At all times material to this complaint, acting alone or in concert with others, he has formulated, directed, controlled, or participated in the acts and practices alleged in this complaint. He transacts or has transacted business in the Northern District of Georgia. At all times material to this complaint, acting alone or in concert with others, he has formulated, directed, controlled, or participated in the acts and practices alleged in this complaint. He transacts or has transacted business in the Northern District of Georgia. Since at least 1998, Defendants have operated a business enterprise that deceptively markets vacation travel packages to consumers throughout the United States.
Defendants induce consumers to purchase vacation packages by means of a telephone sales pitch.
Because of this heading, in a great many instances, consumers believe that these faxes are from the travel division of their company or are in some way approved or sponsored by their employer. Defendants also have induced and continue to induce consumers to call their toll free number through advertising other than unsolicited faxes. The vacation travel packages sold by Defendants typically include one night's accommodation in Ft. Lauderdale, Florida, a round trip cruise to Freeport, Grand Bahama Island, and three nights' accommodation on Grand Bahama Island for a stated rate per person, plus port and service charges. When the consumers call Defendants' toll free number, they are provided with little additional information by Defendants' sales representatives regarding the vacation travel package.