1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 1:23-CV-22553

UNITED STATES OF AMERICA,

Plaintiff,

v.

HELLO HELLO MIAMI, LLC, a limited 

liability company,

and

LUIS E. LEON AMARIS a/k/a LUIS LEON, 

individually and as an officer of HELLO 

HELLO MIAMI, LLC,

Defendants.

COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION, MONETARY 

RELIEF, AND OTHER RELIEF AND DEMAND FOR JURY TRIAL

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“FTC” or “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: 

Plaintiff brings this action under Sections 5(a), 5(m)(1)(A), 13(b), 16(a), and 19 of the 

FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), 56(a), and 57b, and Section 6 of the 

Telemarketing and Consumer Fraud and Abuse Prevention Act (the “Telemarketing Act”), 15 

U.S.C. § 6105, to obtain monetary civil penalties, a permanent injunction, and other relief for 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 1 of 13
2

Defendants’ violations of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the FTC’s 

Telemarketing Sales Rule (the “TSR” or “Rule”), as amended, 16 C.F.R. Part 310.

SUMMARY OF CASE

1. Defendants Hello Hello Miami, LLC (“HHM”), and its Chief Executive Officer

and sole shareholder, Luis E. Leon Amaris (“Leon”), provide voice over internet protocol 

(“VoIP”) services to foreign telemarketers that deliver phone calls impersonating Amazon.com, 

Inc. (“Amazon”), calls to persons on the National “Do Not Call” Registry (“DNC Registry” or 

“Registry”), and calls playing a prerecorded message (“robocalls”) to consumers that have not 

consented in violation of the TSR. 

2. Defendants provided substantial assistance or support to the sellers and 

telemarketers despite knowing or consciously avoiding knowing that they were engaged in acts 

or practices that violated the TSR.

JURISDICTION AND VENUE

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

and 1345.

4. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), and 15 U.S.C. 

§ 53(b).

DEFENDANTS

5. Defendant Hello Hello Miami, LLC is a limited liability company with its 

principal place of business at 78 SW 7th Street, Suite 500, Miami, Florida 33130. HHM transacts 

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

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 2 of 13
3

6. Defendant Luis E. Leon Amaris is the CEO of HHM. 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 HHM, including the acts and 

practices set forth in this Complaint. Leon is HHM’s sole employee, sole shareholder, and is 

responsible for compliance, termination of business relationships, and responding to traceback 

requests, i.e., requests regarding the origination of illegal VoIP traffic. Defendant Leon resides at 

an unknown address and, in connection with the matters alleged herein, transacts, or has 

transacted business in this District and throughout the United States.

COMMERCE

7. 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.

THE TELEMARKETING SALES RULE AND 

THE NATIONAL DO NOT CALL REGISTRY

8. Congress directed the FTC to prescribe rules prohibiting abusive and deceptive 

telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101-6108. The 

FTC adopted the original TSR in 1995, extensively amended it in 2003, and amended certain 

provisions thereafter. 16 C.F.R. Part 310. 

9. Among other things, the 2003 amendments to the TSR established a National Do 

Not Call registry, maintained by the FTC, of consumers who do not wish to receive certain types 

of telemarketing calls. Consumers can register their telephone numbers on the Registry without 

charge either through a toll-free telephone call or online at donotcall.gov. 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 3 of 13
4

10. Consumers who receive telemarketing calls to their registered numbers can 

complain of Registry violations the same way they registered, through a toll-free telephone call 

or online at donotcall.gov, or by contacting law enforcement authorities.

11. The TSR defines “telemarketing” as “a plan, program or campaign which is 

conducted to induce the purchase of goods or services or a charitable contribution, by use of one 

or more telephones and which involves more than one interstate telephone call.” 16 C.F.R. 

§ 310.2(gg). 

12. Under the TSR, a “telemarketer” is “any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a customer or donor.” 16 C.F.R. 

§ 310.2(ff). 

13. A “seller” is “any person who, in connection with a telemarketing transaction, 

provides, offers to provide, or arranges for others to provide goods or services to the customer in 

exchange for consideration.” 16 C.F.R. § 310.2(dd). 

14. The FTC allows sellers, telemarketers, and other permitted organizations to access 

the Registry online at telemarketing.donotcall.gov, to pay any required fee(s), and to download 

the numbers not to call. 

15. Under the TSR, an “outbound telephone call” is “a telephone call initiated by a 

telemarketer to induce the purchase of goods or services or to solicit a charitable contribution.”

16 C.F.R. § 310.2(x). 

16. The TSR prohibits sellers and telemarketers from initiating an outbound telephone 

call to a number on the Registry, unless the settler or telemarketer can demonstrate that it has 

obtained the call recipient’s express written agreement to receive such calls from it or can 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 4 of 13
5

demonstrate that it already has an established business relationship with the call recipient. 16 

C.F.R. § 310.4(b)(1)(iii)(B). 

17. The TSR prohibits initiating an outbound telephone call that delivers a 

prerecorded message to induce the purchase of any good or service, unless the telemarketer has 

an express written agreement from the recipient to receive such prerecorded messages from it. 16 

C.F.R. § 310.4(b)(1)(v). Calls delivering prerecorded messages are commonly called “robocalls.” 

18. The TSR also prohibits misrepresenting a seller or telemarketer’s affiliation with 

any person in the sale of goods or services. 16 C.F.R. § 310.3(a)(2)(viii).

19. The TSR further prohibits making false or misleading statements to induce a 

person to pay for goods or services or to induce a charitable contribution. 16 C.F.R. § 

310.3(a)(4).

20. The TSR additionally prohibits failure to disclose the identity of a seller of goods 

or services truthfully, promptly, and in a clear and conspicuous manner to the person receiving 

the call. 16 C.F.R. § 310.4(d)(1).

21. It is a violation of the TSR for any person to provide substantial assistance or 

support to any seller or telemarketer when that person knows or consciously avoids knowing that 

the seller or telemarketer is engaged in any practice that violates Sections 310.3(a), (c) or (d), or 

310.4 of the TSR. 16 C.F.R. § 310.3(b). 

22. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a).

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 5 of 13
6

23. Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and Section 18(d)(3) 

of the FTC Act, 15 U.S.C. § 57a(d)(3), authorize this Court to award monetary civil penalties of 

up to $50,120 for each violation of the TSR assessed after January 11, 2023, including penalties 

whose associated violation predated January 11, 2023.

DEFENDANTS’ UNLAWFUL ACTIVITIES

24. HHM is a nationwide provider of voice over internet protocol (“VoIP”) services, 

i.e., digital calling over the internet. It provides inbound services, outbound calling services, and 

VoIP termination, which is the routing of telephone calls from one provider to the next until the 

call is routed to the recipient. 

25. HHM’s customers are sellers or telemarketers that make outbound calls under the 

TSR. 16 C.F.R. § 310.2(ff), (dd), (x). 

26. The Telecommunications Act defines “information service” as “the offering of a 

capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or 

making available information via telecommunications[.]” 47 U.S.C. § 153(24). 

27. HHM’s interconnected VoIP services “transform[s] information” and/or “mak[es]

available information via telecommunications.” 47 U.S.C. § 153(24). 

28. Therefore, HHM’s VoIP services fit within the meaning of “information service” 

as defined by 47 U.S.C. § 153(24).

29. The Federal Communications Commission (“FCC”) requires VoIP providers to 

register with the FCC and follow certain regulations, such as making 911 calls available and 

protecting customer call records from disclosure. HHM was registered with the FCC as a 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 6 of 13
7

“telecommunications carrier” that offers interstate or international telecommunications services 

or interconnected VoIP services.

HHM’s AMAZON ROBOCALLS

30. In the last few years, the FTC has experienced an uptick in consumer complaints 

reporting business impersonator calls from scammers claiming to be Amazon.

31. From at least October 6, 2021 to February 20, 2022 (the “relevant period”), HHM 

transmitted robocalls from foreign telemarketers to U.S. consumers on the DNC Registry via its 

VoIP interconnection services. Many of these pre-recorded messages impersonated Amazon in 

order to induce consumers to purchase goods or services or provide personal information. 

32. Providing VoIP interconnection services constitutes the provision of substantial 

support and assistance to a telemarketer under the TSR.

33. Specifically, during the relevant period, HHM transmitted approximately

37,811,350 calls in the United States. Of those calls, approximately 52% were to U.S. customers 

on the DNC Registry. Almost 100% of these calls were of a duration of one minute or less. 

Massive volumes of very short calls are a distinct feature of fraudulent robocall campaigns. 

Many of the calls HHM transmitted included a pre-recorded message that stated: (i) the message

was from Amazon and the consumer’s account was on hold and their authorization was needed, 

(ii) the consumer’s Amazon Prime account experienced a suspicious change, or (iii) the

consumer’s Amazon Prime account was about to be renewed.

34. Amazon did not authorize these calls and the foreign telemarketers making these 

calls were not affiliated with Amazon.

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 7 of 13
8

35. Based on the massive volume of calls, their short duration, and their often 

deceptive nature, it should have been clear to Defendants that they were transmitting robocalls 

for which the sellers and telemarketers could not demonstrate, as the TSR requires, that they had 

obtained an express agreement from each call’s recipient to receive calls playing a pre-recorded 

message from that seller or telemarketer. These same factors should have also made clear to 

Defendants that, for calls they transmitted to phone numbers on the National DNC Registry, the 

seller or telemarketer could not demonstrate having obtained an express agreement or having an 

established business relationship with the consumer. 

36. For example, during the relevant period, HHM transmitted calls from at least ten

foreign VoIP providers that transmitted robocalls to consumers in the United States that 

purported to be from Amazon. These calls stated, for example, the following:

Hello. This is Amazon. This call is to authorize a payment of $999. We would 

like to inform you that there is an order placed for iPhone 11 Pro using your 

Amazon account. If you do not authorize this order, please press 1 to talk with 

Amazon specialists to report fraud or else press 2 to authorize.

37. Defendants repeatedly received notice that providers were using their services to 

transmit these types of illegal robocalls. For example, HHM received forty-two traceback 

requests from the USTelecom’s Industry Traceback Group (“ITG”)1between September 2021 

and January 2022 regarding a client, VoIP Tech Solutions (“VoIP Tech”), in India.

38. These traceback requests included a link to an audio recording of each call, and 

stated the following:

As part of traceback conducted by the Industry Traceback Group, your network 

has been identified in the call path for voice traffic that has been deemed suspicious 

and potentially illegal.

1 The ITG is a collaboration of companies across the wireline, wireless, VoIP and cable industries 

that traces and identifies the source of illegal calls. 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 8 of 13
9

39. The traceback requests stated that the calls purported to be for an Amazon 

subscription campaign and informed consumers that their Amazon account would be auto 

renewed for Amazon Prime services.

40. HHM did not suspend VOIP Tech from sending further call traffic on its networks

for three-and-a-half months after it began receiving such traceback requests.

41. Similarly, between December 11, 2021, and January 5, 2022, HHM transmitted 

illegal calls from Zathura IT Solutions (“Zathura IT”), to United States consumers. During that 

same period, HHM received 17 traceback requests from the ITG alerting it to the fraudulent 

nature of Zathura IT’s calls.

42. Despite receipt of these traceback requests, HHM did not suspend Zathura IT 

until January 19, 2022.

43. HHM never suspended at least six providers that transmitted illegal calls using its 

services.

44. On March 22, 2022, the FCC sent a warning letter to HHM stating:

We have determined that Hello Hello Miami, LLC (“Hello Hello Miami”) is 

apparently transmitting illegal robocall traffic on behalf of one or more of its 

clients. You should investigate and, if necessary, cease transmitting such traffic 

immediately and take steps to prevent your network from continuing to be a 

source of apparently illegal robocalls.

45. Despite this warning, HHM continued to transmit illegal call traffic. For example,

although HHM claimed to have suspended one such provider, Invoketel, on January 19, 2022, 

Invoketel continued to transmit traffic on HHM’s networks through May 15, 2022.

46. 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 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 9 of 13
10

Commission because Defendants continued their unlawful acts or practices despite knowledge of 

numerous warnings concerning the unlawful conduct. In addition, Defendants remain in the 

VoIP industry and maintain the means, ability, and incentive to continue their unlawful conduct.

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count I

Assisting and Facilitating Violations of the Telemarketing Sales Rule

47. Defendants provided substantial assistance or support to their customers, who 

were “seller[s]” and/or “telemarketer[s]” engaged in “telemarketing,” as defined by the TSR, 16 

C.F.R. § 310.2. 

48. As set forth above in paragraphs 23 to 47, in numerous instances, in connection 

with telemarketing, HHM’s customers: 

a. Initiated or caused the initiation of outbound telephone calls to telephone numbers 

on the National DNC Registry to induce the purchase of goods or services, in violation of 

16 C.F.R. § 310.4(b)(1)(iii)(B);

b. Initiated or caused the initiation of outbound telephone calls that delivered 

prerecorded messages to induce the purchase of goods or services, in violation of 16 

C.F.R. § 310.4(b)(1)(v);

c. Misrepresented, directly or by implication, in the sale of goods or services, their 

affiliation with, or endorsement or sponsorship by any person, in violation of 16 C.F.R. 

§ 310.3(a)(2)(vii);

d. Made false or misleading statements to induce a person to pay for goods or 

services or to induce a charitable contribution, in violation of 16 C.F.R. § 310.3(a)(4); 

and 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 10 of 13
11

e. Failed to disclose the identity of the seller of the goods or services truthfully, 

promptly, and in a clear and conspicuous manner to the person receiving the call, in 

violation of 16 C.F.R. § 310.4(d)(1).

49. At all relevant times, Defendants knew, or consciously avoided knowing, that 

their customers were making the unlawful calls described in paragraph 34, which violated 

§ 310.4 and § 310.3(a) of the TSR. 

50. Defendants’ substantial assistance and support of TSR violations, as alleged in 

paragraphs 31 to 47, above, violates the TSR, 16 C.F.R. § 310.3(b). 

CONSUMER INJURY

51. Consumers have suffered and will suffer substantial injury as a result of 

Defendants’ violations of the TSR. Defendants’ services facilitated millions of robocalls to 

consumers on the Do Not Call Registry and assisted robocall traffic that impersonated Amazon. 

These actions likely resulted in stolen information and financial loss. Absent injunctive relief by 

this Court, HHM and Leon are likely to continue to injure consumers and harm the public 

interest. 

THIS COURT’S POWER TO GRANT RELIEF

52. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and other ancillary relief to prevent and remedy any violation of any provision of law 

enforced by the FTC. 

53. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as modified by 

Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 1990, 28 U.S.C. § 2461, as 

amended, and as implemented by 16 C.F.R. § 1.98(d), authorizes this Court to award monetary 

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 11 of 13
12

civil penalties of up to $50,120 for each violation of the TSR, 16 C.F.R. § 1.98(d). Defendants’ 

violations of the TSR were committed with the knowledge required by Section 5(m)(1)(A) of the 

FTC Act, 15 U.S.C. § 45(m)(1)(A).

54. This Court, in the exercise of its equitable jurisdiction, may award ancillary relief 

to remedy injury caused by Defendants’ violations of the TSR and the FTC Act.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that this Court, as authorized by Sections 5(a), 

5(m)(1)(A), and 13(b) of the FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), and pursuant to 

its own equitable powers: 

A. Enter judgment against Defendants and in favor of Plaintiff for each violation alleged in 

this complaint; 

B. Award Plaintiff monetary civil penalties from each Defendant for every violation of the 

TSR; 

C. Enter a permanent injunction to prevent future violations of the TSR and the FTC Act by 

Defendants; and 

D. Award Plaintiff the costs of bringing this action, as well as such other and additional 

relief as the Court may determine to be just and proper.

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury of all issues so triable pursuant to Rule 38 of the 

Federal Rules of Civil Procedure.

Respectfully submitted,

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 12 of 13
13

Dated: July 10, 2023

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General JAMES A. WEINKLE

 Assistant United States Attorney

ARUN G. RAO Florida Bar No. 0710891

Deputy Assistant Attorney General Email: James.Weinkle@usdoj.gov

 Office of the United States Attorney

AMANDA N. LISKAMM Southern District of Florida

Director, Consumer Protection Branch Alto Lee Adams Federal Courthouse

 101 South U.S. Highway One, 3100

RACHAEL L. DOUD Fort Pierce, FL 34950

Assistant Director, Consumer Protection Branch Telephone: 772.293.0945 (Direct)

\s\ Rowan L. Reid Counsel for United States of America 

ROWAN L. REID

Special Florida Bar No. A5503062

MEREDITH L. REITER

Trial Attorneys

Department of Justice

Civil Division

Consumer Protection Branch

450 5th Street NW

Washington, DC 20530

rowan.l.reid@usdoj.gov

meredith.l.reiter@usdoj.gov

Counsel for United States of America

FEDERAL TRADE COMMISSION

Sophia Siddiqui

Christine M. Todaro

Federal Trade Commission

600 Pennsylvania Ave. NW, Mailstop CC-5201

Washington, DC 20580 

OF COUNSEL

Case 1:23-cv-22553-XXXX Document 1 Entered on FLSD Docket 07/10/2023 Page 13 of 13
JS 44 (Rev. 04/21) FLSD Revised 12/02/2022 CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provid

by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiati

the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.

ed 

ng 

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

(d)Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH MARTIN ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)

(For Diversity Cases Only) and One Box for Defendant) 

☐ 1 U.S. Government ☐ 3 Federal Question PTF DEF PTF DEF

Plaintiff (U.S. Government Not a Party) ☐ Citizen of This State ☐ 1 ☐ 1 Incorporated or Principal Place ☐ 4 ☐ 4

of Business In This State

☐ 2 U.S. Government ☐ 4 Diversity ☐ Citizen of Another State ☐ 2 ☐ 2 Incorporated and Principal Place ☐ 5 ☐ 5

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a

Foreign Country ☐ 3 ☐ 3 Foreign Nation ☐ 6 ☐ 6

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

☐ 110 Insurance PERSONAL INJURY PERSONAL INJURY ☐ 625 Drug Related Seizure ☐ 422 Appeal 28 USC 158 ☐ 375 False Claims Act

☐ 120 Marine ☐ 310 Airplane ☐ 365 Personal Injury - of Property 21 USC 881 ☐ 423 Withdrawal ☐ 376 Qui Tam (31 USC 3729(a))

☐ 130 Miller Act ☐ 315 Airplane Product Product Liability ☐ 690 Other 28 USC 157 400 State Reapportionment

☐ 140 Negotiable Instrument Liability ☐ 367 Health Care/ ☐ 410 Antitrust

☐ 150 Recovery of Overpayment ☐ 320 Assault, Libel & Pharmaceutical INTELLECTUAL PROPERTY 

RIGHTS ☐ 430 Banks and Banking

& Enforcement of Judgment Slander Personal Injury ☐ 820 Copyrights ☐ 450 Commerce

☐ 151 Medicare Act ☐ 330 Federal Employers’ Product Liability ☐ 830 Patent ☐ 460 Deportation

☐ 152 Recovery of Defaulted

Student Loans Liability

☐

368 Asbestos Personal 

Injury Product Liability

☐ 835 Patent – Abbreviated

New Drug Application ☐ 470 Racketeer Influenced and Corrupt Organizations

(Excl. Veterans) ☐ 340 Marine

☐ 840 Trademark

☐ 480 Consumer Credit 

☐ (15 USC 1681 or 1692) 880 Defend Trade Secrets

Act of 2016

☐ 153 Recovery of Overpayment ☐ 345 Marine Product LABOR SOCIAL SECURITY ☐ 485 Telephone Consumer 

Protection Act (TCPA)

of Veteran’s Benefits Liability PERSONAL PROPERTY ☐ 710 Fair Labor Standards Acts ☐ 861 HIA (1395ff) ☐ 490 Cable/Sat TV

☐ 160 Stockholders’ Suits ☐ 350 Motor Vehicle ☐ 720 Labor/Mgmt. Relations ☐ 862 Black Lung (923) ☐ 850 Securities/Commodities/

☐ 190 Other Contract ☐ 355 Motor Vehicle ☐ 740 Railway Labor Act ☐ 863 DIWC/DIWW (405(g)) Exchange

☐ 195 Contract Product Liability Product Liability ☐ 751 Family and Medical ☐ 864 SSID Title XVI ☐ 890 Other Statutory Actions

☐ 196 Franchise ☐ 360 Other Personal Leave Act ☐ 865 RSI (405(g)) ☐ 891 Agricultural Acts

Injury ☐ 790 Other Labor Litigation ☐ 893 Environmental Matters

☐ 362 Personal Injury -

☐ 370 Other Fraud

☐ 371 Truth in Lending

☐ 380 Other Personal

Property Damage

☐ 385 Property Damage

Product Liability ☐ 791 Employee Retirement ☐ 895 Freedom of Information Act

Med. Malpractice Income Security Act ☐ 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS FEDERAL TAX SUITS ☐ 899 Administrative Procedure

☐ 210 Land Condemnation ☐ 440 Other Civil Rights Habeas Corpus: ☐ 870 Taxes (U.S. Plaintiff or

Defendant)

Act/Review or Appeal of

Agency Decision

☐ 220 Foreclosure ☐ 441 Voting ☐ 463 Alien Detainee ☐ 871 IRS—Third Party 26 USC

7609 ☐ 950 Constitutionality of State Statutes

☐ 230 Rent Lease & Ejectment ☐ 442 Employment ☐ 510 Motions to Vacate 

Sentence

☐ 240 Torts to Land ☐ 443 Housing/

Accommodations ☐ 530 General

☐ 245 Tort Product Liability ☐ 445 Amer. w/Disabilities - ☐ 535 Death Penalty IMMIGRATION

☐ 290 All Other Real Property Employment Other: ☐ 462 Naturalization Application 

☐ 446 Amer. w/Disabilities - ☐ 540 Mandamus & Other ☐ 465 Other Immigration

Other ☐ 550 Civil Rights Actions

☐ 448 Education ☐ 555 Prison Condition

☐

560 Civil Detainee – Conditions of

Confinement

V. ORIGIN (Place an “X” in One Box Only)

Transferred from

another district

(specify)

☐ 6 Multidistrict

Litigation

Transfer

8 Multidistrict 

Litigation 

– Direct 

File

☐9 Remanded from

Appellate Court

☐ 1 Original

Proceeding ☐ 2 Removed from State

Court 

☐ 3 Re-filed

(See VI

below)

☐ 4 Reinstated 

or

Reopened 

☐ 5 ☐ 7 Appeal to 

District Judge

from Magistrate

Judgment

☐

VI. RELATED/

RE-FILED CASE(S)

(See instructions): a) Re-filed Case ☐YES ☐NO b) Related Cases ☐YES ☐ NO

 JUDGE: DOCKET NUMBER:

VII. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):

LENGTH OF TRIAL via days estimated (for both sides to try entire case)

VIII. REQUESTED IN

COMPLAINT:

CHECK IF THIS IS A CLASS ACTION

UNDER F.R.C.P. 23 DEMAND $ CHECK YES only if demanded in complaint:

JURY DEMAND: ☐ Yes ☐ No

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY : RECEIPT # AMOUNT IFP JUDGE MAG JUDGE

Case 1:23-cv-22553-XXXX Document 1-1 Entered on FLSD Docket 07/10/2023 Page 1 of 2

7/10/2023 Rowan L Reid

United States of America Hello Hello Miami, LLC; Luis E. Leon Amaris

Miami-Dade County Rowan L. Reid; 450 5th Street NW, WDC 202-532-4315 15 U.S.C. § 56 - Federal Trade Commission Act - violation of telemarketing sales rule; 15 USC 45; 15 USC 53 5

L
JS 44 (Rev. 04/21) FLSD Revised 12/02/2022 

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required 

by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the 

use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil 

complaint filed. The attorney filing a case should complete the form as follows:

I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, 

giving both name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the

time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation 

cases, the county of residence of the “defendant” is the location of the tract of land involved.)

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting

in this section “(see attachment)”.

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in

one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the

Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and

box 1 or 2 should be marked. Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4

is checked, the citizenship of the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this

section for each principal party.

IV. Nature of Suit. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of

suit code that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an “X” in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition 

for removal is granted, check this box.

Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict 

litigation transfers. 

Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this 

box is checked, do not check (5) above.

Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.

Remanded from Appellate Court. (8) Check this box if remanded from Appellate Court. 

VI. Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the

corresponding judges name for such cases.

VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional

statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553

 Brief Description: Unauthorized reception of cable service

VIII. Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.

Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

Date and Attorney Signature. Date and sign the civil cover sheet.

Case 1:23-cv-22553-XXXX Document 1-1 Entered on FLSD Docket 07/10/2023 Page 2 of 2