PLAINTIFF 4. The FTC is an independent agency of the United States Government created by statute. 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. 5. The FTC is authorized to initiate federal district court proceedings, by its own attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as may be appropriate in each case, including rescission or reformation of contracts, restitution, and the disgorgement ofill-gotten monies. 15 U.S.C. §§ 53(b) and 56(a)(2)(A).
DEFENDANTS 6. Defendant Expand, Inc. (“Expand”), also doing business as Gigats, also doing business as Education Match, also doing business as SoftRock, Inc., is an Illinois corporation with its principal place of business in Orlando, FL. Expand transacts or has transacted business in this district and throughout the United States. 7. Defendant Ayman A. Difrawi, also known as Alec Difrawi, also known as Ayman El-Difrawi, is the founder, self-described ·’quarterback,” chief executive officer, and a director of Expand. At all times material 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 Expand, including the acts and practices set forth in this Complaint. Defendant Difrawi 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.
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