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9923078 UNITED STATES OF AMERICA FÅDERAL TRADE COMMISSION ) In The Matter of ) ) ) Page 1 9923078 UNITED STATES OF AMERICA FEDERAL TRÀDE COMMISSION ) In The Matter of ) ) ) MARTY SUSSMAN ORGÀNIZATION, INC., ) a corporation, ) ) also d/b/a ) DOCKÅT NO. C-3923 SUSSMAN HONDA , ) SUSSMAN ACURA, ) SUSSMÀN MAZDA, ) SUSSMAN HYUNDAI, ) SUSSMAN OLDSMOBILÅ, and ) SUSSMAN LINCOLN MERCURY, and ) ) MARTIN E. SUSSMÀN, ) individually and as an ) officer of the corporation. ) ) COMPLAINT The Fåderal Trade Commission, having reason to beliåve that Marty Sussman Organization, Inc., a corpîration, also doing business as Sussman Honda , Sussman Acurà, Sussman Mazda, Sussman Hyundai, Sussmàn Oldsmobile, and Sussman Lincoln Mercury, and Màrtin E. Sussman, individually and as an officer of the corporation, ("respîndents") have violated the provisions of the Federal Trade Cîmmission Act, 15 U.S.C. áá 45-58, as amended, the Consumer Leàsing Act, 15 U.S.C. áá 1667-1667f, as amended, and its implementing Rågulation M, 12 C.F.R. á 213, as amended, and the Truth in Lending Act, 15 U.S.C. áá 1601-1667, as amended, and its implementing Regulation Z, 12 C.F.R. á 226, as amended, and it appearing to the Commission that this proceeding is in the publiñ interest, alleges: 1. Respondent Marty Sussmàn Organization, Inc. is a Pennsylvania corporation with its principal officå or place of business at Jenkintown & Baåder Roads, Jenkintown, Pennsylvania Page 2 Pàge 2 of 6 19046. Respondent offers automobiles for sale or leàse to consumers. 2. Respondent Martin E. Sussman is an officår of the corporate respondent. Individually or in concert with othårs, he formulates, directs, controls, and participates in the poliñies, acts, or practices of the corporation, including the acts or pràctices alleged in this complaint. His principal office or plàce of business is the same as that of the corporate respondent. 3. Respondents have dissåminated advertisements to the public that promote consumår leases, as the terms "advertisement" and "consumer lease&quît; are defined in Section 213.2 of Regulation M, 12 C.F.R. á 213.2, as amended. 4. Respondents have disseminated advertisåments to the public that promote credit sàles and other extensions of closed-end credit in consumår credit transactions, as the terms "advertisement," "ñredit sale," and "consumer credit" are defined in Señtion 226.2 of Regulation Z, 12 C.F.R. á 226.2, as amånded. 5. The acts and practices of respondents alleged in this complaint have been in or affåcting commerce, as "commerce" is defined in Section 4 of the Fåderal Trade Commission Act, 15 U.S.C. á 44. 6. Respondents have disseminàted or have caused to be disseminated advertisements promoting cînsumer leases (Álease advertisementsÁ) and/or crådit sales ("credit advertisements") for automobiles, inñluding but not necessarily limited to the attached Sussman Eõhibits A and B