Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 1 of 29 

UNITED STATES DISTRICT COURT 

DISTRICT OF CONNECTICUT 

FEDERAL TRADE COMMISSION, and 

STATE OF CONNECTICUT,

 Plaintiffs, 

v. 

CHASE NISSAN LLC, a limited liability 

company, also d/b/a MANCHESTER CITY 

NISSAN, and 

PATRICK DIBRE, individually and as an officer 

of CHASE NISSAN LLC, also d/b/a 

MANCHESTER CITY NISSAN, 

REFAAT SOBOH, aka BRIAN SOBOH, 

individually and as an officer 

of CHASE NISSAN LLC, also d/b/a 

MANCHESTER CITY NISSAN, 

MICHAEL HAMADI, 

AIHAM ALKHATIB, 

MATTHEW CHMIELINSKI, and 

FRED MOJICA, aka FREDDY MOJICA, 

Defendants. 

Case No. ____________ 

COMPLAINT FOR PERMANENT 

INJUNCTION, MONETARY 

JUDGMENT, CIVIL PENALTY 

JUDGMENT, AND OTHER 

RELIEF 

Plaintiffs, the Federal Trade Commission (“FTC” or “Commission”), and the State of 

Connecticut, by William Tong, Connecticut Attorney General, for their Complaint allege: 

1. The FTC brings this action for Defendants’ violations of Sections 5(a) of the FTC 

Act, 15 U.S.C. § 45(a). Defendants’ violations relate to deceptive and unfair practices in 

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advertising, marketing, promotion, offering for sale, lease, or financing, and sale, lease, or 

financing of motor vehicles. For these violations, the FTC seeks relief, including a permanent 

injunction and other relief, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b). 

2. The State of Connecticut, by and through William Tong, the Attorney General of 

the State of Connecticut, acting at the request of Bryan Cafferelli, Commissioner of the 

Connecticut Department of Consumer Protection, brings this action under the Connecticut Unfair 

Trade Practices Act (“CUTPA”), Chapter 735a of the Connecticut General Statutes, and more 

particularly General Statutes § 42-110m, to obtain injunctive relief against the Defendants’ 

alleged violations of General Statutes § 42-110b(a), to obtain other relief as is necessary to 

redress injury to consumers resulting from the Defendants’ violations of law, and disgorge 

Defendants of ill-gotten money and civil penalties, pursuant to General Statutes § 42-110o(b). 

JURISDICTION AND VENUE 

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

4. Supplemental jurisdiction over the State of Connecticut’s claims is proper under 

28 U.S.C. § 1367. 

5. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), (c)(1), and 

(c)(2), and 15 U.S.C. § 53(b). 

PLAINTIFFS 

6. The FTC is an independent agency of the United States Government created by 

the FTC Act, which authorizes the FTC to commence this district court civil action by its own 

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attorneys. 15 U.S.C. §§ 41–58. The FTC 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. 

7. The State of Connecticut, through its Attorney General acting at the request of the 

Commissioner of Consumer Protection, is authorized to initiate proceedings to enjoin violations 

of CUTPA and to seek injunctive relief, restitution, and civil penalties and other equitable relief 

as this Court deems appropriate under General Statutes §§ 42-110m and 42-110o. 

DEFENDANTS 

8. Defendant Chase Nissan LLC (“Chase Nissan”), also doing business as 

Manchester City Nissan, is a Connecticut limited liability company with its principal place of 

business at 30 Tolland Turnpike, Manchester, Connecticut 06040. Chase Nissan is a closely held 

corporation. Defendants Patrick Dibre and Refaat Soboh are the sole principals. Chase Nissan 

transacts or has transacted business in this District and throughout the United States. At all times 

relevant to this Complaint, acting alone or in concert with others, Chase Nissan has advertised, 

marketed, distributed, or sold automobiles to consumers throughout the United States. 

9. Defendant Patrick Dibre is a principal and managing member of Chase Nissan. At 

all times relevant to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of 

Manchester City Nissan, including the acts and practices described in this Complaint. As a 

principal and managing partner, he has the authority to control the practices alleged in this 

Complaint. In this capacity, he personally responded under oath to a 2021 inquiry by the State of 

Connecticut into Chase Nissan’s certification fee and add-on charge practices. He admitted that 

Chase Nissan charged additional certification fees, labeled these fees as “State of CT Inspection 

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and Safety Charges,” and labeled optional add-on charges that consumers did not have to 

purchase as “Taxable Fees.” Defendant Dibre, in connection with the matters alleged herein, 

transacts or has transacted business in this District and throughout the United States. 

10. Defendant Refaat Soboh, aka Brian Soboh is a principal and managing partner of 

Chase Nissan. At all times relevant to this Complaint, acting alone or in concert with others, he 

has formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices of Manchester City Nissan, including the acts and practices described in this 

Complaint. As a principal and managing partner, he has the authority to control the practices 

alleged in this Complaint. In this capacity, he prepared, participated in, or supervised Chase 

Nissan’s response to an FTC inquiry regarding certification fees and add-on charges, in which 

Chase Nissan admits that it received a 2021 inquiry from the State of Connecticut and consumer 

complaints. Defendant Soboh resides in this District and, in connection with the matters alleged 

herein, transacts or has transacted business in this District and throughout the United States. 

11. Defendant Michael Hamadi is the general manager of Manchester City Nissan. At 

all times relevant to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of 

Manchester City Nissan, including the acts and practices described in this Complaint. As general 

manager, he has the authority to control the practices alleged in this Complaint. He also has 

responded to at least one consumer complaint about unauthorized add-on charges and told 

employees who were charging a certification fee not to charge such a fee only on certain types of 

leased vehicles. Defendant Hamadi resides in this District and, in connection with the matters 

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alleged herein, transacts or has transacted business in this District and throughout the United 

States. 

12. Defendant Aiham Alkhatib is a finance manager at Manchester City Nissan. At all 

times relevant to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of 

Manchester City Nissan, including the acts and practices described in this Complaint. He has 

participated directly in charging consumers for add-on services without the consumers’ 

expressed informed consent or in falsely telling consumers that they are required to purchase 

add-on services. Defendant Alkhatib resides in this District and, in connection with the matters 

alleged herein, transacts or has transacted business in this District and throughout the United 

States. 

13. Defendant Matthew Chmielinksi is a sales manager at Manchester City Nissan. At 

all times relevant to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of 

Manchester City Nissan, including the acts and practices described in this Complaint. He has 

participated directly in charging consumers for additional inspection, reconditioning, or 

certification fees. He also has responded to consumer complaints about unauthorized or 

deceptive add-on charges. Defendant Chmielinski resides in this District and, in connection with 

the matters alleged herein, transacts or has transacted business in this District and throughout the 

United States. 

14. Defendant Fred Mojica, aka Freddy Mojica is a sales manager at Manchester City 

Nissan. At all times relevant to this Complaint, acting alone or in concert with others, he has 

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formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices of Manchester City Nissan, including the acts and practices described in this 

Complaint. He has participated directly in charging consumers for additional inspection, 

reconditioning, or certification fees. Defendant Mojica resides in this District and, in connection 

with the matters alleged herein, transacts or has transacted business in this District and 

throughout the United States. 

COMMERCE 

15. At all times relevant to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS ACTIVITIES 

16. Defendants operate Manchester City Nissan, an automobile dealership in 

Manchester, Connecticut. Defendants advertise certified pre-owned vehicles for low prices. 

Many consumers visit Defendants’ dealership because of the low advertised prices for certified 

pre-owned vehicles. But Defendants do not honor those prices. Instead, Defendants doublecharge consumers the cost to certify vehicles that Defendants had advertised as already certified. 

Worse, Defendants often fail to properly certify the vehicles they sell, leaving many consumers 

to pay twice for a service Defendants fail to perform once. Defendants also charge consumers for 

add-ons that they did not know about or authorize, or deceive consumers into paying for them by 

saying that they are required. In addition, Defendants lie about the amount of mandatory state 

registration and other fees consumers must pay. 

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Background on Certified Vehicles 

17. Defendants advertise and sell certified pre-owned cars. Certified vehicles come 

with a limited manufacturer warranty. Before advertising a used car as certified, Defendants 

must inspect the vehicle for safety issues and recondition the vehicle if any repairs are necessary. 

For example, to certify a Nissan vehicle, Defendants must perform an inspection in accordance 

with Nissan’s checklist, and if specific items need to be repaired, Defendants must recondition 

the vehicle to meet the manufacturer’s certification requirements. Defendants then must report 

the sale of the used vehicle and pay a certification fee to the manufacturer. The manufacturer 

does not activate the certified warranty unless and until the dealer reports the sale and pays the 

fee. 

Defendants’ Junk Certification Fees 

18. On their website and on third-party websites, Defendants—who describe 

themselves as the “#1 FACTORY CERTIFIED NISSAN DEALER IN NEW ENGLAND!”— 

advertise particular certified pre-owned vehicles for specific prices. For example, in one such ad 

on Defendants’ website, Defendants represent that consumers can purchase a “Nissan Certified” 

2021 Nissan Rogue S SUV for “Your Price” of $26,000. 

7 
2021 Nissan Rogue S SUV Stock #PC679674A 

t 2 other people interested in this vehicle 

0 335views 

$26,000 

Your Price 

0 Nissan Certified 

0 Low Mileage 

0 Carfax 1 Owner 

□ Bluetooth Connectivity 

® Back-up Camera * Fuel Efficient 

Q SCHEDULE MY 

~ TEST DRIVE 

8 Enlarge Photos (35) 

.GET PRE ~ APPROVED $ vouR 

~ Certified Pre-owned ~ "-._/. mifJ!S 

PAYMENT 

- Advertised price on all Certified Nissans include NEMAC Captive Finance Rebate-, Rogue S, 4D Sport Utility, 2.5L 14 DOHC 16V, CVT with Xtronic, /JWD, 

Super Black, Charcoal Cloth. 

At Manchester City Nissan we want you to know that all our vehicles are priced at a competitive value position to the market. We use an independent 3rd 

party software to research internet listings on all vehicles in the market so we can ensure that our prices are the most competitive out there. We do this 

simply so people choose us when they start searching for their next car. 

Priced below KBB Fair Purchase Price! 

Clean CARFAX. CARFAX One-Owner. 

Certified. Nissan Certified Details: 

• 167 Point Inspection 

• Transferable Warranty 

• Plus 1 Year Pre-Paid Maintenance Included. 

• Vehicle Histo,y 

• Limited Warranty: 84 Month/100,000 Mile (whichever comes first) from original in.service date 

• Warranty Deductible: $100 

• Roadside Assistance 

Our Sales, Service and Parts Departments work closely together to provide you with the most enjoyable, least stressful car-buying experience possible. The 

average tenure for our sales people, managers, technicians and all other employees is over 20 years. Most of them have been career employees of 

Manchester City Nissan - and with that much experience, you can be sure they'll provide you with the highest quality care for you and your vehicle. We are 

also proud to be a Better Business Bureau Accredited Business with an A• rating. 

Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 8 of 29 

19. Defendants also claim that certified vehicles come with an inspection and limited 

warranty. For example, the above advertisement lists several items below the header “Nissan 

Certified Details,” including an inspection and a “Limited Warranty: 84 Month/100,000 Mile 

(whichever comes first) from original in-service date.” 

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A true and correct copy of this ad is Attachment A to this Complaint. 

20. Based on Defendants’ ads, many consumers believe that Defendants will sell 

them the advertised certified vehicle for the advertised price. In numerous instances, however, 

when consumers attempt to purchase certified vehicles for the prices advertised, Defendants 

charge them hundreds to thousands of dollars in additional fees for services that are part of 

certifying a vehicle (e.g., fees for inspection, “CT Safety and Reconditioning,” “certification 

upgrades,” and “CPO,” which stands for certified pre-owned). In many instances, Defendants 

roll these costs into the price of the vehicle that appears in the agreement. 

21. For example, Defendants advertised a “Certified” 2017 Nissan Rogue for 

$15,700. Defendants did not sell the car for $15,700. Instead, Defendants charged the buyer a 

$5,295.65 inspection fee on top of the price advertised for a vehicle that was advertised as 

already inspected as part of the certification process. In another instance, Defendants advertised a 

“Certified” 2018 Nissan Altima for $14,000, but then charged the buyer a $2,525.00 fee for 

“connecticut [sic] safety and reconditioning” on top of the price advertised for a vehicle that was 

advertised as already reconditioned. Thus, in many instances, Defendants do not sell consumers 

the advertised certified vehicles for the advertised prices. 

22. Moreover, in numerous instances, Defendants represent that consumers are 

required to pay these additional inspection, safety and reconditioning, and certification fees to 

purchase vehicles. For example, Defendants told a consumer that a $2,250 fee was required for 

“CT Safety and Reconditioning.” 

23. In fact, consumers are not required to pay inspection, safety and reconditioning, 

and certification fees to purchase vehicles that are already advertised as certified. Many 

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manufacturers including Nissan specifically prohibit Defendants from separately charging for the 

cost of certification. Further, the State of Connecticut does not require consumers to pay a fee for 

safety and reconditioning. 

24. Additionally, in numerous instances, despite stating in advertisements that 

vehicles are certified and come with a limited warranty, Defendants do not get the vehicles 

certified by the manufacturer. In numerous instances, Defendants advertised a vehicle as 

certified, but did not report the sale of that vehicle or pay the certification fee to the 

manufacturer. Thus, the consumer did not receive a certified vehicle or the benefits of the limited 

manufacturer warranty that come with certification. In other words, Defendants often charge 

consumers twice for “certifying” a vehicle that they do not actually certify. 

Defendants’ Unlawful Add-On Charges 

25. Once consumers have settled on a price for the vehicle, consumers who are 

financing their purchase or leasing their vehicle must meet with a financing manager to go over 

the terms of their financing or leasing, frequently after a lengthy wait. Defendants present 

consumers with a stack of complex, highly technical documents and then rush consumers 

through the closing process, which typically requires consumers to sign their name in over a 

dozen places. The finance manager typically just shows the consumers where to sign. This 

process – from the consumer waiting to meet with someone from finance to the consumer 

signing their deal – often takes several hours. 

26. As part of these transactions, Defendants often charge consumers for add-ons, 

such as GAP insurance, service contracts, maintenance contracts, and Total Loss Protection 

(“TLP”). For example, Defendants tack on charges for TLP in more than 90% of their deals. 

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27. In numerous instances, Defendants have included add-on charges in the closing 

documents for these deals without obtaining the consumers’ express informed consent. These 

charges commonly amount to hundreds or thousands of dollars and are typically added to the 

amount financed and spread out over monthly payments, making the added charges more 

difficult to detect. 

28. Many consumers have complained about Defendants charging for add-ons 

without authorization. For example, one consumer agreed to purchase a 2017 Nissan Rogue 

Sport that was advertised for $20,500. She sat down with a salesperson and negotiated a 

payment. Then she met with the finance manager, Defendant Aiham Alkhatib, to discuss 

financing. He told her the monthly payment, which was higher than she had been quoted during 

her negotiation, but he did not explain why the payment had increased. The consumer assumed 

that the increased monthly payment was related to her credit. Defendant Alkhatib then had her 

sign the contract electronically on a tablet. 

29. It was not until after she left the dealership that she realized she had been charged 

for unwanted items. She was surprised to learn that, without her knowledge or authorization, 

Defendants had charged her $3,300 for a Nissan service contract and $3,500 for a preventative 

maintenance agreement. She also was surprised to learn that Defendants had charged her $516 

for TLP, again without her knowledge or consent. The consumer sought, and eventually 

obtained, a refund for some, but not all, of these charges. 

30. Defendants gave another consumer the impression that he was getting GAP 

insurance and a bumper-to-bumper warranty at no extra cost. He later discovered that Defendants 

had charged him $895 for GAP insurance and $4,160 for a service contract. 

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31. In some instances, Defendants have charged consumers for add-ons that they told 

the consumers were free. For example, one consumer was told by the finance manager that she 

would receive oil changes as a “gift.” She later discovered that, without her knowledge or 

consent, Defendants had charged her $289 for a maintenance contract, which included oil 

changes. 

32. In other instances, Defendants have charged consumers for add-on products that 

consumers have specifically declined. For example, one consumer complained that she was 

charged over $9,000 for four warranties (“Maintenance Care Protection,” “Chase Auto Care 

Purchase Platinum,” “Vehicle Service Contract,” and “Security + Maintenance”) and $516 for 

TLP that she specifically declined. 

33. In numerous other instances, Defendants tell consumers that the dealership or a 

third party such as the finance company requires consumers to purchase add-on products or 

packages to purchase, lease, or finance the vehicle. 

34. For example, Defendant Alkhatib indicated to one consumer that if she did not 

buy GAP insurance, the finance company would not loan her the money to purchase the car. 

Defendants added GAP insurance to her purchase. 

35. Defendants told another consumer that she had to buy GAP insurance, TLP, and 

an extended warranty. But because Defendants already had the keys to her trade-in and the plates 

had been already taken off the vehicle, she felt like she did not have the option to walk out, and 

she ended up with charges for add-on items she did not want. 

36. As another example, Defendants charge for TLP, an optional add-on that 

Defendants sometimes call “Vehicle Identification Number (VIN) Etching,” but label it as 

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“Taxable Fees (Estimated)” on consumers’ paperwork. This leads consumers to believe the 

charges are required taxes rather than optional add-ons. 

37. Despite Defendants’ claims that these add-on items are required, they are not. 

Consumers are not required to enter into add-on product agreements to purchase, lease, or obtain 

financing for a vehicle. Connecticut does not require consumers to purchase add-ons. Neither the 

finance company nor the third-party add-on provider require that the add-ons be sold. And 

Defendants charge some consumers for these add-ons, but not others, demonstrating that the addons are not required. 

Defendants’ Junk Fees for Registration and Other State Services 

38. In the contract and purchase or lease order, Defendants list the amount of each 

mandatory registration and other state fee. But, in many cases, those registration and other state 

fees are a fraction of what Defendants claim. Defendants simply tack on an additional amount in 

bogus fees on the consumers’ contract without the consumers’ knowledge or consent. 

39. For example, Defendants told one consumer that Connecticut registration and 

other state fees were $345. But, in fact, Connecticut registration and other fees were only 

$208.20. Defendants tacked on an additional $136.80 in bogus fees. 

40. In another case, Defendants told a consumer that Connecticut registration and 

other state fees were $245. But, in fact, Connecticut registration and other fees were only $190. 

Defendants tacked on an additional $55 in bogus fees. 

41. In numerous transactions, Defendants also double charge consumers taxes and the 

documentation fee without the consumers’ knowledge or consent by charging taxes and the 

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documentation fee once in negotiation and then, once the consumer has signed off on the 

negotiated price including taxes and the documentation fee, again in the final contract. 

Defendants Have Persisted in Their Misconduct 

42. On May 14, 2021, the Connecticut Department of Consumer Protection 

(“Connecticut DCP”) sent a civil investigative demand to Chase Nissan asking the dealership to 

identify various fees appearing in its sales paperwork, including “certification upgrade”, “State 

of CT Inspection and Safety Charge”, and “Taxable Fees (Estimated).” 

43. On September 29, 2021, Chase Nissan responded. Chase Nissan identified the 

“certification upgrade” as “an additional charge for an extended limited warranty.” Asked to 

identify the “State of CT Inspection and Safety Charge,” Chase Nissan responded, “This is the 

Certification Upgrade.” Chase Nissan answered that “[Taxable Fees (Estimated)] is for Vehicle 

Identification Number (VIN) Etching. The Dealer assesses a fee of $516.00 for VIN Etching. 

This fee is optional.” Patrick Dibre prepared the response and a swore under oath that these 

answers were accurate. 

44. On June 24, 2022, the Connecticut DCP sent a letter warning Chase Nissan that it 

was an illegal deceptive advertising practice to charge an additional certification fee for vehicles 

advertised as certified pre-owned or to advertise that a vehicle is certified pre-owned when, in 

fact, it is not certified. The Connecticut DCP also questioned Chase Nissan’s practice of labeling 

a charge as a “State of CT Inspection and Safety Charge” when it “has nothing to do with the 

State of Connecticut, safety of the vehicle or inspection of the vehicle” and is just another name 

for a certification. Finally, the Connecticut DCP warned Chase Nissan that by calling the fee for 

Vehicle Identification Number (VIN) etching “Taxable Fee (Estimated),” “a reasonable 

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consumer could fairly conclude that this is a requi[r]ed tax but it is, in fact, a voluntary service 

option that consumers may decline to purchase.” 

45. Defendants nonetheless have continued to charge consumers extra to certify 

vehicles that were advertised as certified. And they have continued to mislead consumers into 

thinking that optional add-on charges were required. 

46. Defendants’ practices have persisted despite consumer complaints made directly 

to them and on public websites. 

* * * 

47. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission. 

VIOLATIONS OF THE FTC ACT 

48. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” 

49. Misrepresentations or deceptive omissions of material fact constitute deceptive 

acts or practices prohibited by Section 5(a) of the FTC Act. 

50. Acts or practices are unfair under Section 5 of the FTC Act if they cause or are 

likely to cause substantial injury to consumers that consumers cannot reasonably avoid 

themselves and that is not outweighed by countervailing benefits to consumers or competition. 

15 U.S.C. § 45(n). 

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VIOLATIONS OF CUTPA 

51. At section 42-110b(a), CUTPA states the following: “[n]o person shall engage in 

unfair methods of competition and unfair or deceptive acts or practices in the conduct of any 

trade or commerce.” 

52. At section 42-110a(4), CUTPA states that “trade” and “commerce” shall mean the 

“advertising, the sale or rent or lease, the offering for sale or lease, or the distribution of any 

service or any property, tangible or intangible, real, personal or mixed, and any article, 

commodity, or thing of value in this state.” 

53. At section 42-110b(b), CUTPA also states that: “[i]t is the intent that in 

construing subsection (a) of this section, the commissioner and the courts of this state shall be 

guided by interpretations given by the Federal Trade Commission and the federal courts to 

Section 5(a)(1) of the Federal Trade Commission Act (15 U.S.C. § 45(a)(1)), as from time to 

time amended.” 

54. Defendants all operated, or have operated, from Connecticut. 

55. The acts and practices alleged in this Complaint all emanate from and are 

intimately associated with Connecticut, are directed at Connecticut consumers, and affect the 

marketing and sales of motor vehicles in Connecticut. Defendants are therefore engaged in trade 

or commerce in the State of Connecticut. 

Count I 

Misrepresentations Regarding Advertised Prices 

(by Plaintiff FTC against all Defendants) 

56. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants 

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represent, directly or indirectly, expressly or by implication, that Defendants will sell particular 

vehicles at specific prices. 

57. Defendants’ representations as described in Paragraph 50 are false or misleading 

or were not substantiated at the time the representations were made. 

58. Therefore, Defendants’ representations as described in Paragraph 50 constitute 

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

Count II 

Misrepresentations Regarding Certification 

(by Plaintiff FTC against all Defendants) 

59. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants 

represent, directly or indirectly, expressly or by implication, that Defendants will sell consumers 

a certified used vehicle with a limited manufacturer warranty. 

60. Defendants’ representations as described in Paragraph 53 are false or misleading 

or were not substantiated at the time the representations were made. 

61. Therefore, Defendants’ representations as described in Paragraph 53 constitute 

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

Count III 

Misrepresentations Regarding Fees and Add-Ons 

(by Plaintiff FTC against all Defendants) 

62. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants 

represent, directly or indirectly, expressly or by implication, that consumers are required to pay 

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certain fees or charges, such as for inspecting, reconditioning, certifying vehicles, or add-ons, to 

purchase, lease, or finance vehicles. 

63. Defendants’ representations as described in Paragraph 56 are false or misleading 

or were not substantiated at the time the representations were made. 

64. Therefore, Defendants’ representations as described in Paragraph 56 constitute 

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

Count IV 

Misrepresentations Regarding Authorization of Charges 

(by Plaintiff FTC against all Defendants) 

65. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants 

represent, directly or indirectly, expressly or by implication, that charges appearing on 

consumers’ sales or lease contracts are authorized by consumers. 

66. Defendants’ representations as described in Paragraph 59 are false or misleading 

or were not substantiated at the time the representations were made. 

67. Therefore, Defendants’ representations as described in Paragraph 59 constitute 

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

Count V 

Misrepresentations Regarding State Registration and Other Fees 

(by Plaintiff FTC against Defendants Chase Nissan, Dibre, Soboh, Hamadi, and Alkhatib) 

68. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants 

represent, directly or indirectly, expressly or by implication, that registration and other state fees 

cost a particular amount. 

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69. Defendants’ representations as described in Paragraph 62 are false or misleading 

or were not substantiated at the time the representations were made. 

70. Therefore, Defendants’ representations as described in Paragraph 62 constitute 

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

Count VI 

Unauthorized Charges 

(by Plaintiff FTC against all Defendants) 

71. In numerous instances, Defendants charge consumers without obtaining 

consumers’ express informed consent. 

72. Defendants’ acts or practices cause or are likely to cause substantial injury to 

consumers that consumers cannot reasonably avoid themselves and that is not outweighed by 

countervailing benefits to consumers or competition. 

73. Therefore, Defendants’ acts or practices as described in Paragraph 65 constitute 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), (n). 

Count VII 

Misrepresentations Regarding Advertised Prices 

(by Plaintiff State of Connecticut against Defendants Chase Nissan, Dibre, Soboh, 

and Hamadi) 

74. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or 

indirectly, expressly or by implication, that Defendants will sell particular vehicles at specific 

prices. 

75. In truth and in fact, the Defendants do not sell those particular vehicles at the 

specific represented prices. 

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76. Defendants’ acts and practices, as described herein, were likely to mislead 

consumers acting reasonably under the circumstances into believing that the Defendants’ 

representations concerning the specific price at which they would sell a vehicle were true and 

accurate. 

77. Defendants’ representations as set forth in paragraph 68 of this Count were 

material to consumers’ decisions about whether or not to purchase a vehicle from the 

Defendants. 

78. Defendants have therefore engaged in unfair or deceptive acts and practices in 

violation of Conn. Gen. Stat. § 42-110b(a). 

Count VIII 

Misrepresentations Regarding Certification 

(by Plaintiff State of Connecticut against all Defendants) 

79. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or 

indirectly, expressly or by implication, that Defendants will sell consumers a certified used 

vehicle with a limited manufacturer warranty. 

80. In truth and in fact, the Defendants did not sell those particular vehicles with a 

limited manufacturer warranty. 

81. Defendants’ acts and practices, as described herein, were likely to mislead 

consumers acting reasonably under the circumstances into believing that the Defendants’ 

representations concerning the inclusion of a limited manufacturer warranty were true and 

accurate. 

20 
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 21 of 29 

82. Defendants’ representations as set forth in paragraph 73 of this Count were 

material to consumers’ decisions about whether or not to purchase a vehicle from the 

Defendants. 

83. Defendants have therefore engaged in unfair or deceptive acts and practices in 

violation of Conn. Gen. Stat. § 42-110b(a). 

Count IX 

Misrepresentations Regarding Fees and Add-Ons 

(by Plaintiff State of Connecticut against all Defendants) 

84. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or 

indirectly, expressly or by implication, that consumers are required to pay certain fees, such as 

for inspecting, reconditioning, or certifying vehicles, or to buy certain add-ons to purchase, lease, 

or finance certified vehicles. 

85. In truth and in fact, consumers were not required to pay certain fees, such as for 

inspecting, reconditioning, or certifying vehicles, or to buy certain add-ons to purchase, lease, or 

finance certified vehicles. 

86. Defendants’ acts and practices, as described herein, were likely to mislead 

consumers acting reasonably under the circumstances into believing that the Defendants’ 

representations concerning the payment of such fees and the purchase of such add-ons to 

purchase, lease, or finance certified vehicles were true and accurate. 

87. Defendants’ representations as set forth in paragraph 78 of this Count were 

material to consumers’ decisions about whether or not to pay such fees and purchase such addons in connection with a purchase a vehicle from the Defendants. 

21 
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 22 of 29 

88. Defendants have therefore engaged in unfair or deceptive acts and practices in 

violation of Conn. Gen. Stat. § 42-110b(a). 

Count X 

Misrepresentations Regarding Authorization of Charges 

(by Plaintiff State of Connecticut against all Defendants) 

89. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or 

indirectly, expressly or by implication, that charges appearing on sales or lease contracts were 

authorized by consumers. 

90. In truth and in fact, consumers did not authorize the charges on sales or lease 

contracts. 

91. Defendants’ acts and practices, as described herein, were likely to mislead 

consumers acting reasonably under the circumstances into believing that certain charges on sales 

and lease contracts were mandatory and Defendants’ representations that such charges were 

mandatory were true and accurate. 

92. Defendants’ representations as set forth in paragraph 83 of this Count were 

material to consumers’ decisions about whether or not to authorize such charges in connection 

with a purchase of a vehicle from the Defendants. 

93. Defendants have therefore engaged in unfair or deceptive acts and practices in 

violation of Conn. Gen. Stat. § 42-110b(a). 

Count XI 

Misrepresentations Regarding Authorization of Charges 

(by Plaintiff State of Connecticut against Defendants Chase Nissan, Dibre, Soboh, Hamadi, 

and Alkhatib) 

22 
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 23 of 29 

94. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or 

indirectly, expressly or by implication, that registration and other state fees cost a particular 

amount and charged consumers that amount. 

95. In truth and in fact, Defendants’ representations as to registration and other state 

fees were inaccurate and inflated and Defendants collected funds from consumers exceeding 

what was required by the state. 

96. Defendants’ acts and practices, as described herein, were likely to mislead 

consumers acting reasonably under the circumstances into believing that the amounts Defendants 

collected from consumers to pay certain registration and state fees were true and accurate. 

97. Defendants’ representations as set forth in paragraph 88 of this Count were 

material to consumers’ decisions about whether or not to purchase a vehicle from the 

Defendants. 

98. Defendants have therefore engaged in unfair or deceptive acts and practices in 

violation of Conn. Gen. Stat. § 42-110b(a). 

Count XII 

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-18) 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

99. The allegations of Paragraphs 73 of Count VIII are incorporated by reference as 

Paragraph 93 of Count XII as if fully set forth herein. 

100. Defendant Chase Nissan’s acts and practices violate § 42-110b-18(c) of the 

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it 

23 
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 24 of 29 

misrepresented that the motor vehicles it offered for sale are “Nissan Certified.” In truth and in 

fact, Defendant Chase Nissan’s representations were false. 

101. Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and 

practices in violation of Conn. Gen. Stat. § 42-110b(a). 

Count XIII 

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-22) 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

102. The allegations of Paragraphs 63, 73, and 78 of Counts VII, VIII, and IX are 

incorporated by reference as Paragraph 96 of Count XIII as if fully set forth herein. 

103. Defendant Chase Nissan’s acts and practices violate § 42-110b-22 of the 

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it 

failed to conspicuously state all material contingencies, conditions, and limitations on its offer to 

sell motor vehicles at the advertised price. 

104. Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and 

practices in violation of Conn. Gen. Stat. § 42-110b(a). 

Count XIV 

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(1)) 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

105. The allegations of Paragraphs 63, 73, and 78 of Counts VII, VIII, and IX are 

incorporated by reference as Paragraph 99 of Count XIV as if fully set forth herein. 

106. Defendant Chase Nissan’s acts and practices violate § 42-110b-28(1) of the 

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it 

failed to sell motor vehicles to consumers in accordance with the terms and conditions it had 

advertised, including the advertised price. 

24 
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 25 of 29 

107. Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and 

practices in violation of Conn. Gen. Stat. § 42-110b(a). 

Count XV 

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(6)) 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

108. The allegations of Paragraphs 63, 73, and 78 of Counts VII, VIII, and IX are 

incorporated by reference as Paragraph 102 of Count XV as if fully set forth herein. 

109. Defendant Chase Nissan’s acts and practices violate § 42-110b-28(6) of the 

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it 

advertised prices for the sale of motor vehicles without including in those prices numerous fees 

and charges that it later represented to consumers were required to be paid in connection with the 

sale. 

110. Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and 

practices in violation of Conn. Gen. Stat. § 42-110b(a). 

Count XVI 

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(17)) 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

111. The allegations of Paragraphs 63, 73, and 78 of Counts VII, VIII, and IX are 

incorporated by reference as Paragraph 105 of Count XVI has if fully set forth herein. 

112. Defendant Chase Nissan’s acts and practices violate § 42-110b-28(17) of the 

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it 

made representations or statements of fact in an advertisement when it knew or should have 

known that the representations or statements were false or misleading. 

25 
 

Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 26 of 29 

113. Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and 

practices in violation of Conn. Gen. Stat. § 42-110b(a). 

Count XVII 

Civil Penalties 

(by Plaintiff State of Connecticut against Defendant Chase Nissan) 

114. The allegations of Paragraphs 63, 73, 78, 83, 93, 96, 99, 102, and 105 of Counts 

VII through XVI are incorporated by reference as Paragraph 108 of Count XVII as if fully set 

forth herein. 

115. Defendants engaged in the acts and practices alleged herein when it knew or 

should have known that its conduct was unfair or deceptive, in violation of Conn. Gen. Stat. § 

42-110b(a), and, therefore, is liable for civil penalties of up to $5,000 per willful violation 

pursuant to Conn. Gen. Stat. § 42-110o(b). 

CONSUMER INJURY 

116. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act and CUTPA. Absent injunctive relief 

by this Court, Defendants are likely to continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF

 Wherefore, Plaintiffs requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC Act and 

CUTPA by Defendants; 

B. Award such relief as the Court finds necessary to redress injury to consumers 

resulting from Defendants’ violations of CUTPA, including, but not limited to, rescission or 

26 
 

 

 

 

 

 

 

 

 

 

 

Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 27 of 29 

reformation of contracts, restitution, the refund of monies paid, civil penalties and the 

disgorgement of ill-gotten monies; 

C. Award the State of Connecticut its attorneys’ fees; 

D. Award the State of Connecticut the costs of bringing this action; and 

E. Award any additional relief as the Court determines to be just and proper.

 Respectfully submitted,

 Jonathan J. Blake (Juris no. ct22321) 

 Michael Nunes (Juris no. ct31522) 

Assistant Attorneys General 

 Office of the Attorney General 

 165 Capitol Avenue 

 Hartford, CT 06106 

 Phone: 860-808-5400 

 Fax: 808-808-5593 

Jonathan.blake@ct.gov 

Michael.nunes@ct.gov 

27 

Dated: ____________________ __________________________ 

 Samuel Jacobson 

 Edward Smith

 Federal Trade Commission

 600 Pennsylvania Ave., NW 

 Mail Stop CC-10232 

 Washington, DC 20580 

 Phone: (202) 876-5590 (Jacobson) 

 Fax: (202) 326-3768 

sjacobson@ftc.gov 

esmith2@ftc.gov 

 Attorneys for Plaintiff

 FEDERAL TRADE COMMISSION 

WILLIAM TONG

 ATTORNEY GENERAL 

Dated: ____________________ ________________________________________ 

01/02/2024 /s/ Samuel Jacobson

01/02/2024 /s/ Jonathan J. Blake
Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 28 of 29 

ATTACHMENT A 
Hu111t:: Sμt::uals Now Vt I 11clt::s N1ss.11 Mut.lt::ls P1 to-Ovv11t::t.l Vt::I 11Llt::s C,il1f1t::t.l 'vt::I 11clts f 11Ia11u11y Se1V1ct:: & Pc11 ls AI.Juu. \f\;e: Buv Cais 

D. Manchester City Nissan 

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Cars wth Nav,gabon 

m Enl3r~e Photos (35) 

Q. 

2021 Nissan Rogue S SUV 

Stock #PC679674A t 2 other people ir.feresiea in fhio vehcle 

(!) '335 v;ews 

$26,000 

YJur Price 

0 Nissan Certified 

0 Low Mileage 

0 Carfax 1 ONner 

CJ Bluetooth Connectivity 

® Back-up Camera * Fuel Efficient 

tai\GETPRE 

~ APPROVED 

Q SCHEDULE MY 

~ TEST DRIVE 

f"',._ 

N ISSAN 

"'-/. Certified Pre-owned -

Fuel Efficiency Rating Get More Info 

City MPG 

26 i High""ay MPG 33 \. Call (860) 640-4514 

Bc:t~t:nl ur 2(21 EPA111ilt:!'OYt:l' 1cdi11y~. U~t:l' ·ur tUfflfJc:lli~UII fJUlfJU~:::~ Ufll)'. YLur 111ilt:!'c:IYt:l' 

V+'ill ,·arydeoendirg on driving conditions how you jri've and 'l'la ntain 'yOUrvehicl~, batteryp~cl< ~gc/cond tion (if ~pplic::iblc), ~nd other :~ctorc. 

'✓eh1cle Spec1f1ca-ions Veh cle Features 

Type: Pre Owred 

M.1ke: l\lissan J,1odol: Rogu, 

Trm: S Doers: 4C Sport Utilit) 

Exterior: Super 8 ack Interior. Charcoal 

!':tnr.k N ,m- P~R7CJR7 4A 

M leage: 1(.476 Fuel E :onomy: 26133 

Engine: 2.5L 14 0JHC 16V -ransmission: CVTwilh )itro1ic 

Fuel: Goso ine 0ri"8: A\1110 

MJdel Code: 220'1 

,L\)OUI 

'7" AluminumAlloyWheels 

4-Vlfheel Disc Brakes 

ABS brakes 

AM/FM ~adio 

APFLE CAR-Pl.fl( &A.NDR0I0AUTO 

BACK UP CAMERA 

Olack Cplash Cuards (Cet of 4:, 

Brake ass st 

CLEAN Cfl.RF.WNOA.CCIDENTS 

REPORTED 

Delay-off headlig1ts 

Dri"8r ,anily mirror 

Duel front ,ide impact airbags 

fULLYDETAILE0 

Fuu, Wht::t:!1 i11Jt:!p:::111Jt:ml ~U~fJ::l'U::iuf 

rront CenterP.rm·es: 

F'ront read ng lights 

llluninated entry 

LOCAL TRAD:: 

J~IS3AN FACTORY CERTIFIEC 

Occupant sensing a rbog 

Overhead 3irtag 

Panic e1arm 

P a55enger vanify mirro, 

ro\Ner steering 

REMAll~DER :)F FACTCRYWARRAI\ TY 

Reor seat eerier armrest 

Reor >MndJw def•os:er 

Renote keyless 3nt1Y 

Speed-Sensitive .Nipers 

spoiler 

-ac.horneter 

-m ctccring v...hccl 

-rip C'omputer 

II Speakers 

5.604 Me RatiJ 

ALL l'VH::EL DRIV:: 

Al>IIF"1 radio 

Air CJncitioninJ 

Auto High-beam f-eadlights 

B_UETQOTHIHAI\DS FREE•CELL 

p;Q\IE 

O ind Gpot Wamin;J 

8Jmoer;: bod\·-color 

Clott Seat-rim 

Driver door bin 

Dual front impact airbags 

E ec1ronic Sta bi lily Control 

FirsrnidKit 

F1u11I Bu..:kt:I St:!'e!l~ 

rron1 anti-roll bar 

Fully automatic headl gh1s 

Low :ire pressure ...vamina 

ONE OV'/NER 

Outs de temperature jisplar 

o,erhead cJnsole 

P3ssengerdooroIn 

PJwer door mi Tors 

rJwerwindows 

RadiJ data system 

Rear sice impact airbag 

Rearwindo,v v<iper 

Sleed cont·ol 

Sllit folcing rear seat 

s:ee11ngwreeI mounted audio comro s 

Tele~c.oping 5t~erngwh~el 

Troction control 

Vari~bly interm ttent \A.oiper~ 

=Advertised price on all Certified Nissans include NE MAC Captive Finance Rebate=, Ro~ue S, 40 Sport Utility, 2,5l U OOHC 16V, CVT with Xtronic, AWO, 

Super Black, Charcoal Cloth. 

At lilanchester City Nissan we want you to know that all our vehicles are priced at a competitive value position to the market We use an independent 3rd 

party software to research internet listings on all vehicles in the market so we can ensure that our prices are the most competitive out there, We do this 

simply so people choose us when they start searching for their next car, 

Priced below KBB Fair Purchase Price! 

Clean CARFAlt CARFAX One-Owner, 

r.P.rtifiP.rl. Ni ..... an r.P.rtifiP.rl OP.t,.il,;: 

• 167 Point ln~pection 

• Tran.terable Warranty 

= Plus 1 Year Pre Paid Maintenance Included. 

• Vehicle History 

• limited Warranty: 8~ Montb/100,000 Mile (whichever comes fin:t) from original in seovice date 

• Warranty Deductible: $100 

= Roadside Assistance 

Our Soles, Service ~nd Parts Oep~rtenenb work closelv together to provide you with 1he most enjoyable, le~st ,1ressful car-buying experience possible. 11,e 

overage tenure for our soles people, m~nogers, technicians oud all o1her employees is over 20 ye ors. Most of them hove been career employees of 

Mc:111t.:htt~tu Cily ru~c:10 - c:imt with thc:it rnud1 ttXfJttlittru.:tt, yuu t.:c:10 b~ su1tt th~y•H fJ•uvht~ yuu with thtt hiyhtt1i,t quc:11ity t.:c:111:t ru, yuu ~md yuu1 vtthit.:ltt. Wt! c:111:t 

also proud to be a Bener Business Bureau Accredited Business with an A• rating, 

Similar Vehicles 

~021 Ni~~:m Ruyut:! 2021 Ni~~(:UI Ruyut:! 2021 Ni~~cm Ruyu::! 

2021 Nissan Rogue 

Recently Viewed Vehicles 

20,2 Nissan Frontier ,021 Niss3n Rogue 

Check Safety Recall Statu, 

Case 3:24-cv-00012 Document 1 Filed 01/04/24 Page 29 of 29 

Web Data Collection Report

Page Title

Pre-Owned Nissan Rogue in Manchester CT | PC679674A

URL

https://manchestercitynissan.com/vehicles/2021-nissan-rogue-s-pc679674a-5n1at3abxmc831101

Collection Date

Tue Apr 11 2023 10:55:48 GMT-0400 (Eastern Daylight Time)

Browser Information

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