UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

MARK BENT,

individually, and on behalf of all others 

similarly situated,

Plaintiff,

v.

GOTOGATE, INC.,

Defendant.

/

CASE NO: 

CLASS ACTION COMPLAINT

Plaintiff Mark Bent ("Plaintiff"), on behalf of himself and all others similarly 

situated, alleges the following based upon personal knowledge as to himself, upon 

information and belief, and the investigation of his counsel as to all other matters, and 

brings this class action against Defendant GotoGate ("Defendant" or “GTG”), as follows: 

I. Nature of the Action

1. In total, 128,934 flights were canceled in the U.S. from January to July,

2022 surpassing pre-pandemic levels.1 Additionally, during that same time period, nearly 

a million flights have been delayed.2 The delays and cancellations are attributed to 

widespread fleet issues, staffing shortages, air traffic control, weather, and other 

conditions.3 The Bureau of Transportation Statistics calculates on time, delayed, and 

1 https://www.travelandleisure.com/travel-news/2022-flight-cancellations-pandemicdata

2 Id.

3 https://www.afar.com/magazine/why-there-are-so-many-delayed-and-canceledflights-in-2022

CLASS ACTION

JURY TRIAL DEMANDED

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cancelled flights and estimates that only 76% of flights are on time in 2022, down 12% 

from 2021.4

2. Given the unprecedented travel environment, unreliable flights are 

becoming the new norm, leaving consumers in limbo without solid travel plans or travel 

dates. To ease the unreliable travel burden on consumers, the U.S. Department of 

Transportation requires foreign and domestic airlines to fully refund airline tickets when 

a consumer cancels within 24-hours of booking.5

3. As a result of travel delays, cancellations, and call center hold times, 

customers like Plaintiff and Class Members rely on third party companies like Defendant 

to facilitate unreliable travel. Like many other modern day travel agents, GTG’s ecommerce website acts as the bridge to connect consumers with affordable airlines, 

hotels, car rentals and other travel services.6 Part of GTG’s charm is that customers do not

have to wait in an airline call center cue to cancel a flight and request a refund. With GTG, 

it allegedly has a customer service team to process consumer refund requests directly with 

airlines as a service for Plaintiff and Class Members. Notably, GTG’s refund assistance 

policy is supposed to make it easier on consumers to navigate refunds related to cancelled 

flights. GTG’s outward marketing, e-commerce website, and travel offerings may even 

make sense to consumers during these unsettling times. In theory, intermediary 

companies like GTG should ease the stress level of airlines cancellations, making it easier 

to process refunds. Unfortunately, the pandemic and other industry disruption provides 

a fertile haven for companies like GGTG to scam consumers, withhold refunds, cause 

4 https://www.transtats.bts.gov/homedrillchart.asp

5 https://www.transportation.gov/airconsumer/notice-24hour-reservation

6 https://www.gotogate.com/

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excessive delays, charge excessive fees, among other things.

4. In accordance with the Department of Transportation, the foreign and 

domestic airline industry has developed a reliable standard where a consumer may cancel 

their airline ticket within 24-hours of booking and receive a full refund. 

5. Defendant GTG sought to capitalize on this cancellation promise and 

launched a business described as a place where “you always fly smart and enjoy 

more! ... Above all a passion for making every trip an unforgettable 

experience.”7 On its website, consumers can book flights, hotels, holiday homes, and 

rental cars. GTG boasts that it helps to connect nearly 14 million customers with over 650 

airlines, including flights from 77 countries across the globe. To assist with its massive 

amount of travel bookings, GTG guarantees 24/7 support, with over 1,000 dedicated 

employees and IATA Certified Travel Agents “so that you can book with confidence,” the 

highest encryption and safety measures, 35 languages, etc.

6. GTG routinely markets to consumers who need flexible, last minute travel 

bookings at affordable pricing.

7. To alleviate concerns about Covid-19 cancellations, understaffed airlines, 

weather delays, and more, GTG offers flexible booking:

7 https://www.gotogate.com/rf/about-us

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8. GTG claims to have a straightforward flight cancellation process:

9. Moreover, prior to booking, GTG ensures its customers that it handles all 

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flight changes and cancellations. Specifically:

10. As illustrated in its Terms and Conditions, GTG reassures that it processes 

refunds when a customer requests a cancellation. More specifically, GTG makes the false 

promise:

If you wish to request a change or cancellation refund, as an additional own 

service, We offer to handle the request on your behalf if permitted by the 

conditions of the airline.8 

11. Plaintiff’s refund at issue stems from a flight booked with 

Lufthansa/Condor airline, a foreign airline required to issue a full refund when an airline 

passenger requests a refund within 24-hours of booking, in accordance with Department 

of Transportation regulations.9

8 https://www.gotogate.com/rf/travel-conditions#APPENDICES_FEES

9 https://www.lufthansa.com/us/en/local-page/customer-serviceplan#:~:text=Providing%20Prompt%20Ticket%20Refunds,made%20by%20cash%20or

%20check.

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12. Upon information and belief, Lufthansa/Condor issues consumer 

cancellation refunds within seven (7) days of a consumer’s request for refund.10

13. Additionally, as GTG knows, the Department of Transportation has issued 

airline requirements related to this 24-hour refund regulation: 

The 24-hour reservation requirement is mandated by the Department of 

Transportation’s consumer rule “Enhancing Airline Passenger Protections” 

(14 CFR 259.5(b)(4), 76 Fed. Reg. 23110, 23166, Apr. 25, 2011) and applies 

to all reservations made seven days or more prior to the flight’s scheduled 

departure time.1 To comply with the regulation, carriers may not deceive 

consumers about the 24-hour reservation requirement when consumers 

inquire about cancelling or changing a reservation within 24 hours of 

making or paying for that reservation. This guidance also clarifies that the 

Department’s Office of Aviation Enforcement and Proceedings 

(Enforcement Office) considers the failure to notify such consumers of the 

24-hour reservation requirement to be unfair and deceptive in violation of 

49 U.S.C. § 41712. It also considers the failure to offer a passenger a full 

refund in the original form of payment in the event of a cancellation request 

covered by the 24-hour reservation requirement to be an unfair and 

deceptive practice.

11

14. GTG’s marketing practices directly conflict with its Terms and Conditions. 

GTG claims to assist its customers with navigating cancellation refund requests with third 

party travel companies, and requires that GTG customers, like Plaintiff, use GTG to 

request a refund from airlines, yet expressly denies that GTG has any influence over the 

refund process:

10 https://www.lufthansa.com/us/en/local-page/customer-serviceplan#:~:text=Providing%20Prompt%20Ticket%20Refunds,made%20by%20cash%20or

%20check.

11https://www.transportation.gov/sites/dot.gov/files/docs/Notice_24hour_hold_final2

0130530_0.pdf

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15. One of GTG’s revenue streams is charging administrative assistance fees as 

a result of customer cancellation and refund requests:

16. Ultimately, Plaintiff has never received any refund from GTG. Plaintiff is 

not alone. As set forth below, Defendant’s scheme to steal consumer airline refunds is 

their “biscoff and coffee” and standard business practice. Accordingly, this case can, and 

should, proceed as a class action.

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II. Jurisdiction and Venue

17. The Court has jurisdiction over this action pursuant to the Class Action

Fairness Act 28 U.S.C. § 1332(d), because there are at least 100 Class members in the 

proposed Class, the combined claims of proposed Class members exceed $5,000,000, 

exclusive of interest and costs, and at least one Class member is a citizen of a state other 

than GotoGate’s states of citizenship, Delaware and Florida. This Court also has 

supplemental jurisdiction over the state law claims alleged herein pursuant to 28 U.S.C. 

§1367.

18. GTG’s corporate headquarters in the United States is located at 4300

Biscayne Blvd. Suite 203, Miami, FL 33137. It is from this location that GTG contracts 

with its online customers and processes the refund requests at issue in this litigation. On 

information and belief, any refunds made by GTG are also processed from its Miami 

corporate headquarters. Accordingly, venue is proper in this Court pursuant to 28 

U.S.C. § 1391 because GTG is a corporation subject to personal jurisdiction in this 

District and is therefore deemed to reside in this District for the purposes of venue. 

19. GTG’s Terms and Conditions, to which Plaintiff is a party, states, “As a

consumer, you will benefit from any mandatory provisions of the law of the country in 

which you are resident. Nothing in these T&Cs, including this Section 13.1, affects your 

rights as a consumer to rely on such mandatory provisions of local law.” 

20. GTG does substantial business in the State of Florida and within this judicial

District, is registered to and is doing business within the State of Florida, and otherwise 

maintains the requisite minimum contacts with the State of Florida. 

21. This Court also has jurisdiction over Plaintiff’s claims because Plaintiff is a

Florida resident and Plaintiff purchased the airline ticket at issue using GTG’s official eCase 1:22-cv-23084-DPG Document 1 Entered on FLSD Docket 09/23/2022 Page 8 of 38
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commerce website located at www.gotogate.com.

III. The Parties

22. Plaintiff Mark Bent is a veteran of the United States Marine Corps and is a

citizen of Florida. Plaintiff currently resides in Duval County, Florida, and has at all times 

pertinent to this Complaint.

23. Defendant GotoGate is a Delaware corporation, which operates from its

corporate headquarters located at 4300 Biscayne Blvd Suite 203, Miami, FL 33137. 

Defendant is a subsidiary of the Etraveli Group. GTG is the entity responsible for 

arranging flight accommodations between third party servicers (airlines, hotels, etc.) and

Plaintiff and members of the Class throughout the United States and across the world.

IV. Factual Allegations

A. GTG’s Business Model

24. Founded in 2009, GTG operates its website with a URL of

www.gotogate.com. The website operates as a modern day e-commerce travel agent, and 

facilitates the bookings of flights, hotels, and rental cars between said third party 

companies and consumers through GTG’s online e-commerce website, with GTG acting 

as an online travel agent. Rather than only making reservations like other online 

reservation companies like Orbitz or Travelocity, GTG promotes itself as doing more for 

its customers including: purchasing and cancelling flights, hotels, and rental cars, 

processing payments from consumers to third parties, requesting refunds from third 

parties on behalf of consumers, communicating with third parties about refunds, 

receiving refunds intended for consumers that are received from third parties, and 

processing refunds between consumers and GTG.

25. In or around 2009, Etraveli Group, acquired GotoGate. Etraveli Group is

Case 1:22-cv-23084-DPG Document 1 Entered on FLSD Docket 09/23/2022 Page 9 of 38
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headquartered in Uppsala, Sweden, with an estimated annual revenue of 3 billion euros 

or $2,904,525,000.00. Etraveli Group is owned by Booking Holdings, a publicly 

traded corporation (Nasdaq symbol: BKNG) worth an estimated $80.53 billion. 

26. After the acquisition, GTG became the Etraveli Group’s leading brand,

allowing Etraveli Group to expand its markets from a regional to international, 

spearheading the efforts to reach a greater audience around the world. 12

27. Since Etraveli Group’s purchase, GTG has expanded its services around the

globe, assisting Etraveli Group’s 14 million customers in over 75 markets, over 6 

continents, and interacting in 35 languages, with business offices in Athens, Gothenberg, 

Krakow, Stockholm, Mumbai, and Pune, and outsourcing call centers located in India and 

China.13 

28. GTG asserts that it connects customers with over 650 airlines and

guarantees:

You’re guaranteed to find the flight that’s right for you. Plus we partnered 

with more than 300,000 hotels, holiday homes and car rentals in all sizes 

for a trip of total relaxation. Your next getaway is just a click away.14

B. Plaintiff Contracted Used GTG to Book Airline Travel

29. On April 25, 2022, Plaintiff purchased two one-way passenger airline tickets

with Lufthansa/Condor for his two daughters, Emilie Bent and Abigail Bent, to travel to 

Paris, France. The flight was to be from John F. Kennedy International Airport (JFK) 

with a layover at Frankfurt International Airport (FRA) in Germany and a final 

destination of Charles-de-Gaulle (CDG) in Paris. (the “Flight”) on May 7, 2022.

12 https://www.etraveligroup.com/newsroom/facts/ 

13 Id.

14 https://www.gotogate.com/rf/about-us

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30. At purchase, Plaintiff received a confirmation Booking Number (2830935) 

and Order Number (LL5CSU).

31. Plaintiff paid $721.97 for the flight refunds at issue in this lawsuit. Plaintiff

was not flying with his daughters.

32. Within 30 minutes of booking the Flight, Plaintiff’s daughters called and 

informed Plaintiff that they preferred a later travel date.

33. Immediately following his daughters’ request, Plaintiff called GTG 

customer service number 1-786-405-8511 and requested a cancellation and refund of his 

purchase. At that time, a GTG call center representative informed Plaintiff that he was 

required to cancel directly with the airline, as that is the only way to process a refund 

request and cancel the airline reservation. 

34. Immediately following his call with GTG, Plaintiff called Lufthansa/Condor 

and requested a cancellation of the booking and refund. The Lufthansa representative 

noted that Plaintiff was well within the 24-hour cancellation window but explained that 

because the Flight was booked through GTG, it was the party required to cancel the Flight 

and reimburse Plaintiff. Specifically, Plaintiff was required to return to GTG for a refund 

and not Lufthansa because Plaintiff booked using GTG as his travel agent.

35. Upon information and belief, Lufthansa processes refund claims within 

seven (7) days of a consumer’s refund request if made within 24-hours of booking.

36. Immediately following his conversation with Lufthansa, Plaintiff called 

GTG again and relayed the information from his call with the airline. The GTG call center 

representative repeated that Plaintiff was required to cancel directly with the airline, as it 

is the only way to cancel a GTG reservation.

37. Directly thereafter, Plaintiff hung up the phone and re-dialed GTG customer 

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service. At that time, Plaintiff received an identical canned answer from a different GTG 

customer service representative.

38. At this point, Plaintiff went to the GTG website to look for information on 

refunds. On its website listed under “Support,” GTG limits customer assistance through 

two channels of communication: (1) calls to GTG 24-hour customer service telephone 

number 1-786-405-8511;15 or (2) Using GTG’s Support portal on its website: 

www.gotogate.com.16

39. Other than the two methods outlined above, GTG expressly prohibits any 

other method of communication, including regular mail and communicating directly with 

GTG employees:

15 https://www.gotogate.com/rf/contact-us

16 Id.

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40. After reading the instructions for how to create a “support ticket” and still 

within 24-hours of booking the Flight, on April 25, 2022, Plaintiff followed GTG’s website

support instructions and submitted his cancellation request in accordance with GTG’s 

website instructions by entering Plaintiff’s e-mail and order number.17

41. Following his submission using GTG’s support function on its website, 

Plaintiff received this generic email from GTG:

17 Id.

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42. GTG requires all consumers to agree to its “Terms and Conditions” 

contract.18 

43. Despite the April 25, 2022 “Cancellation” email from GTG confirming 

receipt of Plaintiff’s request for cancellation and a refund, no refund has ever been 

received from GTG for the cancelled flight. 

E. Online Complaints of GTG’s Common Deceptive Practice

44. A deeper investigation of Better Business Bureau (hereinafter, “BBB”)

complaints illustrates a disturbing pattern of GTG’s unlawful business practices

surrounding its failure to issue refunds for flights cancelled within 24 hours. GTG has 

used COVID-19 delays as an excuse to further its scam, and it continues to blame its 

18 https://www.gotogate.com/rf/travel-conditions

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repeated business failures on COVID-19. At the same time, GTG continues to advertise on

its website, run its online e-commerce travel, accept consumer payments, and process 

payments to third parties, request refunds, email customers, but is somehow unable to 

process refund payments to consumers.

45. GTG has at least 517 complaints on the BBB within the last 12 months, along 

with complaints on several other websites where consumers allege similar (or nearly 

identical) harm as that suffered by Plaintiff. A sampling of those complaints are below

without grammatical or typographical alteration:

• I booked 2 airline tickets over 2 years ago, and for a year I have been chasing a 

refund and getting messed around. Told one thing on one call and get a 

contradicting story on the next. Waiting time to get through usually over an hour, 

there is no email or physical address to contact them. They seem to have a set line 

"your refund is being processed we will get back to you" they NEVER do. I have 

tried to escalate the complaint there is NEVER anyone available.19 (August 2022)

• Its **************** do not ever thinkIts **************** do not ever think to 

book with them .I had a flight from ***** to Washington on 08/13/2022 at 4:10 

Am .We went to take our flight and been told we have no seats for us on this plane 

flight number LH 585 We already have conformation number and ticket 

number,so I contact them over the phone and the lady told me we have no flight to 

Washington until next week and I have to be In *** for my work so I told her I need 

my Refund so she processed and told me you will be contact by the email to get 

your refund ,Until now I did not get any email or any thing from them and s  

my trip already .I contact one of them and told me sorry no refund for you!!!20

(August 2022)

• Horrible booking system! Had to book to separate orders for ** ***** dad because 

he needed a one ******* needed a round trip, there was a error on the date flying 

out even though both flights were on the same flight ****************** & arrival 

time. There customer service was terrible waiting to speak to someone over an 

19 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

20 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

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hour, everyone I spoke to had a thick Indian accent & didnt understand how to 

receive the order number. They offered no help in correcting the flight date or 

making any changes nor offering any partial refund or credit. Terrible.21 (August 

2022)

• I have been calling and emailing for the last month about a refund for a canceled 

flight and they keep telling me the same thing over and over again and I just want 

my refund.22 (August 2022)

• My tickets were cancelled last year December and I was told I can book anytime 

over the next one year. It has been 8 months Ive been trying to do so. This is a scam 

company and someone needs to take action against them and not allow them to 

operate. Horrible customer service. This is daylight robbery.23 (August 2022)

• I'll keep it brief:I used GoToGate to book plane tickets for a trip. The airline 

canceled the flights and informed me that they had sent the refund to my booking 

service. I attempted for over 2 MONTHS to secure this refund from their customer 

service team with multiple phone calls and dozens of emails. The flight was 

canceled in April, it is now August, and I assume I have to consider this $271 a 

complete loss. 0 stars, will never use again.24 (August 2022)

• My flight was cancelled and the airline said I would need to get my refund through 

GOTOGATE. It's been over a month of calling for the same answer-they're working 

on the refund. They offer NO timeline for the refund and I can only call them. There 

is no email option and although they say you can check the status online, 

information for my refund isn't on there. I will NEVER use them again.25 (August 

2022)

21 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

22 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

23 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

24 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

25 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

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• I would have given negative if I could. I booked through Gotogate a flight from 

****** to   round trip of Alitalia to travel in October 2021. Unfortunately it got 

cancelled by the airline. I requested Gotogate to process the refund immediately. 

Almost a year later I still havent got refund!!! Their customer service has been a 

joke. No answer or repeat nonsense every time. Be very careful with this company. 

I booked three other tickets from another travel agency (different from city) with 

the same Alitalia flight cancelled and got my refund 6-8 months ago!26 (August 

2022)

• They did refund my money I paid 364$ for a flight then I canceled 20 minutes after 

then they paid me back just 161$ its been almost 2 months that Im waiting for the 

rest of my money. No good dont trust.27 (August 2022)

• I would give negative rating if possible. The worst service ever. The flight was 

cancelled by the airline, they refunded the full amount. Goto gate kept my money 

and did not refund, I was on hold for 3 hrs with customer service and was told that 

they would deduct half my flight charge for refund processing!28 (August 2022)

• It is a Scam!!!!They charged me $34.00 fee to refund my money for a flight 

canceled by the airline!!!Customer service is veeeeery bad!!!29 (August 2022)

• There should be an option to give ZERO stars, if so - that's what I'd give them. The 

average rating of 1 star is too much. DO NOT WASTE YOUR TIME, MONEY, 

PATIENCE OR SANITY on working with this company. IT IS NOT WORTH IT. 

Long story short, I needed my last name changed on my ticket because I got 

married. I contacted them a 8 months before the flight and was directed that I'd 

need to do 2 things: pay [3] extra fees and send them copies of my marriage 

certificate and passport as proof. I completed the requests the same day. After that 

it was multiple email follow ** * and playing phone tag with them with NO 

RESOLVE. I even tried to fix the issue with the airline [TAP] and they couldn't help 

me since I booked the reservation through GoToGate. They also said they haven't 

heard any requests from them to make the changes! After finally losing my 

26 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

27 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

28 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

29 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

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patience and 6 weeks before my flight, I cancelled my flights, disputed the charges 

with my credit card and rebooked directly on another airline. GoToGate had the 

***** to say my dispute wasn't valid!!! I had to send in proof to my credit card 

company with emails, phone records [good thing I took screenshots of phone calls 

made, timestamps of hours long of being on the phone with them] and a letter 

explaining everything. Days later GoToGate even sent an email on 4/23/22 saying 

they'd be issuing me a refund, it's 3 months later [& counting] they still haven't 

refunded my account. Emails GoToGate sends to say they're trying to contact you 

via phone because it can't be disccussed via email is to cover their tracks. If you 

more money to rebook a flight with them (not to mention you HAVE to call them 

to rebook) than it would to just book without this company. Avoid at all costs.30

(July 2022)

• Booked a flight through this company. Checked with the airline and they had no 

records of the booking. This company would not let me cancel and refund my 

money. I had to book another flight through the airline and had to show proof to 

the airline that I had paid this company and they gave me a credit for future flights. 

This company took my money and never booked the flight through the airline31

(July 2022)

• They charge your card more than once for the same ticket. And never refund you 

for months of calls and emails. STAY AWAY.32 (July 2022)

• Complete Scam, my flight was canceled and didn't receive a refund.33 (July 2022)

• PLEASE whatever you do or whatever great deal you find, DO NOT, I repeat...DO 

NOT book anything through this company. Booking is easy but when it comes to 

canceling, they will ghost you in the worst way. I have been trying to get a refund 

for year now. Spirit cancelled my return flight. They refunded the money back to 

GO TO GATE and they will not pass that money back to me (which it is rightfully 

mine). There is no way that this is legal. Every time I go to the website for contact 

info regarding a refund, there is a DIFFERENT number. All of the numbers stay 

30 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

31 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

32 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

33 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

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busy or doesn't even ring. Sometimes there is even an international number listed. 

They should not be in business and I advise anyone not to do business with them. 

You will regret it, guaranteed. DO NOT TRUST THEM, USE THEM, OR CLICK ON 

THEIR SITE.There was not an option to leave ZERO stars.34 (July 2022)

• The problem is when flights get cancelled. They use their own credit cards to book 

the flights that you purchased and the airlines refund the money to the credit card 

they booked it through however GO TO GATE doesn't refund it to the actual 

customer. They get claim that they never received a refund from the airlines which 

is total ********. If you call the airlines which is what I had to do, they were able to 

tell me when a refund was issued and the last four of the credit card it was issued 

to along with an email address that they used call, you're on hold for a long time 

and find no resolve or your calls are dropped. SERIOUSLY DO NOT WASTE YOUR 

TIME WITH THIS COMPANY. I DON'T EVEN KNOW HOW THEY'RE STILL 

ABLE TO DO BUSINESS AT ALL!!!!35 (July 2022)

• The whole site should be shut down. They refuse to give refunds. They charge you 

to rebook your flight. The customer service is awful. They tried to charge me an 

additional $300 to rebook my flight by claiming the fare was higher than what it 

was. It costs you 

• when it was booked. Get that information and call your credit card company and 

file a dispute. You will never see a refund from GO TO GATE*****.36 (July 2022)

• Worst travel agency in the market. They sell insurance through ************, 

which is a fraudulent company that doesn't have a valid phone number to reach 

out to follow the status of your claims. I filed a claim on May 1st, it's been 3 months 

and none has reached out to get my money refunded. I asked GO To Gate for a 

valid phone number to call ************ and they did not provide me any valid 

information to solve my problem. I'm not going to continue wasting my time, so 

I'll file a claim through the **************************************, c/o 

********** of ********* Services.37 (June 2022)

34 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

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• STAY AWAY! This is a scam company! Been waiting for my refund for about 5 

Months now. Had to cancel my trip due to COVID, calling them takes 4 hours of 

my time as they are awful at picking up the phone, they wont reply to emails, its 

impossible! Their customer service is awful! Its only yes maam, no maam, barely 

understand them and when I asked to speak with a Manager the rude guy said no 

maam, thats not possible I dont understand how a scammer, group of thieves can 

still be in business!38 (June 2022)

• as mentioned by many reviewers, gotogate doesn't deserve a single star. My flight 

was cancelled by the airline and gotogate confirmed that I am eligible for full 

refund. It's been more than 2 months since then. Lufthansa said they issue refund 

within 7 days for cancelled flights. I am still waiting to receive my $2243 refund 

from Gotogate.39 (June 2022)

• I dont think they deserve even one star. Been chasing my refund for 6 months now 

and they take zero accountability. Awful company. Dont know how they are still in 

business. They are quick to take your money and not willing to help you after. 

Worst experience with a travel company. Do yourself a favour and avoid avoid 

avoid.40 (June 2022)

• Hi Team,I have make a booking on gotogate website $1048.78$ Reference 

LFMMYW, its been more than 6months I am chasing for the refund.team kindly 

help to resolve and refund at the earliest.Regards.41 (June 2022)

• They still didn't refund my money. This company is acting like a scam. I bought a 

ticket through this company. The flight was cancelled and they said they will start 

the refunding process, but since then i didn't get any messages or calls. I think they 

are trying to ignore me hoping that I'll forget or just skip refunding questions. I'll 

open a case on them.42 (June 2022)

• I wish I could give a zero-star rating for GOTOGATE. They cancelled our flight on 

March 24, 2022 through an email and when you call their customer service for any 

update on the refund, you get no explanation and you get rude and impatient 

people on the phone. I called mid-May and two weeks after and I have been 

38 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

39 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

40 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

41 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

42 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

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pleasant on the phone both times. They have no way of giving any update on the 

refund process and expect you to wait for their email only when the refund is on 

the way. It can apparently take up to more than six months for any update at all. 

You will have hoped you have never encountered them at all. I am a frequent 

traveller and this is the worst service I have ever come upon. I am warning 

everyone, NEVER USE GOTOTGATE FOR ANYTHING!43 (June 2022)

• Do yourself a favor and never use them. They are fraudsters and scammers. I 

booked flight a year ago for my family and they cancelled it. I never got any refund 

or they never gave me new tickets. They are the worst. Please do not use them, they 

will burn you.44 (May 2022)

• Horrible! Assumed I wad dealing with Booking.com. but apparently it was this 

place that booked the flight. ****** airlines canceled my flight. Been fighting for a 

refund for weeks. Getting runaround from ******, Booking.com and this place. DO 

Not Use any of them!!!45 (May 2022)

• BUYER BEWARE!!! Cancelled flights without rebooking services. Booking.com 

uses a third party vendor GoToGate. These jokers have the worst customer service. 

Ive made 5 calls trying to rebook or get refunds for the cancelled flights. Ive been 

disconnected during transfers and called a liar by one rep during this process. I 

WILL NEVER USE GO TO GATE AGAIN.46 (May 2022)

• This company is a scam. We booked our flight and due to a website error on the 

airline our flight was cancelled but they told us GoToGate could fix it by calling. 

The GoToGate rep was condescending and told me it was fixed, "this happens all 

the time", and to wait 24 hours for the system to update. 24 hours later a different 

rep tells me the issue was never fixed and the airline says it is now to late to fix. 

Gotogate tells me they will investigate and call me back as soon as possible with a 

resolution. It is now 3 weeks past my scheduled trip, GoToGate tells me they are 

still "Investigating" and refuse to give me anything in writing confirming the status 

of the investigation which prevents me from taking it up with my bank. I'm out 

$2200 for the flight and more with all the lost bookings for the actual trip. Do not 

use this service!!47 (May 2022)

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• Appears to be an unscrupulous company at best. Told me my flight was cancelled. 

I requested refund. I was told I had to wait uptom2 months for a refund. Also only 

refunded a fraction of the amount charged. Not at all confident i will ever see that 

money again.My advice....do not use!Wish I had read these reviews first.48 (May 

2022)

• GOTOGATE is a ****!! They offer cheap tickets which do not actually exist, then 

after you pay your flight is "cancelled" and they do not refund your money. DO 

NOT USE GOTOGATE!!49 (May 2022)

• Just like everyone else, my airline cancelled my flight and I have been fighting for 

almost six months to get a refund. Huge scam. Stay away!50 (April 2022)

• They sent no email with confirmation information on 2 tickets booked in 2020. 

The airline company has issued a refund as of late 2021 and they never refunded 

my credit card. Customer Service not all that great or trustworthy. They claim they 

are checking information and get no resolution. They like to play games either 

saying I can't get refunded since I called 3 months late. However they are holding 

on to my $1590.12 dollars. Not sure why this company is still in business and 

scamming customers. Save your selves the aggravation don't book thru them, go 

directly thru the airline company. I told them one way or the other I would get my 

refund but they weren't getting away with it.51 (April 2022)

46. Upon information and belief, GTG has a BBB rating of “F” and did not 

respond to any of the above-mentioned complaints.

47. Other websites with similar consumer complaints against GTG, including 

but not limited to:

48 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

49 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

50 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

51 https://www.bbb.org/us/fl/miami/profile/online-travel-agency/gotogate-inc-0633-

90363965/customer-reviews

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48. Disturbingly, upon information and belief, GTG has seen some or all of the refund 

disputes herein but ignores them and refuses to respond to negative consumer complaints. Instead, 

GTG only responds to certain 5-star reviews:

49. GTG knew or should have known that it was receiving and would continue to 

receive complaints and reports of breach of contract, failure to refund its customers, and continuing 

its deceptive and unlawful business practices.

50. GTG has committed a host of unlawful business practices, including: (a) breaching 

its contractual obligations to process payments to Plaintiff and other Class Members by the 

specified date after completed transactions; (b) falsely advertising its commitment to assist 

customers with airline services to receive travel refunds by a certain date after cancellation; (c) 

Case 1:22-cv-23084-DPG Document 1 Entered on FLSD Docket 09/23/2022 Page 26 of 38
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keeping possession of refund payments once reimbursed by an airline and/or without rebooking a 

customer on a future flight; failing to process consumer cancellation refund requests; (d) 

marketing, advertising, and charging inflated fees based on reasonable expectations about refund 

payment timing.

51. GTG repeatedly failed to disclose to prospective e-commerce travelers that it would 

not process refund payments and/or that its refund payments would be severely delayed by many 

months. The company’s deception has damaged Plaintiff and Class Members, either through total 

non-payment, delayed payments without interest, and/or inflated fees. Indeed, GTG is not entitled 

to any fees or commission given its wildly unlawful conduct and that it manufactured the delay it 

seeks to hide behind. 

52. GTG has disabled and removed any and all derogatory or negative consumer 

reviews, complaints, and/or comments on its Google page.52 GTG therefore knowingly and 

repeatedly fails to disclose its fraudulent and unlawful conduct, and actively conceals its conduct 

from new consumers.

53. GTG fails to make payments to e-commerce consumers, which is a direct and 

material breach of the Terms and Conditions of the contractual obligations entered into and agreed 

to by Plaintiff and Class Members. 

54. By prolonging and/or refusing to make payments to e-commerce consumers, GTG

can use the payment refunds as an interest free and tax-free loan to itself.

55. Without paying Plaintiff and hundreds of other customers, GTG’s e-commerce

marketplace is essentially operating as a scam used to bilk travelers out of cancelled travel services

52https://www.google.com/search?q=gotogate&oq=gotogate&aqs=chrome..69i57.1054j

0j1&sourceid=chrome&ie=UTF-8

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and unlawfully retaining refunds from consumers—a fact it tries to spin in a positive light in its 

marketing materials and on its website, as GTG claims to assist its customers with refunds.

56. Plaintiff and Class Members have suffered actual damages as a result of GTG’s 

material breaches of its Terms and Conditions contract.

57. Plaintiff and Class Members have suffered actual damages as a result of GTG

engaging in various unfair and deceptive trade practices described herein, including falsely 

advertising timely refund payments, inflating fees or commission prices based on timely payments, 

and retaining lucrative refund payments without ever returning refunds to its customers or paying 

interest for excessive delays.

58. Had Plaintiff known the truth about GTG’s unlawful business practices—including 

its failure to refund payments and its inflated fees or commissions—he would not have used GTG’s 

services to purchase airline tickets for his daughters. 

59. GTG’s marketing and advertising was and is false, misleading, and reasonably 

likely to deceive the public.

V. Class Action Allegations

60. Plaintiff seeks to bring this case as a class action on behalf of himself and all other 

persons similarly situated, pursuant to Rule 23 of the Federal Rules of Civil Procedure. The 

proposed class (the “National Class” and “Florida Subclass” are collectively referred to as the 

“Class”) is defined as follows:

National Class

All persons in the United States who (a) submitted a cancellation 

request within 24-hours of booking with GotoGate and received an 

automatically generated email from GTG acknowledging receipt of 

cancellation with a time stamp dated within 24-hours of booking; 

and (b) were not issued a refund payment by GotoGate following 

the cancellation. 

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Florida Subclass

All Florida residents who (a) submitted a cancellation request within 

24-hours of booking with GotoGate and received an automatically 

generated email from GTG acknowledging receipt of cancellation 

with a time stamp dated within 24-hours of booking; and (b) were 

not issued a refund payment by GotoGate following the completed 

transaction and cancellation. 

61. Expressly excluded from the Class are:

a. any Judge or Magistrate presiding over this action and members of their immediate 

families;

b. GotoGate and any entity in which GotoGate has a controlling interest, or which has a 

controlling interest in GotoGate and its legal representatives, assigns and successors; and 

c. all persons who properly execute and file a timely request for exclusion from the Class. 

62. Plaintiff reserves the right to amend the Class definition at the Class Certification 

stage of the litigation if further investigation and discovery indicates that the Class definition 

should be narrowed, expanded, or otherwise modified.

Rule 23(a) Criteria

63. Numerosity. The exact number of Class members is unknown as such information 

is in the exclusive control of GTG. However, due to the nature of the trade and commerce involved

and the number of reviews and complaints, Plaintiff believes the Class consists of thousands of 

consumers, geographically dispersed throughout the United States, making joinder of all Class 

members impracticable. Class members are ascertainable from a review of GTG’s business 

records.

64. Commonality. Common questions of law and fact affect the right of each Class 

member and common relief by way of damages is sought for Plaintiff and Class members. The 

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harm that GTG has caused or could cause is substantially uniform with respect to Class members. 

Common questions of law and fact that affect the Class members include, but are not limited to:

(a) Whether GTG Terms and Conditions contract is uniform for all Class Members;

(c) Whether GTG’s practice of not reimbursing consumers after receiving notice of

cancellation within 24-hours of booking is a breach of its terms;

(d) Whether GTG’s practice of retaining consumers’ refund proceeds violates Florida

law as an unfair and deceptive practice;

(d) Whether GTG’s breach of its contractual refund payment obligations precludes it

from taking any service fees (or a lower service fee) on the refund of the goods at issue; 

(f) Whether GTG was unjustly enriched by retaining the customers’ refund monies;

and

(g) Whether the members of the Class have sustained damages and, if so, the proper

measure of such damages.

65. Typicality. The claims and defenses of the representative Plaintiff are typical of

the claims and defenses of the Class because they are all owed a refund of monies unlawfully 

retained by GTG. Additionally, GTG failed to disclose to each Class Member that it would not 

process owed refund payments to customers in a timely manner under the contract—or even at all. 

Plaintiff has suffered damages of the same type and the same manner as the Class he seeks to 

represent and is similarly affected by GTG’s wrongful conduct. Specifically, Plaintiff should have 

received a full refund of $721.97 as a result of his cancellation within 24-hours of purchase but

has not received any refund payment to date. Plaintiff has also not received any interest on the 

amount due and has been deprived of the use of his money while be unlawfully retained by GTG. 

There is nothing peculiar about Plaintiff’s claims. Indeed, Plaintiffs’ claims are typical of the 

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claims of other class members as detailed in the complaints quoted above.

66. Adequacy of Representation. The representative Plaintiff will fairly and 

adequately assert and protect the interests of the Class. First, Plaintiff has hired attorneys who are 

experienced in prosecuting class action claims within this state and across the United States, and 

who will adequately represent the interests of the Class. Second, Plaintiff has no conflict of interest 

that will interfere with the maintenance of this class action as his claims are the same as the class 

members he seeks to represent.

Rule 23 (b) Criteria

67. The common questions of law and fact set forth herein predominate over any 

questions affecting only individual Class members, including whether GTG unlawfully retains 

customers’ refund monies from flights cancelled within 24-hours of booking. A class action 

provides a fair and efficient method for the adjudication of this controversy for these reasons and 

is superior to the alternative methods involved in individual litigation.

68. Although the class is numerous enough to meet the numerosity requirement, the 

proposed Class does not create manageability problems because the claims turn on common legal 

determinations. Either the contractually required refund payments were timely made or they were 

not. There are no unusual legal or factual issues that would create manageability problems as the 

issues turn on interpretation of GTG’s standard form Terms and Conditions contracts and 

marketing materials.

69. Prosecution of separate actions by individual members of the Class would create a 

risk of inconsistent and varying adjudications against Defendant when confronted with 

incompatible standards of conduct. 

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70. Despite the costly nature of the refund monies retained by GTG, the claims of the 

individual Class members are, nevertheless, small in relation to the expenses of individual 

litigation, making a Class action the only procedural method of redress in which Class members 

can, as a practical matter, recover their damages and stop the unfair and deceptive practices at 

issue. 

71. Injunctive relief is also proper because GTG has acted or refused to act on grounds 

that apply generally to the Class, so that final injunctive relief is appropriate with respect to the 

class as a whole to prevent further harm from repetitive deceptive and unfair retention of 

customers’ refund monies.

72. Class members are readily identifiable and ascertainable given the online nature of 

GTG’s business practices. The company’s generic email distributed after a refund request within 

24-hours of booking creates a written acknowledgement of a cancellation request made within 24 

hours of booking which will make identification of Class members simple and straightforward. 

Tolling of any Applicable Statutes of Limitations

73. For the reasons set forth herein, Plaintiff and putative members of the Class are 

within the applicable statute of limitation for the claims presented here. GTG actively concealed 

that it would untimely refund payments or refund payments at all when customers request a 

cancellation within 24-hours of booking, including by not responding to written letters, requiring 

customers to call airlines for refunds when it knows the airlines require customers to request via 

GTG, sending generic emails about refund payments and delays, among other things. Thus, GTG

is estopped from asserting any statute of limitation defense that might otherwise be applicable to 

the claims asserted herein.

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VI. CAUSES OF ACTION

COUNT I

Breach of Contract

(On Behalf of the National Class)

74. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1-73, as if set 

forth fully herein.

75. Plaintiff and Class Members entered into identical Terms and Condition contracts 

with GTG when they booked travel using GTG’s services, submitted cancellation requests for 

refunds within 24-hours of booking, and received the same automated generic email from GTG 

confirming its receipt. The identical Terms and Conditions are therefore binding on both GTG and 

all Class members, including Plaintiff.

76. Plaintiff and Class Members performed all conditions precedent under the Terms 

and Conditions contract prior to filing this action.

77. Plaintiff’s and Class Members’ Terms and Conditions contract with GTG required 

refund payments from GTG and required Class Members to use GTG as the middleman to recover 

a refund. 

78. Specifically, GTG’s Terms and Conditions make the following contractual 

promise: “If you wish to request a change or cancellation refund, as an additional own service, 

We offer to handle the request on your behalf if permitted by the conditions of the airline." 53 

79. All airlines operating within the United States are required to provide full refunds 

to all flights cancelled within 24 hours of booking. Thus, GTG’s promise to provide cancellations 

and refunds consistent with the “conditions of the airline” requires a full refund of all flights 

cancelled within 24 hours. 

53 https://www.gotogate.com/rf/travel-conditions#APPENDICES_FEES

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80. GTG breached the Terms and Conditions contract by failing to refund Plaintiff and 

Class Members following its receipt and acknowledgement of their refund request. For example, 

Plaintiff purchased flights on April 25, 2022, at 1:42 p.m., EST. This purchase was confirmed by 

email from GTG. Shortly thereafter, and within 24 hours of booking, Plaintiff submitted a written 

request for cancellation to GotoGate using its website form located at www.gotogate.com.

81. On April 25, 2022, at 5:18 p.m., GotoGate sent an automatically generated email 

confirmation to Plaintiff and acknowledged that it had received Plaintiff’s request for cancellation.

82. On information and belief, similar “Cancellation” emails are automatically 

generated by GTG once an online request has been made for a cancellation and refund. These 

email requests satisfy the written request requirement of the Terms and Conditions and will 

identify class members who also requested a refund within 24 hours of booking. 

83. As a direct and proximate result of GTG’s breach, Plaintiff and Class Members 

have suffered actual damages by failing to receive monies they are contractually owed for refund 

of travel cancelled within 24-hours of booking. 

84. Additionally, Plaintiff and the class did not receive any prejudgment interest on the 

refund amounts due. 

85. Specifically, Plaintiff has suffered monetary damage equal to $721.97, the purchase 

price of his two cancelled flights plus interest thereon. As a result of GTG’s breach of contract, 

GTG should not be permitted to obtain any fees related to the refunds completed on behalf of 

Plaintiff and the Class. Therefore, Plaintiff and Class Members demand refund of the full price of 

the travel purchased on GTG’s website as a result of GTG’s breach of contract, without any 

deduction for refund administrative or processing fees. 

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COUNT II

Violation of Florida’s Deceptive and Unfair Trade Practices Act

Florida Statute Section 501.201, et seq.

(On Behalf of the Florida Subclass)

86. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1-73, as if set

forth fully herein.

87. The purpose of the Florida Deceptive and Unfair Trade Practices Act, Fla. Stat. §

501.201, et seq., (“FDUTPA”) is to “protect the consuming public ... from those who engage in 

unfair methods of competition, or unconscionable, deceptive or unfair acts or practice in the 

conduct of any trade or commerce.” Fla. Stat. § 501.202(2).

88. Plaintiff and the members of the Class are a “consumer” as defined by Florida

Statute § 501.203(7).

89. The airline tickets are “trade or commerce” as defined by Florida Statute §

501.203(8).

90. FDUTPA was enacted to protect the consuming public and legitimate business

enterprises from those who engage in unconscionable, deceptive, or unfair acts or practices in the 

conduct of any trade or commerce, and in unfair methods of competition.

91. From its United States headquarters in Miami Florida, GTG makes decisions on

how to hand refund payments due to customers residing within the United States. It also collects 

and holds in Miami cancellation refund payments from various airlines for cancelled flights. On 

information and belief, the funds that are due and owing to Plaintiff and the class are retained 

within the state of Florida. 

92. For the reasons discussed herein, GotoGate violated FDUTPA by engaging in the

actions described herein by failing to disclose that GTG does not actually issue refunds, causes 

extreme delays in returning refunds, and/or charges excessive fees in issuing refunds beyond its 

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Terms and Conditions contract with the Class, which violates Florida Statute § 501.201, et. seq. 

GTG’s unconscionable, deceptive, and unfair acts and practices described herein were likely to, 

and did in fact, deceive members of the public, including consumers (like Plaintiff and members 

of the Class) acting reasonably under the circumstances and to their detriment.

93. In committing the acts alleged above, GTG engaged in unconscionable, deceptive,

and unfair acts and practices failing to disclose the true nature of its refund policy that resulted in 

withholding refund payments, extreme delays in returning refunds, and/or excessive fees beyond 

the scope and agreement in the Terms and Conditions contract between GTG and the Class.

94. GTG’s actions constitute unconscionable, deceptive, or unfair acts or practices

because, as alleged herein, GTG failed to disclose to Plaintiff and members of the Class the true 

nature of its refund policy, thereby offending an established public policy with the Department of 

Transportation and airline policies to provide full refunds for any flights cancelled within 24 hours, 

and engaging in immoral, unethical, oppressive, and unscrupulous activities that are and were 

substantially injurious to consumers.

95. In committing the acts alleged above, GTG engaged in unconscionable, deceptive,

and unfair acts and practices.

96. GTG’s conduct is unconscionable, deceptive, and unfair, as it is likely to, and did,

mislead consumers acting reasonably under the circumstances. Plaintiff and members of the Class, 

as consumers, relied on GTG’s representations.

97. As a direct and proximate result of GTG’s conduct, Plaintiff and the members of

the Class have been harmed by not receiving the benefit of their bargain. Specifically, Plaintiff and 

the Class cancelled their travel within 24-hours of booking and requested a timely refund. In 

respond, GTG acknowledged receipt of the timely cancellation and request for refund. However, 

Case 1:22-cv-23084-DPG Document 1 Entered on FLSD Docket 09/23/2022 Page 36 of 38
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GTG failed to provide any refund at all despite its representations to the contrary. Plaintiff and 

members of the Class have suffered actual damage in the amount of the ticket price paid for all 

flights cancelled within 24 hours of booking. 

98. Specifically, Plaintiff has suffered monetary damage of $721.97, the amount he

paid for the flights cancelled within 24 hours, plus any interest due thereon. 

99. As a direct and proximate result of the unconscionable, unfair, and deceptive acts

or practices alleged herein, Plaintiff and members of the Class have been damaged and are entitled 

to recover actual damages, to the extent permitted by law, including Florida Statutes § 501.211 in 

an amount to be proven at trial. In addition, pursuant to Florida Statute § 501.211, Plaintiff and the 

members of the Class seek equitable relief and to enjoin GTG on terms the Court considers reasonable. 

100. Plaintiff and the members of the Class also seek reasonable attorneys’ fees and

costs, as prescribed by Florida Statutes § 501.211(2). 

Prayer for Relief 

WHEREFORE, Plaintiff prays that this case be certified and maintained as a class action 

and for judgment to be entered against GotoGate as follows: 

A. Enter an order certifying the proposed Class, designating Plaintiff as the Class

representative, and designating the undersigned as Class Counsel;

B. Declare that GotoGate is financially responsible for notifying all Class members;

C. Declare that GotoGate must disgorge, for the benefit of the Class, the ill-gotten

profits it received from retaining cancelled flight proceeds;

D. For economic and compensatory damages on behalf of Plaintiff and all members of

the Class;

E. For actual damages sustained, as allowed by law;

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F. For punitive or exemplary damages;

G. For injunctive and declaratory relief;

H. For reasonable attorneys’ fees and reimbursement of all costs for the prosecution

of this action pursuant to Florida Statute § 501.211(2); and

I. For such other and further relief as this Court deems just and appropriate.

Jury Demand 

Plaintiff hereby demands a trial by jury on all issues so triable. 

DATED this 23rd day of September, 2022. 

Respectfully submitted, 

/s/ Brian W. Warwick 

BRIAN W. WARWICK, FBN: 0605573 

JANET R. VARNELL, FBN: 0071072 

MATTHEW T. PETERSON, FBN: 1020720 

ERIKA WILLIS, FBN: 

1101 E. CUMBERLAND AVE., STE. 201H, #105 

TAMPA, FL 33602 

TELEPHONE: (352) 753-8600 

FACSIMILE: (352-504-3301 

jvarnell@vandwlaw.com 

bwarwick@vandwlaw.com 

mpeterson@vandwlaw.com 

ewillis@vandwlaw.com 

kstroly@vandwlaw.com 

Christopher J. Brochu 

FL BAR NO.: 1013897 

Brochu Law, PLLC 

841 Prudential Drive, Suite 1200 Jacksonville, 

Florida 32207 Telephone: 904-201-1771 

C.BROCHU@BROCHULAW.COM

38

Attorneys for Plaintiff, Mark Bent, and on behalf of all 

others similarly situated. 

100021 

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