He has transacted business in the Northern District of Georgia. Defendant Wayne Gregory is a sales representative for Creative. At all times material to this complaint, acting alone or in concert with others, he has participated in the acts and practices of the corporate defendants, including the acts and practices set forth in this complaint. He has transacted business in the Northern District of Georgia. Since at least early 1996, the defendants have been engaged in a common scheme to promote, offer to sell and sell nationwide to consumers a business opportunity involving vending machines which distribute disposable cameras and other film products.
Defendants advertise their camera vending machine venture through newspaper advertisements.
If a consumer responds to the advertisement, his name and telephone number generally are taken by an operator, and the call is returned by a sales representative for the corporate defendants. These sales representatives include defendants Steven Axelrod, Arnold Filner, and Wayne Gregory. In the return call, the sales representatives explain that the business opportunity being sold is vending machines that distribute disposable cameras and other film products. The investment price does not include the cost of any inventory. The sales representatives stress the importance of Creative's use of Kodak products to ensure the success of the business opportunity.