WILLIAM BLUMENTHAL General Counsel KENNETH H. ABBE (Cal. Bar No. 172416)
[email protected] JENNIFER M. BRENNAN (Cal. Bar No. 225473) j mbrennan@f tc .gov Federal Trade Commission 10877 Wilshire Blvd., Ste Los Angeles, CA 90024 (310) 824-4343 (voice) (310) 824-4380 (fax). Attorneys for Plaintiff FTC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION d, FEDERAL TRADE COMMISSION, ) Case No. Plaintiff, ) COMPLAINT FOR INJUNCTIVE AND ) OTHER EQUITABLE RELIEF v. 1 LA GRANA, LLC, ) a California corporation; ) LA GRANA, INC., a California corporation; ) LOSINI, LLC, 1 a California corporation; ) ) CARLOS I~~IGUEZ,individually ) and as an officer or 1 director of La Grana, ) LLC, La Grana, Inc ., and ) Losini, LLC; and ) 1 CLAUDIA I~IGUEZ,individually ) and as an officer or 1 director of La Grana, 1 LLC, and Losini, LLC; ) ) Defendants. ) Plaintiff, the Federal Trade Commission, by its undersigned attorneys, alleges: 1. The Federal Trade Commission brings this action under Section 13(b) of the Federal Trade Commission Act ('FTC Act"), 15 U.S.C. § 53(b), to secure a permanent injunction, rescission of contracts and restitution, disgorgement of ill-gotten gains, and other equitable relief against Defendants for engaging in deceptive acts or practices in connection with the advertising, marketing, promoting, offering for sale, and sale of weight loss packages in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52, and a music collection on compact discs ('CDs") in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45 (a).