Product: Money transfer, virtual currency, or money service

I am filing this urgent complaint against PayPal Holdings , Inc. for egregious violations of consumer protection laws, including illegal fund holds, retaliatory actions against a XXXX consumer, permanent account deactivation without explanation, and practices that have caused irreparable harm to my livelihood and survival. I am a XXXX individual, barely making ends meet, and PayPals actions have left me unable to pay for life-sustaining medication, essential living expenses, and critical business operations. 
PayPal has refused to disclose the reasons for permanently deactivating my account and has stolen my funds, stating that they will hold them for six months without justification. These actions occurred with full knowledge of their illegality, as PayPal has faced numerous legal actions and regulatory penalties in the past for similar behavior. Notably, this retaliatory act was executed two days before XXXX, demonstrating both deliberate malice and disregard for the law.

Despite multiple requests for explanation and numerous phone calls with customer support, I have received no clear response. These actions are not isolated incidents ; PayPal has a documented history of engaging in unlawful practices, including unjust fund holds, retaliation against consumers, and breaches of federal and state consumer protection statutes. I am seeking immediate intervention to address this matter and prevent further harm. 
________________________________________ Specific Violations of Law Federal Laws Violated 1. Electronic Fund Transfer Act ( EFTA ) 15 U.S.C. 1693 et seq.

o PayPals actions violate the EFTA by arbitrarily holding my funds without clear and legitimate justification. The EFTA mandates transparency and timely access to electronic funds. PayPals failure to provide notice and valid reasoning for the hold contravenes this federal statute. 

2. Unfair and Deceptive Acts and Practices ( UDAP ) Federal Trade Commission Act ( 15 U.S.C. 45 ) o PayPals practices constitute unfair and deceptive acts, including withholding funds critical for my survival and business operations. The Federal Trade Commission Act prohibits businesses from engaging in practices that cause substantial harm to consumers. 

3. Americans with XXXXXXXX XXXX ( XXXX ) 42 U.S.C. 12101 et seq.

o As a XXXX individual, I am entitled to equal access to financial services. PayPals retaliatory actions, resulting in financial deprivation, may violate XXXX protections by disproportionately impacting my ability to access essential services. 

4. Retaliation Protections Under Federal Law o Retaliation for filing formal complaints with regulatory agencies is prohibited under federal consumer protection laws. PayPals decision to hold my funds and permanently deactivate my account appears to be direct retaliation for my ongoing complaints with state and federal agencies.

Florida State Laws Violated 1. Florida Deceptive and Unfair Trade Practices Act ( FDUTPA ) Florida Statutes Chapter 501, Part II o PayPals actions violate FDUTPA by engaging in deceptive and unfair practices that have caused significant harm to a Florida resident. The arbitrary fund hold, lack of transparency, retaliation, and unexplained account deactivation all contravene the statute.

2. Breach of Fiduciary Duty o As a payment processor, PayPal has a fiduciary duty to act in good faith and with due care. Arbitrarily holding my funds without a legitimate reason constitutes a breach of this duty under Florida law. 
3. Civil Rights Protections Under Florida Law o Florida law prohibits discriminatory practices against XXXX individuals. PayPals actions have disproportionately impacted my ability to live and operate my business.

________________________________________ Detailed Timeline of Events 1. Eight-Month Investigation Initiated : I filed formal complaints with multiple regulatory agencies against PayPal approximately eight months ago.

2. Permanent Account Deactivation : PayPal has permanently deactivated my account without providing any explanation despite multiple requests for clarity.

3. Retaliatory Fund Hold : Today, without warning or explanation, PayPal arbitrarily began holding my funds. Despite repeated requests for clarification, they have refused to provide any justification. Over nearly 15 years of using PayPal, I have never had a single customer file a dispute or lodge a complaint against me, my invoices, or my services. There are no compliance issues on my account.

These actions are entirely unjustified and appear to be a retaliatory power move designed to silence me for exercising my consumer rights by filing legitimate complaints about PayPal 's illegal practices. This deliberate and malicious act not only violates my consumer rights but also undermines due process, as it effectively prevents me from continuing to report their ongoing illegal activities.

Furthermore, during a call with PayPal support staff, I was explicitly told that they do not care if I get my life-sustaining medication and that I should just hurry up and die. They then hung up on me. This is not only unconscionable but constitutes a direct and intentional attack on my basic human rights. By targeting a XXXX individual and depriving me of the funds necessary for survival, PayPals actions amount to a calculated effort to murder me through financial deprivation, ensuring I can not obtain essential medication or meet critical needs.

4. PayPal 's actions are a clear violation of federal and state laws protecting consumers and XXXX individuals. Their disregard for my life, my rights, and my ability to survive underscores the severity of their malicious intent. Immediate intervention is necessary to hold PayPal accountable and prevent further harm.

5. Severe Harm Experienced : o Unable to pay for critical medication.

o Lost business opportunities, resulting in financial devastation.

o Emotional distress caused by the inability to meet basic living needs.

o PayPal deliberately enacted these harmful actions two days before XXXX, exacerbating the impact on my livelihood and well-being. 
________________________________________ Precedent and Supporting Case Law XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX o This class action lawsuit alleged that XXXX arbitrarily froze customer accounts and held funds without justification, violating the EFTA and engaging in unfair practices. The case resulted in a significant settlement, highlighting PayPals history of similar violations. 

2. In re PayPal Account Hold Litigation, 446 F. Supp. 3d 1376 ( N.D. Cal. 2020 ) o Plaintiffs accused PayPal of systematically freezing accounts and holding funds in bad faith. The court acknowledged the potential violations of consumer protection laws, emphasizing the need for transparency and accountability.

3. Consumer Financial Protection Bureau v. PayPal , Inc. ( 2015 ) o The
CFPB fined PayPal {$25.00} million for deceptive practices, including failing to provide adequate information about its practices and harming consumers through unfair actions. 
________________________________________ Relief Requested 1. Immediate Reinstatement of My Account and Release of Funds : o I request that PayPal immediately reinstate my account and release all funds currently held.

2. Investigation of Retaliatory Practices : o I request a formal investigation into PayPals retaliatory actions and their compliance with federal and state laws.

3. Explanation for Permanent Deactivation : o I demand a detailed and transparent explanation for the permanent deactivation of my account.

4. Compensatory and Punitive Damages : I seek substantial compensation for : Lost income and business opportunities.

Emotional distress and hardship caused by PayPals actions.

Punitive damages to account for the severity of harm caused and to deter future violations, considering PayPals repeated offenses and knowledge of their legal obligations.

5. Implementation of Oversight Measures : o Regulatory agencies must enforce stricter oversight to prevent PayPal from engaging in similar practices in the future.

PayPals actions are not only illegal but morally reprehensible. They have caused significant harm to a XXXX individual barely making ends meet, and their retaliation against a legitimate complaint demonstrates a flagrant disregard for consumer rights and federal law. Their refusal to provide an explanation for permanently deactivating my account, coupled with their decision to withhold my funds for six months, is tantamount to theft and an attack on my livelihood. These deliberate actions, taken during the holiday season with full knowledge of their legal violations, warrant immediate and substantial intervention. I urge all relevant agencies to act swiftly and decisively to compel a substantial settlement and ensure justice is served.