tailieunhanh - IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION DANIEL KEELLER

Tham khảo sách 'in the circuit court of cook county, illinois county department, chancery division daniel keeller', kinh doanh - tiếp thị, quản trị kinh doanh phục vụ nhu cầu học tập, nghiên cứu và làm việc hiệu quả | IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS COUNTY DEPARTMENT CHANCERY DIVISION DANIEL KEELLER individually and on behalf of all others similarly situated Plaintiff No. v. GROUPON Inc. a Delaware Corporation d b a Groupon Defendant. CLASS ACTION COMPLAINT Plaintiff Daniel Keeler Plaintiff for his Class Action Complaint alleges as follows upon personal knowledge as to himself and his own acts and experiences and as to all other matters upon information and belief based upon inter alia investigation conducted by his attorneys Introduction 1. Plaintiff s claims herein are based upon Defendant Groupon Inc. s d b a Groupon Defendant illegal practices related to its online gift certificate sales business. 2. Groupon is a company that sells gift certificates that the company refers to as Groupons to consumers as defined by the Illinois Consumer Fraud and Deceptive Business Practices Act 815 ILCS 505 1 et seq. ICFA . Groupon sells and seeks to sell its gift certificates in a variety of cities throughout the United States. Groupon claims to offer consumers a variety of benefits purportedly using collective buying power to obtain savings in the purchase of said gift certificates. 3. In clear contravention of Illinois law which is Groupon s law of choice on its website Groupon in attempting to make sales of its gift certificates used deception fraud false pretense false promises misrepresentations and or concealment suppressed and or omitted material facts with the intent that others would rely upon the concealment suppression or omission of such material facts to induce consumers to buy its gift certificates in clear violation of the ICFA. 4. Groupon knowingly and intentionally employs a business model designed to systematically deceive its customers by selling Groupons or gift certificates for non-food products with an expiration date of less than five years certificates in violation of the law. See 815 ILCS 505 2SS b no person shall sell a gift certificate on or after .

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