EXHIBIT 99.1

                          UNITED STATES DISTRICT COURT
                          SOUTHERN DISTRICT OF FLORIDA


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RICHARD BOGEN,                                       :
                                                     :
         Plaintiff,                                  :
                                                     :        Civil Action No.
         - against -                                 :
                                                     :
KENNETH BURROUGHS, DOUGLAS W.                        :        CLASS ACTION
BAENA, JOSEPH J. MESSINA, BRUCE                      :        COMPLAINT
FOERSTER, JOE C. GREENE, SUSIE                       :
HENRY, LARRY MUELLER, MAKO                           :
MARINE INTERNATIONAL, INC.,                          :
TRACKER MARINE, L.P., and                            :
TRACKAQ, INC.,                                       :
                                                     :
                  Defendants.                        :
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         Plaintiff,   individually  and  on  behalf  of  all  persons  similarly
situated,  by his attorneys,  alleges the following upon information and belief,
except for those allegations  which pertain to plaintiff,  which allegations are
based upon  personal  knowledge,  after due  investigation  by his counsel.  The
investigation  included a review and analysis of public statements and corporate
documents of defendants, including filings with the United States Securities and
Exchange Commission (the "SEC"),  analyst reports, and other review and analysis
of materials  concerning the  defendants  named herein and the  allegations  set
forth   below,   including   newspaper   articles   and  articles  in  financial
publications:

                              NATURE OF THE ACTION

         1. This  action  arises  out of an  unlawful  scheme and plan to enable
Trackaq,  Inc. ("Trackaq") to acquire the remaining  approximately 19% ownership



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of Mako Marine International,  Inc. ("Mako" or the "Company") which Trackaq does
not  already  own  for  grossly  inadequate   consideration  and  in  breach  of
defendants'  fiduciary  duties.  Plaintiff  alleges that he and the other public
stockholders   of  Mako  common  stock  are  entitled  to  enjoin  the  proposed
transaction,  or alternatively,  to recover damages in the event the transaction
is  consummated.  

                             JURISDICTION AND VENUE

         2. This  action  arises  under the common law of the State of  Florida.
This Court has  jurisdiction  over this action  pursuant  to 28 U.S.C.  ss. 1332
(diversity of  citizenship).  With regard to the  requirements of 28 U.S.C.  ss.
1332,  plaintiff  avers that he is a citizen of the State of New Jersey and that
each of the  defendants  are  citizens  of  states  other  than the State of New
Jersey,  and that the  matter  in  controversy  exceeds  $75,000,  exclusive  of
interest and costs. 

         3. Venue is proper in this District because many of the acts complained
of, including the development and the carrying out of the proposed  transaction,
occurred within this District.  In addition,  several of the defendants transact
business or reside in this District and Mako maintains its principal  offices in
this District.

                                   THE PARTIES

         4. Plaintiff Richard Bogen is, and at all relevant times was, the owner
of Mako common stock. 

         5.  Defendant  Mako is a corporation  organized and existing  under the

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laws of the State of Florida with its  principal  executive  offices  located at
4355 NW 128th Street, Miami, Florida 33054. Mako designs, manufactures and sells
offshore boats for sport fishermen and recreational  use. The Company markets 24
models  ranging  in length  from 17 to 29 feet.  Mako  sells  its boats  through
independent  dealers  along the  eastern  coast of the United  States,  the Gulf
Coast, the Great Lakes region and in foreign markets.

         6. Defendant Trackaq is a corporation  organized and existing under the
laws of the State of Florida.  Trackaq is a  wholly-owned  subsidiary of Tracker
Marine, L.P. ("Tracker Marine"). According to Mako's Schedule 13D/A-2 filed with
the SEC on August 7, 1997,  Trackaq  owns of record and  beneficially  7,330,000
shares of the common stock of Mako, representing approximately 81% of the issued
and outstanding shares of the common stock of Mako.

         7. Defendant  Tracker Marine is a limited  partnership  organized under
the laws of the State of Missouri with its principal  executive  offices located
at 2500 East  Kearney,  Springfield,  MO 56803.  Tracker  Marine's  sole general
partner  is  JLM  Management   Company  ("JLM"),   a   privately-held   Missouri
corporation.  John L. Morris ("Morris") is the sole director of JLM and, through
a revocable  trust,  the  indirect  beneficial  owner of all of the  outstanding
capital stock of JLM. On January 16, 1997,  Tracker Marine  acquired  control of
Mako by means of Tracker  Marine's  purchase of 930,000  shares of common  stock
from  CreditAmerica  Venture Capital,  Inc.  ("CAVC"),  immediately  followed by
Tracker's  purchase  from Mako of 6,400,000  newly issued shares of common stock
("Mako  Shares").  With its  acquisition of the CAVC shares,  along with the 6.4
million newly issued Mako shares,  Tracker Marine  acquired a total of 7,300,000

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shares  of  common  stock,  representing  approximately  81%  of  the  currently
outstanding shares of Mako common stock.

         8. Defendant Kenneth Burroughs  ("Burroughs"),  a resident of Missouri,
is the  Chairman  of the Board  and  Chief  Executive  Officer  of the  Company.
Burroughs was designated to the Board by Tracker  Marine,  pursuant to the Stock
Purchase  Agreement  dated  December 4, 1996, by and between  Tracker Marine and
Mako,  and appointed by the Mako Board  effective upon the  consummation  of the
transaction on January 16, 1997.

         9.  Defendant  Susie  Henry  ("Henry"),  a resident of  Missouri,  is a
director of the Company.  Henry was  designated to the Board by Tracker  Marine,
pursuant to the Stock Purchase  Agreement dated December 4, 1996, by and between
Tracker  Marine and Mako,  and  appointed by the Mako Board  effective  upon the
consummation  of the  transaction  on January 16,  1997.  Henry is the sister of
Morris.

         10. Defendant Larry Mueller ("Mueller"),  a resident of Missouri,  is a
director of the Company.  Mueller was designated to the Board by Tracker Marine,
pursuant to the Stock Purchase  Agreement dated December 4, 1996, by and between
Tracker  Marine and Mako,  and  appointed by the Mako Board  effective  upon the
consummation   of  the   transaction  on  January  16,  1997.   Mueller  is  the
brother-in-law of Morris.

         11. Defendant Joe C. Greene  ("Greene"),  a resident of Missouri,  is a
director of the Company.  Greene was designated to the Board by Tracker  Marine,
pursuant to the Stock Purchase  Agreement dated December 4, 1996, by and between


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Tracker  Marine and Mako,  and  appointed by the Mako Board  effective  upon the
consummation of the transaction on January 16, 1997.

         12. Defendant Douglas W. Baena ("Baena"),  a resident of Florida,  is a
director  of the  Company.  Baena is the former  Chairman  of the  Board,  Chief
Executive Officer and President of the Company.

         13. Defendant Joseph J. Messina ("Messina"), a resident of New York, is
a director of the Company.

         14.  Defendants  Baena and Messina,  in February  1994,  formed  Credit
America Venture Capital,  Inc. ("CAVC").  CAVC was the principal  shareholder of
Mako until the  consummation of the transaction  with Tracker Marine.  To enable
Tracker Marine to acquire the  approximately  81 percent interest in Mako, CAVC,
through Baena and Messina,  sold 930,000  shares of Mako common stock to Tracker
Marine,  which represented at the time approximately 35% of Mako's common stock,
at a net price of $1.40 per share.

         15. Defendant Bruce Foerster ("Foerster"),  a resident of Florida, is a
director of the Company.

         16. The above-named individual defendants (collectively the "Individual
Defendants") as officers and/or directors of the Company,  and/or as significant
shareholders of the Company owe fiduciary  duties of good faith,  loyalty,  fair
dealing,  due care,  and candor to plaintiff  and the other members of the Class
(as defined below).

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                            CLASS ACTION ALLEGATIONS

         17.  Plaintiff  brings this action as a class action  pursuant to rules
23(a) and 23(b)(3) of the Federal Rules of Civil Procedure (Fed. R. Civ. P.") on
behalf of himself  and all other  stockholders  of the  Company as of August 12,
1997  (the  "Class"),  and  their  successors  in  interest,  who are or will be
threatened with injury arising from defendants' actions. Excluded from the Class
are  the  defendants  herein,  members  of  their  immediate  families,  and any
subsidiary,  firm, trust, corporation,  or other entity related to or affiliated
with any of the defendants.

         18.  This  action is properly  maintainable  as a class  action for the
following  reasons:  

         (a)  the  Class  is  so  numerous   that  joinder  of  all  members  is
impracticable.  While the exact number of Class  members is unknown to plaintiff
at this time and can only be ascertained  through appropriate  discovery,  there
are more  than 9  million  shares  of Mako  common  stock  outstanding,  held by
hundreds of shareholders of record.  The holders of these shares are believed to
be geographically  dispersed  throughout the United States. Mako common stock is
listed and actively traded on the NASDAQ/National  Market System Bulletin Board;


         (b) there are  questions of law and fact which are common to members of
the Class and which  predominate  over any questions  affecting only  individual
members. The common questions include, inter alia, the following:

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                  (i) whether  defendants  have  engaged and are  continuing  to
         engage in a plan and  scheme to benefit  Trackaq at the  expense of the
         members  of the Class;  (ii)  whether  the  Individual  Defendants,  as
         directors   and/or  officers  of  the  Company  and/or  as  significant
         shareholders of the Company,  have breached their fiduciary duties owed
         to plaintiff and the other members of the Class, including their duties
         of entire  fairness,  loyalty,  due care,  and  candor;  (iii)  whether
         defendants  have  disclosed all material  facts in connection  with the
         challenged  transaction;  and  (iv)  whether  plaintiff  and the  other
         members of the Class would be irreparably  damaged were  defendants not
         enjoined from the conduct described herein; 

         (c) the  claims of  plaintiff  are  typical  of the claims of the other
members  of the  Class  and  plaintiff  has  no  interest  that  is  adverse  or
antagonistic  to the  interests of the Class;  

         (d) the  plaintiff  is  committed  to  prosecuting  this action and has
retained  counsel  competent  and  experienced  in  litigation  of this  nature.
Plaintiff  is an  adequate  representative  of the  Class  and will  fairly  and
adequately  protect  the  interests  of the  Class;  and 

         (e) a class action is superior to other available  methods for the fair
and efficient  adjudication of this controversy  since a multiplicity of actions
could result in an  unwarranted  burden on the court system and could create the
possibility  of  inconsistent  judgments.  Moreover,  a class  action will allow
redress for many persons  whose claims would  otherwise be too small to litigate
individually.  There will be no difficulty in the management of this action as a
class action.

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                             SUBSTANTIVE ALLEGATIONS

         19. On August 8, 1997,  Tracker Marine announced that Trackaq adopted a
Plan of Merger pursuant to which Trackaq will merge into Mako. Under the Plan of
Merger,  the public  shareholders  of Mako will  receive  $1.25 in cash for each
share of Mako common stock they own, and holders of public warrants will receive
$0.125 in cash for each warrant they own (the "Transaction").  Upon consummation
of the proposed  merger,  Mako will become a wholly-owned  subsidiary of Tracker
Marine. JLM, the sole general partner of Tracker Marine, has approved the merger
of Trackaq with and into Mako.

         20. The purpose of the  Transaction is to enable Trackaq to acquire one
hundred percent (100%) equity  ownership of Mako and its valuable assets for its
own benefit at the expense of Mako's public  stockholders,  who will be deprived
of their equity  investment  and the  benefits  thereof  including,  among other
things, the expected growth in the Company's profitability.

         21. The Transaction is the product of unfair dealing,  and the price of
$1.25 cash per share is unconscionable  and unfair and so grossly  inadequate as
to constitute a gross breach of trust committed by defendants against the public
stockholders because, among other things:

         (a) the  announcement  of the  proposed  Transaction  was made when the
Company was poised for  significant  future  growth and  earnings.  On August 4,

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1997, the Company announced its preliminary  operating results for the three and
twelve  month  periods  ended June 28,  1997.  The  Company  expects  revenue of
approximately  $6.3 million with a net loss of  approximately  $425,000 or $0.26
per share for the fourth  quarter of fiscal  1996.  This  compares to revenue of
$6.1  million  and a net loss of  $706,000  or $0.26 per  share  for the  fourth
quarter of fiscal 1996.  Further,  revenues for the Company's  fiscal year ended
June 28, 1997 is expected to be  approximately  $20.1 million with a net loss of
approximately  $3.85  million or $0.69 per share.  This  compares  to revenue of
$19.9  million and a net loss of $3 million or $1.19 per share for fiscal  1996.


         (b) because  Trackaq has an  overwhelming  controlling  interest in the
Company's  common  stock,  no  third  party  will  likely  bid for  Mako.  Thus,
defendants  will be able to proceed with the  Transaction  without an auction or
other type of market check to maximize value for Mako's public shareholders; and


         (c) defendants  timed the  announcement  of the Transaction to place an
artificial  lid or cap on the market price for Mako's stock to enable Trackaq to
acquire the minority stock at the lowest possible price.  The price of $1.25 per
share  represents  no  premium  over the  market  price on the day  prior to the
announcement  of the Transaction  ($1.25 per share).  It is also below the price
that the stock reached  within the last six months  ($3.25 per share),  and year
($4.125  per  share).  

         22.  By  reason  of  their  positions  with  Mako  and the  controlling
ownership of the Company, the defendants have a fiduciary  relationship with the

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plaintiff  and the members of the Class and owe to them the highest  obligations
of good faith and fair dealing. Further, by reason of defendants' positions with
Mako and  Trackaq's  controlling  ownership  of the Company,  defendants  are in
possession  of non-public  information  concerning  the financial  condition and
prospects of Mako, and especially the true value and expected  increased  future
value of Mako and its assets,  which have not been  disclosed  to Mako's  public
stockholders.  

         23. The defendants  are intent on paying the lowest price,  whereas the
defendants  also have the duty to  maximize  shareholder  value.  The  defendant
fiduciaries  have clear and material  conflicts of interest.  

         24. Any attempt to obtain a fair price for the minority shareholders of
Mako will be prevented by Trackaq  and/or its  representatives.  Trackaq and its
representatives  control  the Mako Board in that  defendants  Burroughs,  Henry,
Greene,  and Mueller  (who  comprise of four of the seven Mako  directors)  were
designated to the Mako Board by Tracker Marine. 

         25. The proposed Transaction is wrongful,  unfair and harmful to Mako's
minority  public  stockholders,  and  represents  an  effort  by  defendants  to
aggrandize  their own financial  position and/or interests at the expense of and
to the  detriment  of Class  members.  The  Transaction  is an  attempt  to deny
plaintiff   and  the  other   members  of  the  Class   their   right  to  share
proportionately in the true value of Mako's valuable assets,  while usurping the
same for the benefit of Trackaq on unfair and inadequate terms.

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         26.  Defendants,   in  failing  to  disclose  the  material  non-public
information  in their  possession  as to the  value of Mako's  assets,  the full
extent of the future  earnings  potential of Mako and its  expected  increase in
profitability,  have breached and are breaching  their  fiduciary  duties to the
members of the Class.

         27. Moreover, the Transaction is procedurally unfair in that it has not
been  disclosed   whether  the  Transaction  was  reviewed  and  approved  by  a
disinterested  third party.  

         28. As a result of  defendants'  unlawful  actions,  plaintiff  and the
other  members of the Class will be damaged in that they will not receive  their
fair portion of the value of Mako's assets and business in the  Transaction  and
will be prevented from obtaining the real value of their equity ownership of the
Company.  

         29.  Unless  the  proposed   Transaction  is  enjoined  by  the  Court,
defendants will continue to breach their fiduciary  duties owed to the plaintiff
and the members of the Class,  will not engage in  arm's-length  negotiations on
the Transaction  terms,  and will consummate and close the proposed  Transaction
complained of and succeed in their plan described  above, all to the irreparable
harm of the plaintiff and the other members of the Class.  

         30.  Plaintiff  and the other  members  of the Class  have no  adequate
remedy at law. 

         WHEREFORE, plaintiff, on behalf of himself and the other members of the
Class, demands judgment as follows:

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         (a)  declaring  this action to be a proper  class  action  maintainable
pursuant to Rule 23(b)(3) of the Fed. R. Civ. P. and certifying plaintiff as the
representative of the Class;

         (b)  ordering  defendants  to  carry  out  their  fiduciary  duties  to
plaintiff  and the other members of the Class,  including  those duties of care,
loyalty,  candor  and fair  dealing;  

         (c) granting  preliminary and permanent  injunctive  relief against the
consummation of the Transaction as described herein;

         (d) appointing a  disinterested  third party to review the terms of the
Transaction and explore alternatives;

         (e) in  the  event  the  Transaction  is  consummated,  rescinding  the
Transaction  effected by defendants  and/or awarding  rescissory  damages to the
Class;

         (f) ordering defendants, jointly and severally, to account to plaintiff
and other  members of the Class for all damages  suffered  and to be suffered by
them as the result of the acts and transactions alleged herein;

         (g)  awarding  plaintiff  the costs  and  disbursements  of the  action
including  allowances for plaintiff's  reasonable  attorneys' and experts' fees;
and (h)  granting  such other and further  relief as the Court may deem just and
proper.

Dated: August 12, 1997


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                                       GOODKIND LABATON RUDOFF
                                       & SUCHAROW LLP



                                       By:
                                          Emily C. Komlossy, Esq.
                                          Suite 2100
                                          200 South Biscayne Blvd.
                                          Miami, FL  33131
                                          (305) 579-1260
                                          (305) 579-1229 (fax)

                                          Attorneys for Plaintiff

OF COUNSEL:

WOLF POPPER LLP
845 Third Avenue
New York, N.Y.  10022
(212) 759-4600

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