Complaint for Permanent Injunction and Other Equitable Relief

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devices, services or cosmetics, in or affecting commerce in connection with the advertising, marketing and sale of Hanrneilin Cellulite Cream in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. 45(a) and 52. JURISDICTION AND VEMJE 2. This Court has jurisdiction over this matter pursuant to 15 U.S.C. $5 45(a), 52, 53(b) and 28 U.S.C. $5 1331, 1337(a), and 1345. and (c). 3. VenueinthisDis~ctisproperunder15U.S.C.§53(b)and28U.S.C.§1391(b) THE PARTIES 4. Plaintiff, the Federal Trade Commission, is an independent agency of the United States Government created by statute. 15 U.S.C. $8 41-58. The Commission enforces Section 5(a) of the FTC Act, 15 U.S.C. 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. The Commission also enforces Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false advertisements for food, drugs, devices, services or cosmetics in or affecting commerce. The Commission, through its own attorneys, may initiate federal district court proceedings to enjoin violations of the FTC Act and to secure such equitable relief, including rescission of contracts and restitution, and the disgorgement of ill-gotten gains caused by Defendants' law violations, as may be appropriate in each case. 15 U.S .C. tj 53(b). 5. Defendant CHK Trading Corp. is a New York corporation, doing business as Hanmeilin Cosmetics and Shangrila, with offices located at 39 West 32nd Street, Suite 300, New York, New York 10001. Defendant CHK Trading Co., Inc., doing business as Hanrneilin Cosmetics and Shangrila, is a New Jersey corporation, with offices located at 8 Garden Place, Page 2 of 24
Apt. 281, Edgewater, New Jersey 07020. CHK Trading Corp. and CHK Trading Co., Inc. (collectively, "CH.) transact, or have transacted, business in this District and throughout the United States through the advertising, marketing, and sale of Hanmeilin Cellulite Cream, among other products, via advertisements and the Internet site, www.ezcellulite.com. 6. Defendant Chong Kim, also known as Chong Hwan Kim, Chong H. Kim and Charles Kim ("Chong Kim), is the president of CHK Trading Corp. and CHIS Trading Co., hc. He is also a director of CHK Trading Co., Inc. He resides at 8 Garden Place, Apt. 281, Edgewater, New Jersey 07020. At all times relevant to this Complaint, acting individually or in concert with others, Chong Kim has formulated, directed, controlled, or participated in the acts or practices of CHK, including the acts or practices alleged in this Complaint. Chong Kim has transacted business in the Southern District of New York. 7. Defendants CHK Trading Corp. and CHK Trading Co., Inc. sell the same product, have the same president and are under his common ownership and control, use similar names, have identical assumed or alternate names, use the same accountant, use the same website, use the same merchant bank and account number to process consumer payments via credit cards, share the same telephone company account, and cooperate and act in concert to carry out the Defendants' business practices as alleged herein. They constitute a common enterprise for purposes of this proceeding. COMMERCE 8. The acts and practices of Defendants alleged in this Complaint are in or affecting ,-a commerce, as "commerce" is defined in Section 4 of the FTC Act, 15 U.S.C. $44. Page 3 of 24
Page 1: WILLLAM E. KOVACIC General Counsel
Page 5 and 6: translations follow each exhibit).
Page 7 and 8: [TRANSLATION] Cellulite, Stretch Ma
Page 9 and 10: Para que Ud. pueda tomar el control
Page 11 and 12: ... 'Hmeilin' Cellulite Cream is th
Page 13 and 14: never eliminated .... Because HANME
Page 15 and 16: Hanmeilin Herbal Cellulite Cream Ot
Page 17 and 18: satisfaction - Removal of cellulite
Page 19 and 20: Hanmeilin Cellulite Cream effect Pr
Page 21 and 22: the dissemination of any false adve
Page 23 and 24: elief by this Court, the Defendants

Complaint for Permanent Injunction and Other Equitable Relief

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