Original Complaint - MLMLaw

93. Defendants have violated the South Carolina Business Opportunity Act, S.C. Code
Ann. §§ 39-57-10 et seq. by engaging in the following:
A. Engaging in the offer or sale of a business opportunity in the State of South Carolina
without being properly registered pursuant to S.C. Code Ann. § 39-51-50;
B. Engaging in the offer or sale of a business opportunity in the State of South Carolina
without filing the required disclosure documents with the office of the Secretary of State
pursuant to S.C. Code Ann. § 39-57-30;
C. Making misrepresentations and misleading statements in connection with the offer or
sale of a business opportunity in the State of South Carolina, including, but not limited to,
misrepresentation concerning earnings claims, compensation and business practices.
CONSUMER INJURY
94. Defendants’ violations of Section 5 of the FTC Act and the laws of various States, as
set forth above, have caused and continue to cause substantial injury to consumers. Absent
injunctive relief by this Court, defendants are likely to continue to injure consumers.
THIS COURT’S POWER TO GRANT RELIEF
95. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant
injunctive and other ancillary relief, including consumer redress, disgorgement and restitution, to
prevent and remedy any violations of any provisions of law enforced by the Federal Trade
Commission.
96. Pursuant to 28 U.S.C. § 1367, this Court has supplemental jurisdiction to allow
plaintiff, the State of Hawaii, to enforce its state law claims under the Hawaii Uniform Securities
Act, Chapter 485, Hawaii Revised Statutes, against defendants in this Court.
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