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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO.: 0:22cv60779

UNITED STATES OF AMERICA,

Plaintiff,

v.

FUNERAL & CREMATION GROUP OF 

NORTH AMERICA, LLC, a Delaware 

limited liability company,

LEGACY CREMATION SERVICES, LLC,

also d/b/a LEGACY FUNERAL 

SERVICES, HERITAGE CREMATION 

PROVIDER, EVERGREEN FUNERAL 

HOME AND CREMATORY, and 

CAROLINA CENTRAL CREMATORY, a 

Colorado limited liability company, and

ANTHONY JOSEPH DAMIANO, a/k/a AJ 

DAMIANO, AJ STYLES, or AJ 

MAHONEY, individually and as an officer

of FUNERAL & CREMATION GROUP OF 

NORTH AMERICA, LLC; and 

LEGACY CREMATION SERVICES, LLC,

Defendants.

COMPLAINT FOR PERMANENT INJUNCTION,

CIVIL PENALTIES, MONETARY RELIEF AND OTHER RELIEF

(DEMAND FOR JURY TRIAL)

Plaintiff, the United States of America, by its undersigned attorneys, acting upon 

notification and authorization to the Attorney General by the Federal Trade Commission (“FTC”

or the “Commission”) pursuant to Section 16(a)(1) of the Federal Trade Commission Act (“FTC 

Act”), 15 U.S.C. § 56(a)(1), for its Complaint alleges:

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1. Plaintiff brings this action under Sections 5(m)(1)(A), 13(b) and 19 of the Federal 

Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(m)(1)(A), 53(b), 56(a), 57b, and the 

Commission’s Trade Regulation Rule Concerning Funeral Industry Practices (“Funeral Rule”), 

16 C.F.R. Part 453, to obtain permanent injunctive relief, monetary relief, and other relief for 

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

the Funeral Rule in connection with the marketing and sale of funeral goods and services.

SUMMARY

2. Defendants hold themselves out to be local funeral homes providing low cost 

cremation services to consumers throughout the United States. 

3. In truth, Defendants do not operate local crematories and do not conduct 

cremations. Defendants deal directly with consumers, offer services, and set prices. Then 

Defendants arrange for third-party cremation providers and funeral homes to perform the 

cremation services. 

4. In numerous instances, Defendants represent lower prices for their cremation 

services than the final price Defendants ultimately require consumers to pay, which includes 

additional undisclosed charges. 

5. In numerous instances, the services Defendants arrange are not located close to 

bereaved consumers as advertised, and thus Defendants force those consumers to travel long 

distances for viewings and to obtain the remains of loved ones. 

6. In some instances when consumers contest Defendants’ charges, Defendants 

threaten not to return or actually refuse to return their loved one’s remains until the consumers 

pay. 

JURISDICTION AND VENUE

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

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and 1345.

8. Venue is proper in this District under 28 U.S.C. § 1391(b)(2), (b)(3), (c)(1), 

(c)(2), and (d), and 15 U.S.C. § 53(b).

DEFENDANTS

9. Defendant Funeral & Cremation Group of North America, LLC (“Funeral & 

Cremation”) is a Delaware limited liability company with its principal place of business at 2124 

Crown Center Drive, Charlotte, NC 28227. Funeral & Cremation transacts or has transacted 

business in this District and throughout the United States. Funeral & Cremation serves as the 

holding company for Legacy Cremation Services, LLC (collectively, “Corporate Defendants”).

Defendant Anthony Joseph Damiano (“Damiano”) is the principal and sole member of Funeral 

& Cremation. At all times relevant to this Complaint, acting alone or in concert with others,

Funeral & Cremation has advertised, marketed, distributed, offered to sell, or sold funeral goods 

and services to consumers throughout the United States.

10. Defendant Legacy Cremation Services, LLC (“Legacy”), also doing business as 

Legacy Funeral Services, Heritage Cremation Provider, Evergreen Funeral Home and 

Crematory, and Carolina Central Crematory, is a Colorado limited liability company with its 

principal places of business as 9800 Mount Pyramid Court, Denver, CO 80112, and 2124 Crown 

Center Drive, Charlotte, NC 28227. Legacy 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, Legacy has advertised, marketed, distributed, offered to sell, or sold funeral 

goods and services to consumers throughout the United States.

11. Defendant Anthony Joseph Damiano, also known AJ Damiano, AJ Styles, or AJ 

Mahoney, is the sole member of Legacy and Funeral & Cremation. At all times relevant to this 

Complaint, acting alone or in concert with others, he has formulated, directed, controlled, had the 

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authority to control, or participated in the acts and practices of Corporate Defendants, including 

the acts and practices set forth in this Complaint. Damiano is solely responsible for managing 

Corporate Defendants, supervising and assigning duties to employees, and approving content for 

Corporate Defendants’ websites. Damiano has, on behalf of Corporate Defendants, responded to 

complaints from regulators, law enforcement agencies, and consumers. Damiano regularly 

communicates with Corporate Defendants’ customers and prospective customers about the

Corporate Defendants’ location, goods and services, and prices. Damiano 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.

COMMON ENTERPRISE

12. Corporate Defendants have operated as a common enterprise while engaging in 

the deceptive, unfair, and unlawful acts and practices and other violations of law alleged below.

Corporate Defendants have conducted the business practices described below through 

interrelated companies that have common ownership, that engage in regular transfer of revenue 

between the common enterprise members, share mailing addresses, and share business functions. 

Because these Corporate Defendants have operated as a common enterprise, each of them is 

liable for the acts and practices alleged below.

COMMERCE

13. At all times material 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.

THE FTC ACT

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

or practices in or affecting commerce.”

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15. Misrepresentations of material facts constitute deceptive acts or practices 

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

16. 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).

THE FUNERAL RULE

17. The Funeral Rule, promulgated by the Commission under Section 18 of

the FTC Act, 15 U.S.C. § 57a, became effective in its entirety on April 30, 1984, and

since that date has remained in full force and effect. Amendments to the Funeral Rule

were promulgated by the Commission under Section 18 of the FTC Act, 15 U.S.C. 

§ 57a, and became effective on July 19, 1994. The Funeral Rule is codified at 16 C.F.R.

Part 453.

18. Defendants are “funeral providers,” as that term is defined in Section 453.l(i) 

of the Funeral Rule, 16 C.F.R. § 453.l(i), and sell or offer to sell “funeral goods” and “funeral 

services,” as those terms are defined in Sections 453.l(h) and 453.l(j) of the Funeral Rule, 16 

C.F.R. §§ 453.l(h) and 453.l(j).

19. The Funeral Rule requires funeral providers to provide accurate price information 

and other readily available information that reasonably answers the questions of consumers who 

ask by telephone about the funeral providers’ offerings and prices. 16 C.F.R. § 453.2(b)(1). 

20. The Funeral Rule further requires funeral providers to provide consumers with 

statements of funeral goods and services at the conclusion of the discussion of arrangements that 

include an itemized written list of the funeral goods and services selected and the prices to be 

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paid for each of them, including any cash advance items, and the total cost of the goods and 

services selected by the consumer. 16 C.F.R. § 453.2(b)(5)(i)(A)-(C).

21. The Funeral Rule requires funeral providers to place the following disclosure in 

the itemized statement of funeral goods and services selected, in immediate conjunction with the 

list of itemized cash advance items required by § 453.2(b)(5)(i)(B): “We charge you for our 

services in obtaining: (specify cash advance items),” if the funeral provider makes a charge upon, 

or receives and retains a rebate, commission or trade or volume discount upon a cash advance 

item. 16 C.F.R. § 453.3(f)(2).

22. Pursuant to Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of 

the Funeral Rule constitutes an unfair or deceptive act or practice in violation of Section 5(a)(l) 

of the FTC Act, 15 U.S.C. § 45(a)(l).

23. Section 5(m)(l)(A) of the FTC Act, 15 U.S.C. § 45(m)(l)(A), authorizes this Court 

to award monetary civil penalties of not more than $43,792 for each violation of the Funeral 

Rule.

24. Each instance in which Defendants have failed to comply with the Funeral Rule, 

16 C.F.R. Part 453, constitutes a separate violation of the Funeral Rule for the purpose of 

assessing monetary civil penalties.

DEFENDANTS’ BUSINESS ACTIVITIES

Defendants’ Misrepresentations about Location

25. Defendants market their services online through two websites: 

www.legacycremationservices.com (“Legacy Website”) and 

www.heritagecremationprovider.com (“Heritage Website”). Damiano owns both websites and 

controls their content. 

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26. Numerous bereaved consumers seek cremation services in the deceased’s 

community so that the family and friends of the deceased can attend memorial services or 

viewings without traveling long distances. 

27. Defendants have optimized the Legacy Website and Heritage Website such that, 

in numerous cases, when consumers query an online search engine for local or affordable 

cremation services, Defendants’ websites appear at or near the top of search results for such 

providers. By doing so, Defendants represent that they provide local crematory services, even 

though Defendants do not own or operate any crematories, and in many cases ultimately do not 

arrange for services in the searched location.

28. Defendants have configured the websites to prominently display the name of the

city or town for which the consumer searched. For example, if a consumer searches for 

cremation services in Abbeville, Alabama and clicks on an optimized link in the search engine 

results, they arrive at a landing page titled “Trusted Cremation Services in Abbeville” that offers 

“compassionate community service close to home.”

Figure 1: Screen capture of Heritage Website landing page for Abbeville, AL. 

29. The Heritage Website does not inform consumers that Legacy, doing business as

Heritage, is not a local crematory or funeral home, and that if consumers engage Legacy’s

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services, Legacy will attempt to locate a provider in the relevant area to perform the cremation 

services.

30. If consumers click on the Legacy Website link for Abbeville, AL Cremation 

Services, they arrive at a landing page titled “Abbeville, AL Cremation Services.”

Figure 2: Screen capture of Legacy Website landing page for Abbeville, AL. 

31. The landing page includes information about the cremation and other funeral 

services available. The phone number for Legacy appears at the top of the page. After scrolling 

past services available, consumers are shown information about cremation services that has been 

optimized to repeat the name of the location searched for by the consumer.

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Figure 3: Screen capture of Legacy Website landing page for Abbeville, AL.

32. The Legacy Website states, at the bottom of the landing page, in small, light 

purple font on a dark purple background:

Legacy Funeral Services license number (FH-706) has a national network of 

locally-licensed funeral and cremation providers for final funeral and cremation 

services, which includes hand selected independently owned and locally operated 

licensed funeral and crematory establishments.

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Figure 4: Screen capture of Legacy Website landing page for Abbeville, AL. 

33. This unclear and inconspicuous statement is the only information on the Legacy 

Website that suggests that Defendants are not themselves a local crematory. It is not in close 

proximity to the prominent representations that Defendants are a local crematory and is 

positioned below optimized location information. 

34. To make cremation arrangements, consumers call Defendants using the telephone 

numbers on Defendants’ websites, or they complete the contact forms on Defendants’ websites 

and Defendants call them. 

35. When consumers ask Defendants whether they are a local crematory, in many 

instances Defendants tell consumers that they are a local crematory or they work with 

crematories in the town where consumers are seeking services. 

36. In fact, Defendants do not own or operate any crematories and always engage 

with third-party cremation providers with which Defendants do not maintain any contracts.

37. In numerous instances, consumers try to locate Defendants’ local crematory, often 

after their loved one’s remains have been taken into care by a third-party service provider hired 

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by Defendants. Consumers learn that—contrary to the representations Defendants make on their 

websites and during telephone calls and in emails with consumers—there is no local crematory 

named “Legacy” or “Heritage.” Upon learning that their loved ones’ remains are not in the 

location Defendants represented, bereaved consumers wishing to have viewings or memorial 

services must travel sometimes more than an hour to the third-party cremation providers’ 

location.

38. Likewise, consumers who want to pick up their loved ones’ cremated remains 

must travel sometimes more than an hour to retrieve them or agree to have the cremated remains

mailed. 

39. In numerous instances, when asked by consumers who are looking for the 

location of the crematory, Defendants refuse to disclose the name and location of the third-party 

cremation provider. 

40. Defendants’ customer service scripts direct employees not to provide the name 

and location of the third-party cremation provider until after consumers have paid.

41. Defendants have refused to disclose the location of third-party crematories 

holding remains. 

Defendants’ Misrepresentations About Price

42. Defendants make representations about the price of cremation services that are 

false and misleading.

43. The Legacy Website lists the price for cremations “[f]rom $695” and states that 

Defendants’ “Cremation Packages Include,” among other things, the “death certificate,”

“[t]ransportation of the deceased to the crematory,” and an “[a]lternative container.” Consumers 

rarely, if ever, receive cremation services from Defendants for $695. In nearly all instances, 

Defendants mark up the cost for cremation, and add numerous additional fees to the price of 

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cremation services.

44. The Legacy Website does not include any disclosures about additional fees or 

items not included in the Cremation Package.

45. The Heritage Website lists the price for cremations as “[o]nly $695 - $1395,” and 

states that cremation services include “[t]ransportation of the deceased to the crematory,” 

“[o]btaining certified copies of death certificate [sic],” “[a]ssistance in filing for VA & Social 

Security Benefits,” and “[r]igid container (for return of the cremated remains).” 

46. Below the price, the Heritage Website includes a confusing statement regarding 

additional expenses such as cash advance items, state fees for permits, certified copies of death 

certificates, alternative cremation container, sales tax, and newspaper charges. However, this 

unclear disclosure is in direct conflict with the representation immediately preceding it, which 

lists death certificates as a part of the cremation services included in the package price. 

Moreover, it is unlikely that consumers are aware that these additional items will add hundreds 

of dollars to the package price advertised online. 

47. During initial phone calls with consumers seeking cremation services, Defendants 

rarely, if ever, offer cremation packages at the $695 low end of the price range advertised online. 

Instead, the prices quoted for cremation packages on the telephone or in emails responding to 

consumer inquiries are generally at least $300 more, often around $995. 

48. Even the higher prices quoted for cremation packages are often false and later 

increased, often exceeding $1,395, the top end of the price range listed on the Heritage Website.

49. In numerous instances, Defendants tell consumers that the price quoted on the 

telephone includes all goods and services when they know that is often not the case.

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50. In numerous instances, Defendants charge consumers additional fees Defendants 

have not previously disclosed for goods and services such as death certificates, death certificate 

filing fees, county permits, heavy duty vinyl pouches, or alternative containers, despite 

Defendants’ representations that these items are included in the service packages. Consumers 

have been charged up to $600 in excess of the prices quoted over the telephone.

51. Even when Defendants disclose some of the additional fees—for example 

additional fees for multiple death certificates, county permits, or urns—Defendants do not 

disclose all fees, and charge consumers significant fees for other items such as alternative 

containers. 

52. After consumers agree over the phone to purchase cremation services from 

Defendants, and after consumers have filled out extensive paperwork, Defendants email 

consumers price statements titled “Statement of Funeral Goods and Services Selected/Purchase 

Agreement” (“Statement”). The Statements include itemized prices for the arranged cremation 

goods and services. 

53. In some instances, Defendants do not send the Statements to consumers until after 

the third-party cremation providers have picked up the deceased.

54. The prices listed on the Statements are often several hundred dollars higher than 

the price Defendants told consumers over the telephone. 

55. Defendants mark up the cost for most services provided by the third-party 

cremation providers, including services identified on the Statement as “cash advance items.” 

Defendants do not disclose on the Statement that they are charging customers more than their

cost for the cash advance items. 

56. In some instances, consumers receive more than one Statement from Defendants, 

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with subsequent Statements including additional or increased costs that were not identified by 

Defendants over the telephone or in prior Statements.

57. In other instances, after sending the Statement, Defendants send consumers 

additional emails or tell consumers over the telephone that there will be additional, undisclosed 

fees for goods or services that Defendants previously led consumers to believe were included in 

the quoted cremation package prices.

Wrongful Withholding of Remains

58. In some instances, when consumers complain to Defendants about the price 

increases, Defendants threaten to withhold or actually withhold the cremated remains from the 

consumers unless and until they pay the new, higher prices. 

59. Some consumers pay the higher prices because they know of no other option to 

recover the remains.

60. Some consumers affected by Defendants’ withholding of remains identify the 

third-party cremation providers and arrange to pick up the remains without paying the higher 

prices. However, in some of these instances, Defendants withhold the death certificates 

requested by the consumers. 

61. Some consumers try to cancel the arrangements with Defendants to avoid paying 

Defendants’ price increases. In some such cases, Defendants charge consumers hundreds of 

dollars to transfer remains to a different funeral home or crematory. 

Prior Proceedings or Activities That Challenged Defendants’ Conduct

62. Between 2014 and 2021, at least ten state attorneys general and state funeral 

licensing boards notified Defendants Damiano, Legacy, or both of their improper marketing and 

sales tactics, including Defendants’ misrepresentations about being locally licensed funeral 

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homes, providing funeral services without a state license, and other misstatements of material 

facts in the marketing and sale of funeral goods and services.

63. Some states, including Florida (2019), North Carolina (2016), Pennsylvania 

(2020), Tennessee (2014), Texas (2021), and Vermont (2020), have ordered Defendants

Damiano and/or Legacy to cease and desist offering funeral goods and services in their states

because Defendants do not hold a valid license to provide those goods and services. 

64. Defendants Damiano and Legacy entered into an Assurance of Voluntary 

Compliance with the Georgia Attorney General in 2017, requiring them to cease and desist 

holding themselves out as a Georgia funeral service provider. Defendants Damiano and Legacy 

acknowledged receipt, awareness, and understanding of the Funeral Rule.

65. Based on the facts and violations of law alleged in this Complaint, Plaintiff has 

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

Commission.

VIOLATIONS OF THE FTC ACT

COUNT I

MISREPRESENTATIONS REGARDING LOCATION AND PRICE AND UNFAIR 

REFUSAL TO RETURN CREMATED REMAINS

66. Paragraphs 1-65 are incorporated as if set forth herein.

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

offering for sale, or sale of funeral goods and services, Defendants represent, directly or 

indirectly, expressly or by implication, that they have a physical location or provide funeral or 

cremation services in the city or town searched for or requested by the consumer.

68. In truth and in fact, in numerous instances in which Defendants have made the 

representations set forth above, Defendants do not have a physical location or provide funeral or 

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cremation services in the city or town searched for or requested by the consumer.

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

offering for sale, or sale of funeral goods and services, Defendants represent directly or 

indirectly, expressly or by implication, that the prices they quote for cremation packages include 

all or substantially all the fees and costs that they will charge consumers for their goods and 

services. 

70. In truth and in fact, in numerous instances in which Defendants have made the 

price representations set forth above, Defendants charge consumers additional costs and fees and 

substantially higher prices for cremation packages than the prices Defendants quoted to 

consumers.

71. In numerous instances, Defendants have misrepresented prices for cremation 

packages, adding costs and fees to substantially raise the prices. In some such instances, 

Defendants have refused to return remains to consumers, threatened that they will not return the 

remains, or withheld information about the location of the remains until the consumers pay the 

increased prices Defendants demand.

72. Defendants’ actions cause or are likely to cause substantial injury to consumers 

that consumers cannot reasonably avoid and that is not outweighed by countervailing benefits to 

consumers or competition.

73. Therefore, Defendants’ representations as set forth above are false and misleading 

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

§ 45(a), (n). 

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VIOLATIONS OF THE FUNERAL RULE

COUNT II

FAILURE TO PROVIDE ACCURATE PRICE INFORMATION, STATEMENTS OF 

FUNERAL GOODS AND SERVICES THAT INCLUDE THE TOTAL COST, AND 

FAILURE TO INCLUDE CASH ADVANCE DISCLOSURE 

74. Paragraphs 1-65 and 67-73 are incorporated as if set forth herein.

75. In numerous instances, in connection with selling or offering to sell funeral goods 

and funeral services, Defendants have failed to provide accurate price information to consumers 

who asked about the price of funeral goods and services, including cremation services by

telephone, failed to provide consumers with statements of funeral goods and services at the 

conclusion of the discussion of arrangements that included the total cost of the goods and 

services selected by the consumer, and/or failed to provide consumers with statements of funeral 

goods and services that disclosed that the price being charged for cash advance items was not the 

same as the cost to Defendants

76. Defendants’ acts or practices as set forth above violate 16 C.F.R. §§ 453.2(b)(1), 

453.2(b)(5)(i)(C), and 453.3(f)(1)(ii). 

77. Each instance in which Defendants have failed to comply with the Funeral Rule, 

16 C.F.R. Part 453, constitutes a separate violation of the Funeral Rule for the purpose of 

assessing monetary civil penalties.

78. Proposed defendants were aware of their obligations under the Funeral Rule

during the relevant time period. 

CONSUMER INJURY

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

injury as a result of Defendants’ violations of the FTC Act and the Funeral Rule. Absent 

injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust 

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enrichment, and harm the public interest.

DEMAND FOR TRIAL BY JURY

Plaintiff, the United States of America, demands trial by jury.

PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court: 

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

Funeral Rule by Defendants;

B. Award monetary relief and other relief within the Court’s power to grant; 

C. Award civil penalties from Defendants for the violations of the Funeral Rule 

alleged in this Complaint; and

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

Respectfully submitted,

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FOR THE UNITED STATES OF AMERICA

Dated: April 22, 2022

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General, 

Civil Division

U.S. DEPARTMENT OF JUSTICE

GUSTAV W. EYLER

Director, Consumer Protection Branch

________________________________ 

Cody Matthew Herche

Wandaly Fernandez Garcia

Trial Attorney

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, DC 20044 

Phone: 202.532.4223 

Email: cody.m.herche@usdoj.gov

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

______________________________ 

James A. Weinkle 

Florida Bar No. 0710891

Assistant United States Attorney

Email: James.Weinkle@usdoj.gov

Office of the United States Attorney 

Alto Lee Adams Federal Courthouse

101 South U.S. Highway One, Suite 3100 

Fort Pierce, FL 34950 

Telephone: 772-293-0945 (Direct) 

Counsel for United States of America

Counsel for United States of America 

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