].

PX 12, from www..net

----------

DEFENDANTS' VIOLATIONS OF THE FTC ACT

13. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits deceptive

acts or practices in or affecting commerce. Section 12(a) of the FTC Act,

15 U.S.C. § 52(a), prohibits the dissemination of any false advertisement

in or affecting commerce for the purpose of inducing, or which is likely to

induce, the purchase of food, drugs, devices or cosmetics. As set forth

below, defendants have engaged and are continuing to engage in such

unlawful practices in connection with the marketing and sale of various

products, including the Super-Zapper Deluxe, Syncrometer, the Dr. 's

New 21 Day Program for Advanced Cancers, and the Complete Herbal Parasite

Program, (also called the Herbal Parasite Cleanse).

14. Through their advertising and promotional materials, including, but not

limited to, the representations set forth in Paragraph 12, above, and

through the use of their Internet websites, " www..net " and

" www..com " defendants have represented expressly or by implication that:

a. Use of the Super-Zapper Deluxe is effective to kill bacteria, viruses

and parasites in the human body;

b. Use of the Super-Zapper Deluxe is effective against chronic infections,

cancer and Acquired Immunodeficiency Syndrome (AIDS);

c. The Super-Zapper Deluxe and the Complete Herbal Parasite Program, are

effective to cure all forms of cancer in humans;

d. Dr. 's New 21 Day Program for Advanced Cancers is effective to cure

all forms of cancer in humans;

e. Dr. 's New 21 Day Program for Advanced Cancers has cured numerous

people with advanced cases of cancer;

f. The Syncrometer device is more accurate than the best testing methods at

diagnosing all forms of disease;

g. The Syncrometer device can detect the presence of any substance at

specific points in the human body.

h. The Super-Zapper Deluxe, used together with the Complete Herbal Parasite

Program, is effective to cure AIDS;

i. The Super-Zapper Deluxe, used together with the Complete Herbal Parasite

Program and avoidance of pollutants, is effective to cure diabetes,

multiple sclerosis, Alzheimer's, endometriosis, asthma and many other

diseases.

j. Dr. 's New 21 Day Program for Advanced Cancers and Super-Zapper

Deluxe, when used by persons with cancer, make surgery and chemotherapy

unnecessary.

15. Defendants did not possess and rely upon a reasonable basis that

substantiated the representations set forth in Paragraph 14, above, at the

time the representations were made. Therefore, the making of the

representations set forth in Paragraph 14, above, is deceptive and

constitutes false advertising for a food, drug or device, in violation of

the FTC Act, 15 U.S.C. §§ 45(a), 52 and 55.

CONSUMER INJURY

16. As a result of defendants' unlawful acts or practices, consumers

throughout the United States have suffered and continue to suffer monetary

loss and possible injuries to their health. Defendants also have been

unjustly enriched as a result of their unlawful practices. Absent

injunctive relief by this Court, the defendants are likely to continue to

injure consumers, reap unjust enrichment and harm the public interest.

THIS COURT'S POWER TO GRANT RELIEF

17. Section 13(B) of the FTC Act, 15 U.S.C. § 53(B), authorizes this Court

to grant injunctive and other equitable relief, including consumer redress,

disgorgement and restitution, to prevent and remedy any violations of any

provision of law enforced by the Commission.

PRAYER FOR RELIEF

WHEREFORE, plaintiff Federal Trade Commission, pursuant to Section 13(B) of

the FTC Act, 15 U.S.C. § 53(B), and the Court's own equitable powers,

requests that this Court:

1. Award plaintiff such temporary preliminary injunctive and ancillary

relief as may be necessary to avert the likelihood of consumer injury

during the pendency of this action, and to preserve the possibility of

effective final relief;

2. Permanently enjoin defendants from violating the Federal Trade

Commission Act as herein alleged;

3. Award such relief as the Court finds necessary to redress injury to

consumers resulting from defendants' violations of the FTC Act, including

the refund of monies paid and the disgorgement of ill-gotten monies; and

4. Award plaintiff the costs of bringing this action, as well as such other

and additional relief as the Court may determine to be just and proper.

Dated:___________________

Respectfully Submitted,

WILLIAM E. KOVACICGeneral CounselFederal Trade CommissionWashington,

D.C. JOHN M. MENDENHALLRegional Director- East Central RegionFederal

Trade Commission Milgrom, Ohio Bar 0012959Federal Trade

Commission1111 E. Superior Avenue, Suite 200Cleveland, Ohio 44114(216)

263-3419

<clarkassn.htm>News Release ||| <../../index.htm>Quackwatch Home Page

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This document is nothing but a sham pleading. It goes no further than making

unsustained statements without a shred of proof that there are any damages, not

even one. Read this closely. This is an atrocity, at the least, by a

governmental authority. Any good lawyer should be in a position to state that as

a fact and force the FTC to prove their statements of damage exist.

Dale

----- Original Message -----

From: Wally Gordon

gallstones

Sent: Wednesday, January 29, 2003 9:58 PM

Subject: More on FTC vs. Dr.

<clarkassn.htm>News Release ||| <../../index.htm>Quackwatch Home Page

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

FEDERAL TRADE COMMISSION, Plaintiff,

v.

DR. CLARK RESEARCH ASSOCIATION, a corporation,

DR. CLARK BEHANDLUNGZENTRUM GMbH, d/b/a DR. CLARK ZENTRUM, a corporation, and

DAVID P. AMREIN, individually and as an officer of both corporations,

Defendants.

Civ No. 1:03CV0054

COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF

Plaintiff, the Federal Trade Commission ( " FTC " or " the Commission " ) for its

complaint alleges:

1. This is an action under Sections 5(a), 12, 13(B) and 15 of the Federal

Trade Commission Act ( " FTC Act " ), 15 U.S.C. §§ 45(a), 52, 53(B) and 55, in

connection with the marketing and sale to the public of various products,

including the Super-Zapper Deluxe, Syncrometer, the Dr. 's New 21 Day

Program for Advanced Cancers, and the Complete Herbal Parasite Program,

(also called the Herbal Parasite Cleanse).

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction over this matter pursuant to

15 U.S.C. §§ 45(a), 52, 53(B) and 55, and 28 U.S.C. §§ 1331, 1337(a) and 1345.

3. This Court has personal jurisdiction over the defendants pursuant to 15

U.S.C. § 53(B).

4. Venue in the Northern District of Ohio is proper under 15 U.S.C. § 53(B)

and 28 U.S.C. §§ 1391(B), ©, and (d).

PLAINTIFF

5. Plaintiff Federal Trade Commission is an independent agency of the

United States government created by statute. 15 U.S.C. §§ 41-58. The

Commission enforces Sections 5(a), 52, and 55 of the FTC Act, which

prohibit unfair or deceptive acts or practices, including false

advertising, in or affecting commerce. The Commission may initiate federal

district court proceedings to enjoin violations of the FTC Act and to

secure such equitable relief as may be appropriate in each case, including

restitution for injured consumers. 15 U.S.C. § 53(B).

DEFENDANTS

6. Defendant Dr. Research Association ( " DCRA " ) is a California

corporation which lists its address at 8135 Engineer Road, #2748, San

Diego, California 92111. The affairs of defendant DCRA are controlled

entirely by the other two defendants. Defendant DCRA has engaged in

marketing, advertising, and selling activities for its products directed to

consumers in the Northern District of Ohio and throughout the United States.

7. Defendant Dr. Behandlungzentrum GMbH ( " DCZ " ) is a corporation

existing under the laws of Switzerland with its official domicile at

Bielstrasse 12, CH-3053 Munchenbuchsee, Switzerland. It has also used the

address of Sonnhaldenstrasse 30, 6052 Hergiswil, Switzerland. It does

business as Dr. Zentrum. Defendant DCZ has engaged in marketing,

advertising, and selling activities for its products directed to consumers

in the Northern District of Ohio and throughout the United States.

8. Defendant P. Amrein is a citizen and resident of Switzerland whose

business addresses are the same as those of the other two defendants. He is

the sole officer and director of both DCRA and DCZ. At all times material

to this Complaint, acting alone or in concert with others, defendant Amrein

has formulated, directed, controlled or participated in the acts and

practices of DCRA and DCZ, including the acts and practices set forth in

this Complaint. Acting through DCRA and DCZ, defendant Amrein has engaged

in marketing, advertising, and selling activities for the products offered

by DCRA and DCZ directed to consumers in the Northern District of Ohio and

throughout the United States.

9. All Defendants have directly solicited business over the Internet and by

other means from consumers in the Northern District of Ohio and throughout

the U.S. by posting web sites for their products directed at U.S.

consumers, by directing advertisements for their products toward U.S.

consumers, and by enabling users throughout the United States to purchase

products online from their web sites.

COMMERCE

10. At all times relevant to this complaint, Defendants have maintained a

substantial course of trade in or affecting commerce, as " commerce " is

defined in Section 4 of the FTC Act, 15 U.S.C. § 44.

DEFENDANTS' COURSE OF CONDUCT

11. Since at least 1999, defendants have engaged in a plan, program or

campaign to sell the Dr. 's New 21 Day Program for Advanced Cancers,

the Complete Herbal Parasite Program (also called the Herbal Parasite

Cleanse and which contains common cloves, black walnut hulls and wormwood

and other products that are or contain " foods or drugs " within the meaning

of Sections 12 and 15 of the FTC Act, 15 U.S.C. §§ 52 and 55 -- and the

Super-Zapper Deluxe, the Syncrometer and other products that are " devices "

within the meaning of Sections 12 and 15 of the FTC Act, 15 U.S.C. §§ 52

and 55.

12. To induce consumers to purchase the products named in Paragraph 11

above, defendants have disseminated or caused to be disseminated, via the

Internet and other means, advertisements and ordering information for the

above-described products, including, but not necessarily limited to, the

attached Plaintiff's Exhibits ( " PXs " ) 1 through 12. These advertisements

contain the following statements that were found at defendants'

interconnected Internet websites, which they name " www..com " and

" www..net: "

----------

Electricity can now be used...

...to kill bacteria, viruses and parasites in minutes, not days or weeks as

antibiotics require.

If you have been suffering from a chronic infection or have cancer, or

AIDS, learn to build the electronic device that will stop it immediately or

buy one [link to web page www..net/utilities/b & p.htm]. It is safe

and without side effects and does not interfere with any treatment you are

now on. (From: " The Cure for all Diseases " , after cover; copyright notice

[link to web page www.net/utilities/copyright.htm]) .

......

Any positively offset [DC] frequency kills all bacteria, viruses and

parasites simultaneously given sufficient voltage (5 to 10 volts), duration

(seven minutes), and frequency (anything from 10 Hz to 500'000 Hz).

But it takes more than one treatment. It takes three treatments to kill

everything. Why? The first zapping kills viruses, bacteria and parasites.

But a few minutes later, bacteria and viruses (different ones) often recur.

I conclude they had been infecting the parasites, and killing the parasites

released them. The second zapping kills the released viruses and bacteria,

but soon a few viruses appear again. They must have been infecting some of

the last bacteria. After a third zapping I never find any viruses, bacteria

or parasites, even hours later. (From: " The Cure for All Diseases " , p.

13ff.; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order a Zapper

Order the book

Order other products

[link to web page www..net/utilities/b & p.htm]

PX 1, from www..net

----------

Dr. 's Plate Zapping Technique

New Zapping Technique: Plate Zapping

Dr. Hulda 's zapper has not changed since its invention - or rather

discovery? - in 1994. It is reliable and can achieve dramatic results, as

confirmed by hundreds of testimonials. But a good researcher is never quite

satisfied with what is good - because there may always be better or faster

results. As detailed in " The Cure for All Advanced Cancers " , Dr. Hulda

has been working a lot with supplements, vitamins and minerals, and

ozonization; recently she has focused more on essential oils among others.

Now she has found it time to re-examine the zapper concept and find ways to

zap even more effectively.

PCBS PREVENT EFFECTIVE ZAPPING

Most patients get fast results from using Dr. Hulda 's zapper. But

with some patients, the success was limited. Dr. found out that those

patients had PCBs preventing the zapper from being effective. Besides this,

PCBs are another factor reducing immunity, besides benzene, asbestos and

lanthanides that were elaborated on in earlier issues of the Bulletin.

PCBs are found in commercial soaps and pesticides (which may occur in

treated wood in homes; produce). The source must be found and eliminated as

always. Then, PCBs can be eliminated from the body by taking ozonated olive

oil (see separate article on ozonization), which takes 2-3 weeks.

PLATE ZAPPING: COMBINING ZAPPER AND SYNCROMETER TECHNIQUES

Then, Dr. made many experiments with different zapper techniques.

They are not actually changes in the zapper circuit, but much rather

additions to the existing zapper circuit. But Dr. was only ready to

talk about one of the new zapper techniques, which she calls plate zapping,

while the others have not progressed enough and been tested enough to be

released.

The Syncrometer uses test plates to test for pathogens and substances in

the human body. It is a simple oscillating circuit with a 1000 Hz base

frequency which is modulated by the frequencies that are fed into the

circuit by the capacitor plates.

It is also possible to narrow the search for toxins and pathogens down to a

specific organ in the body by placing an organ slide on the second test

plate (the " anatomy plate " , therefore).

Now, Dr. has used this technique with the zapper: She simply

connected two test plates to the zapper circuit. It does not matter where

the capacitors are fed into the circuit, but Dr. stresses they should

be on the " hot " side (the red on the Super Zapper DeLuxe).

The plates can now be used to narrow the zapping down to an organ or a

pathogen. This is very specific zapping and has proven to be much more

effective for the organ or pathogen on the slide (while being less

effective for the others). It is also possible to place organs and

pathogens on the plates at the same time; as well as placing several organs

and pathogens on the plates ( " loading the plates " ) - but then the effect

gets more diluted again.

Finally, it has become possible to zap the intestines with the plate

zapping technique. The intestines have been shielded from regular zapper

current. But they can't resist plate zapping current. " Almost all our

cancer patients now find parasites in their stool " , Dr. said on our

last visit to her office, and she showed us little baggies with textbook

examples of parasites from the patients. " I have the patients bring them to

the office. If they find no parasites I know we are missing something " .

SUMMARY

What is plate zapping? -- It means using the zapper with capacitor plates

attached. On the plates you can put slides of anatomy or pathogens to

specifically zap the organ or the pathogen that is on the plate.

Who is plate zapping for? -- Any patient could use it, but since you need

the slides its costs makes it appear more suitable for advanced patients.

How can you plate zap? -- Take Syncrometer plates (or make your own plates

with aluminum foil and cardboard), and connect them to the zapper, for

example with a double alligator clip lead. Make sure you attach it to the

" hot " side (usually red). You can also get plates and a ready made

connection cable on the order form here. You need slides of whatever

pathogens or organs you want to zap specifically. Dr. has initiated a

special digestive kit, because now it is possible to zap the digestive

tract also. You can get slide kits on the order form or single slides from

a biological supply company.

PX 2, from www..net

----------

Welcome to the Dr. Hulda Cancer Page

Dear Visitor

You came here to find out more about Dr. Hulda 's approach to Cancer.

Dr. Hulda is the researcher who claims: " Cancer can now be cured! "

I can imagine that the first things you are interested to know is

Who is Dr. Hulda ?

What are her findings about Cancer?

How have those findings been corroborated?

..........................

Dr. 's work is based on bio-feedback testing (the Syncrometer),

with which she determines the ACTUAL CAUSES of cancer and other health

conditions. Knowing the cause will open the door to prevention and

treatment. For this purpose Dr. Hulda uses a large number of

approaches in natural medicine, but ALL TARGETED AT THE EXACT CAUSE of the

conditions.

...........................

In her first book about cancer " The Cure for All Cancers " , Dr. Hulda

examined the EXACT CAUSES of malignancy, i.e. cancer. In an update 1998 she

added the make-up of a tumor, which comes before a malignant tumor mass. In

her second cancer book, " The Cure for All Advanced Cancers " , Dr.

mapped out a lot more steps from a healthy individual to a person with

cancer. It includes a lot more information about tumors, low immunity and

how to shrink tumors. The " 21 Day Program " is laid out in this book. Her

third book about cancer is called the " Syncrometer Science Laboratory

Manual " . It contains the most advanced procedures for shrinking tumors, the

" Mostly Zapping Program " .

............................

How have those findings been corroborated?

Dr. Hulda has treated over 2,000 cancer patients in the last 15

years. Her techniques have evolved from rather crude to an exact science

during this time. While she used to have all kinds of cancer patients, she

now takes terminal cases only -- she feels the others can do it out of the

book.

You may ask why no university has confirmed her work yet. The reason is

simple, it has not been tested. It is one of the goals of this Association

to do this kind of clinical work. We have started with some research about

Dr. 's zapper first. I have visited and communicated with many

research institutes, and it is very hard to find one that is both qualified

and interested in cooperating for such a research effort. Finally, the

money for such studies is not easily found.

But consider this: The chance of a " spontaneous remission " of terminal

cancer is 1:60,000. That means that out of 60,000 cases one will live. You

can imagine that it does not take many cases to make this statistically

relevant. It would be like watching a person walk over water and ask for a

research study about it to prove it was statistically relevant.

And testimonials we do have galore. You can find them here:

http://www..net/testimonials/testiframe.htm , and this is only a

small fraction of the many we have in our files!

PX 3 from www..net

----------

Cancer Testimonial #0016

Two and half years ago I got terminal liver cancer (primary) and was given

2 to 6months to live. First I used Breuss and after three months Dr.

's cancer cures for the next 15 months. I am 59 years old, feel great

and looking for a job. I had hepatitis B for a long time and my liver was

badly damaged. Many people diagnosed with cancer after me are dead, killed

by orthodox methods. I didn't use any of them. My story was on TV channel

7, Today Tonight program verifying all CAT scans . Also, I could guarantee

with my life that no cancer patient would die from cancer using Dr. 's

treatments. This was not a fluke. I am an engineer for atomic and nuclear

physics and I could understand and compare both treatments. I have all CAT

scans and I would do everything possible to help Dr. . Without her

treatment I would not be alive.

For any help please do not hesitate to call or write.

Yours Sincerely,

V.

PX 4, from www..net

----------

Dr. 's New 21 Day Program for Advanced Cancers

The 21 day program is described in detail in Dr. 's new book " The Cure

for All Advanced Cancers " . Caution: It is intended for severely ill

patients and not for prevention purposes.

We have seen amazing results in hopeless cases with this program that are

nothing short of miraculous. But bear in mind that

1. the dental clean-up and other clean-ups are still the core of the therapy;

2. no therapy in medicine works in 100% of the cases, and be it just for

lack of correct application;

3. the best results are only possible if Syncrometer testing is available.

Excellent results are possible without if a radical approach is chosen, but

Syncrometer testing definitely makes improved care possible.

PX 5, from www..net

----------

Cancer can now be CURED, not just treated

We are not accustomed to thinking about a cure for cancer. We think of

remission as the only possibility. But this book is not about remission. It

is about a cure. This is possible because in 1990 I discovered the true

cause of cancer. The cause is a certain parasite, for which I have found

evidence in every cancer case regardless of the type of cancer. So lung

cancer is not caused by smoking, colon cancer is not caused by a

low-roughage diet, breast cancer is not caused by a fatty diet, retinal

blastoma is not caused by a rare gene, and pancreatic cancer is not caused

by alcohol consumption. Although these are all contributing factors, they

are not THE cause. Once the true cause was found the cure became obvious.

But would it work? I set a goal of 100 cases to be cured of cancer before

publishing my findings. That mark was passed in December, 1992. The

discovery of the cause and cure of all cancers has stood the test of time

and here it is! (From: " The Cure for all Cancers " , after cover; copyright

notice)

PX 6, from www..net

----------

You may not have time...

...to read this entire book first if you have cancer and are scheduled for

surgery, chemotherapy or radiation treatment. You may wish to skip the

first pages which describe how cancer develops.

Go directly to the cancer curing recipe and order your supplies [link to

web page www..net/utilities/b & p.htm]. Using the herbal recipe [link

to web page www..net/disease/p_cleanse.htm] together with the zapper

[link to web page www..net/disease/zapper.htm] is best. It only

takes days to be cured of cancer regardless of the type you have. It does

not matter how far progressed the cancer is, you can still stop it in 5 days.

After you have stopped the cancer, you can turn your attention to getting

well. Read the case histories to see how easy it is to stop even terminal

cancer. Learn from them to avoid mistakes.

Does this mean you can cancel your date for surgery, radiation or

chemotherapy? YES! After curing your cancer with this recipe it cannot come

back. This is not a treatment for cancer: It is a cure! But if you do not

wish to make your doctor angry, you could follow her or his wishes, too. Be

careful not to lose any vital anatomical parts in surgery though, because

you may need them later when you are healthy!

Remember that oncologists are kind, sensitive, compassionate people. They

want the best for you. They have no way of knowing about the true cause and

cure of cancer since it has not been published for them. I chose to publish

it for you first so that it would come to your attention faster. (From:

" The Cure for all Cancers " , after cover; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order your supplies

Order the book

[link to web page www..net/utilities/b & p.htm]

PX 7, from www..net

----------

The Basis of the Discoveries

I have indicated throughout this book the existence of pollutants in food

and other products. These pollutants were identified using a testing device

of my invention known as the Syncrometer. Complete instructions for

building and using this device are contained in this book. Therefore anyone

can repeat the tests described and verify the data.

The Syncrometer is more accurate and versatile than the best existing

testing methods. A method for determining the degree of precision is also

presented. However at this point it only yields positive or negative

results, it does not quantify. The chance of a false positive or a false

negative is about 5%, which can be lessened by test repetition.

PX 8, from www..net

----------

53 CURED Cases the First Year

Cure, not treatment, is the subject of this book. In 1991 I discovered the

source of HIV. Once the source became clear the cure became obvious. But

would it work? After curing 53 cases in a row, all who used this method, I

could wait no longer to present these findings. Since that time many more

have been cured, too many to be added to this book[*]. Most important is

adding yourself to that list! (From: " The Cure for HIV/AIDS " , after cover;

copyright notice [link to web page www..net/utilities/copyright.htm].

[* In the most recent edition of the book five cases verified by PCR lab

testing for HIV have been added.]

PX 9, from www..net

----------

You may not have time...

...to read this entire book first if you are sick with AIDS. You may wish

to skip the part about how HIV infection is caused and go directly to the

HIV Curing Recipe. Order your supplies [link to web page

www..net/utilities/b & p.htm]. Follow the recipe exactly; it was

carefully worked out for you. It takes 5 days to be cured of HIV regardless

of how ill you are. After you have eliminated the virus, you can turn your

attention to getting well from AIDS. Read the case histories to see how

easy it is to stop even terminal AIDS. Learn from them to avoid mistakes.

Or you may zap [link to web page www..net/disease/zapper.htm] the

virus with electricity for 7 minutes and eliminate it that way. Build or

purchase [link to web page www..net/utilities/b & p.htm] a zapper

immediately. Using the herbal recipe [link to web page

www..net/disease/p_cleanse.htm] along with the zapper is best.

Does this mean you can cancel your appointment with your clinical doctor?

No, it does not. Although you will not need HIV-specific drugs after you

test negative, you may need antibiotics and life support systems for your

AIDS. It could take you two years to get completely well.

Remember that doctors are kind, sensitive, compassionate people. They want

the best for you. They have no way of knowing about the true cause and cure

of HIV/AIDS since it has not been published for them. I chose to publish it

for you first so that it would come to your attention faster. (From: " The

Cure for HIV/AIDS " , after cover; copyright notice [link to web page

www..net/utilities/copyright.htm].

Order your supplies

Order the book

[link to web page www..net/utilities/b & p.htm]

PX 10, from www..net

----------

The promise

Step into a new world.

A world without chronic diseases.

Step out of your old world.

It has kept you a prisoner.

Try something new.

The prison has no walls. It has only lines. Lines that mark the ground

around you. Inside the lines are your old ideas. Outside are new ideas that

invite you to step over and escape your prison. Dare to try these new ideas

and your illness promises to recede. In a few weeks it can be gone. (From:

" The Cure for all Diseases " , p.1; copyright notice [link to web page

www..net/utilities/copyright.htm].

PX 11, from www..net

----------

Only Two Health Problems

No matter how long and confusing the list of symptoms a person has, from

chronic fatigue to infertility to mental problems, I am sure to find only

two things wrong: they have in them pollutants and/or parasites. I never

find lack of exercise, vitamin deficiencies, hormone levels or anything

else to be a primary causative factor. So the solution to good health is

obvious:

Problem: Simplest Cure:

Parasites Electronic and herbal treatment

Pollution Avoidance

It's a valiant quest: The quest for health. With optimism in one hand and

determination in the other, you too can work the miracles for yourself that

my clients accomplished in the case histories.

More good news is that it is not expensive. The cost will range from a few

hundred dollars to only a few thousand in order to eliminate both problems

and cure your chronic diseases.

(From: " The Cure for all Diseases " , p.2f.; copyright notice .[link to web

page www..net/utilities/copyright.htm].

PX 12, from www..net

----------

DEFENDANTS' VIOLATIONS OF THE FTC ACT

13. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits deceptive

acts or practices in or affecting commerce. Section 12(a) of the FTC Act,

15 U.S.C. § 52(a), prohibits the dissemination of any false advertisement

in or affecting commerce for the purpose of inducing, or which is likely to

induce, the purchase of food, drugs, devices or cosmetics. As set forth

below, defendants have engaged and are continuing to engage in such

unlawful practices in connection with the marketing and sale of various

products, including the Super-Zapper Deluxe, Syncrometer, the Dr. 's

New 21 Day Program for Advanced Cancers, and the Complete Herbal Parasite

Program, (also called the Herbal Parasite Cleanse).

14. Through their advertising and promotional materials, including, but not

limited to, the representations set forth in Paragraph 12, above, and

through the use of their Internet websites, " www..net " and

" www..com " defendants have represented expressly or by implication

that:

a. Use of the Super-Zapper Deluxe is effective to kill bacteria, viruses

and parasites in the human body;

b. Use of the Super-Zapper Deluxe is effective against chronic infections,

cancer and Acquired Immunodeficiency Syndrome (AIDS);

c. The Super-Zapper Deluxe and the Complete Herbal Parasite Program, are

effective to cure all forms of cancer in humans;

d. Dr. 's New 21 Day Program for Advanced Cancers is effective to cure

all forms of cancer in humans;

e. Dr. 's New 21 Day Program for Advanced Cancers has cured numerous

people with advanced cases of cancer;

f. The Syncrometer device is more accurate than the best testing methods at

diagnosing all forms of disease;

g. The Syncrometer device can detect the presence of any substance at

specific points in the human body.

h. The Super-Zapper Deluxe, used together with the Complete Herbal Parasite

Program, is effective to cure AIDS;

i. The Super-Zapper Deluxe, used together with the Complete Herbal Parasite

Program and avoidance of pollutants, is effective to cure diabetes,

multiple sclerosis, Alzheimer's, endometriosis, asthma and many other

diseases.

j. Dr. 's New 21 Day Program for Advanced Cancers and Super-Zapper

Deluxe, when used by persons with cancer, make surgery and chemotherapy

unnecessary.

15. Defendants did not possess and rely upon a reasonable basis that

substantiated the representations set forth in Paragraph 14, above, at the

time the representations were made. Therefore, the making of the

representations set forth in Paragraph 14, above, is deceptive and

constitutes false advertising for a food, drug or device, in violation of

the FTC Act, 15 U.S.C. §§ 45(a), 52 and 55.

CONSUMER INJURY

16. As a result of defendants' unlawful acts or practices, consumers

throughout the United States have suffered and continue to suffer monetary

loss and possible injuries to their health. Defendants also have been

unjustly enriched as a result of their unlawful practices. Absent

injunctive relief by this Court, the defendants are likely to continue to

injure consumers, reap unjust enrichment and harm the public interest.

THIS COURT'S POWER TO GRANT RELIEF

17. Section 13(B) of the FTC Act, 15 U.S.C. § 53(B), authorizes this Court

to grant injunctive and other equitable relief, including consumer redress,

disgorgement and restitution, to prevent and remedy any violations of any

provision of law enforced by the Commission.

PRAYER FOR RELIEF

WHEREFORE, plaintiff Federal Trade Commission, pursuant to Section 13(B) of

the FTC Act, 15 U.S.C. § 53(B), and the Court's own equitable powers,

requests that this Court:

1. Award plaintiff such temporary preliminary injunctive and ancillary

relief as may be necessary to avert the likelihood of consumer injury

during the pendency of this action, and to preserve the possibility of

effective final relief;

2. Permanently enjoin defendants from violating the Federal Trade

Commission Act as herein alleged;

3. Award such relief as the Court finds necessary to redress injury to

consumers resulting from defendants' violations of the FTC Act, including

the refund of monies paid and the disgorgement of ill-gotten monies; and

4. Award plaintiff the costs of bringing this action, as well as such other

and additional relief as the Court may determine to be just and proper.

Dated:___________________

Respectfully Submitted,

WILLIAM E. KOVACICGeneral CounselFederal Trade CommissionWashington,

D.C. JOHN M. MENDENHALLRegional Director- East Central RegionFederal

Trade Commission Milgrom, Ohio Bar 0012959Federal Trade

Commission1111 E. Superior Avenue, Suite 200Cleveland, Ohio 44114(216)

263-3419

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