Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 1 of 30

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UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

FEDERAL TRADE COMMISSION, and

Case No. 3:24-cv-00012-JCH

STATE OF CONNECTICUT,

AMENDED COMPLAINT FOR

PERMANENT INJUNCTION,

MONETARY JUDGMENT, CIVIL

PENALTY JUDGMENT, AND

OTHER RELIEF

Plaintiffs,

CHASE NISSAN LLC, a limited liability

company, also d/b/a MANCHESTER CITY

NISSAN, and

PATRICK DIBRE, individually and as an officer

of CHASE NISSAN LLC, also d/b/a

MANCHESTER CITY NISSAN,

REFAAT SOBOH, aka BRIAN SOBOH,

individually and as an officer

of CHASE NISSAN LLC, also d/b/a

MANCHESTER CITY NISSAN,

MICHAEL HAMADI,

AIHAM ALKHATIB,

MATTHEW CHMIELINSKI, and

FRED MOJICA, aka FREDDY MOJICA,

Defendants.

Plaintiffs, the Federal Trade Commission (“FTC” or “Commission”), and the State of

Connecticut, by William Tong, Connecticut Attorney General, for their Complaint allege:

The FTC brings this action for Defendants’ violations of Sections 5(a) of the FTC

Act, 15 U.S.C. § 45(a). Defendants’ violations relate to deceptive and unfair practices in

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advertising, marketing, promotion, offering for sale, lease, or financing, and sale, lease, or

financing of motor vehicles. For these violations, the FTC seeks relief, including a permanent

injunction and other relief, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b).

The State of Connecticut, by and through William Tong, the Attorney General of

the State of Connecticut, acting at the request of Bryan Cafferelli, Commissioner of the

Connecticut Department of Consumer Protection, brings this action under the Connecticut Unfair

Trade Practices Act (“CUTPA”), Chapter 735a of the Connecticut General Statutes, and more

particularly General Statutes § 42-110m, to obtain injunctive relief against the Defendants’

alleged violations of General Statutes § 42-110b(a), to obtain other relief as is necessary to

redress injury to consumers resulting from the Defendants’ violations of law, and disgorge

Defendants of ill-gotten money and civil penalties, pursuant to General Statutes § 42-110o(b).

JURISDICTION AND VENUE

This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a),

and 1345.

Supplemental jurisdiction over the State of Connecticut’s claims is proper under

28 U.S.C. § 1367.

Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), (c)(1), and

(c)(2), and 15 U.S.C. § 53(b).

PLAINTIFFS

The FTC is an independent agency of the United States Government created by

the FTC Act, which authorizes the FTC to commence this district court civil action by its own

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attorneys. 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.

The State of Connecticut, through its Attorney General acting at the request of the

Commissioner of Consumer Protection, is authorized to initiate proceedings to enjoin violations

of CUTPA and to seek injunctive relief, restitution, and civil penalties and other equitable relief

as this Court deems appropriate under General Statutes §§ 42-110m and 42-110o.

DEFENDANTS

Defendant Chase Nissan LLC (“Chase Nissan”), also doing business as

Manchester City Nissan, is a Connecticut limited liability company with its principal place of

business at 30 Tolland Turnpike, Manchester, Connecticut 06040. Chase Nissan is a closely held

corporation. Defendants Patrick Dibre and Refaat Soboh are the sole principals. Chase Nissan

transacts or has transacted business in this District and throughout the United States. At all times

relevant to this Complaint, acting alone or in concert with others, Chase Nissan has advertised,

marketed, distributed, or sold automobiles to consumers throughout the United States.

Defendant Patrick Dibre is a principal and managing member of Chase Nissan. At

all times relevant 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

Manchester City Nissan, including the acts and practices described in this Complaint. As a

principal and managing partner, he has the authority to control the practices alleged in this

Complaint. In this capacity, he personally responded under oath to a 2021 inquiry by the State of

Connecticut into Chase Nissan’s certification fee and add-on charge practices. He admitted that

Chase Nissan charged additional certification fees, labeled these fees as “State of CT Inspection

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and Safety Charges,” and labeled optional add-on charges that consumers did not have to

purchase as “Taxable Fees.” Defendant Dibre, in connection with the matters alleged herein,

transacts or has transacted business in this District and throughout the United States.

10.

Defendant Refaat Soboh, aka Brian Soboh is a principal and managing partner of

Chase Nissan. At all times relevant 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 Manchester City Nissan, including the acts and practices described in this

Complaint. As a principal and managing partner, he has the authority to control the practices

alleged in this Complaint. In this capacity, he prepared, participated in, or supervised Chase

Nissan’s response to an FTC inquiry regarding certification fees and add-on charges, in which

Chase Nissan admits that it received a 2021 inquiry from the State of Connecticut and consumer

complaints. Defendant Soboh 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.

11.

Defendant Michael Hamadi is the general manager of Manchester City Nissan. At

all times relevant 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

Manchester City Nissan, including the acts and practices described in this Complaint. As general

manager, he has the authority to control the practices alleged in this Complaint. He also has

responded to at least one consumer complaint about unauthorized add-on charges and told

employees who were charging a certification fee not to charge such a fee only on certain types of

leased vehicles. Defendant Hamadi resides in this District and, in connection with the matters

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alleged herein, transacts or has transacted business in this District and throughout the United

States.

12.

Defendant Aiham Alkhatib is a finance manager at Manchester City Nissan. At all

times relevant 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

Manchester City Nissan, including the acts and practices described in this Complaint. He has

participated directly in charging consumers for add-on services without the consumers’

expressed informed consent or in falsely telling consumers that they are required to purchase

add-on services. Defendant Alkhatib 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.

13.

Defendant Matthew Chmielinksi is a sales manager at Manchester City Nissan. At

all times relevant 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

Manchester City Nissan, including the acts and practices described in this Complaint. He has

participated directly in charging consumers for additional inspection, reconditioning, or

certification fees. He also has responded to consumer complaints about unauthorized or

deceptive add-on charges. Defendant Chmielinski 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.

14.

Defendant Fred Mojica, aka Freddy Mojica is a sales manager at Manchester City

Nissan. At all times relevant to this Complaint, acting alone or in concert with others, he has

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formulated, directed, controlled, had the authority to control, or participated in the acts and

practices of Manchester City Nissan, including the acts and practices described in this

Complaint. He has participated directly in charging consumers for additional inspection,

reconditioning, or certification fees. Defendant Mojica 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.

COMMERCE

15.

At all times relevant to this Complaint, Defendants have maintained a substantial

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act,

15 U.S.C. § 44.

DEFENDANTS’ BUSINESS ACTIVITIES

16.

Defendants operate Manchester City Nissan, an automobile dealership in

Manchester, Connecticut. Defendants advertise certified pre-owned vehicles for low prices.

Many consumers visit Defendants’ dealership because of the low advertised prices for certified

pre-owned vehicles. But Defendants do not honor those prices. Instead, Defendants doublecharge consumers the cost to certify vehicles that Defendants had advertised as already certified.

Worse, Defendants often fail to properly certify the vehicles they sell, leaving many consumers

to pay twice for a service Defendants fail to perform once. Defendants also charge consumers for

add-ons that they did not know about or authorize, or deceive consumers into paying for them by

saying that they are required. In addition, Defendants lie about the amount of mandatory state

registration and other fees consumers must pay.

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Background on Certified Vehicles

17.

Defendants advertise and sell certified pre-owned cars. Certified vehicles come

with a limited manufacturer warranty. Before advertising a used car as certified, Defendants

must inspect the vehicle for safety issues and recondition the vehicle if any repairs are necessary.

For example, to certify a Nissan vehicle, Defendants must perform an inspection in accordance

with Nissan’s checklist, and if specific items need to be repaired, Defendants must recondition

the vehicle to meet the manufacturer’s certification requirements. Defendants then must report

the sale of the used vehicle and pay a certification fee to the manufacturer. The manufacturer

does not activate the certified warranty unless and until the dealer reports the sale and pays the

fee.

Defendants’ Junk Certification Fees

18.

On their website and on third-party websites, Defendants—who describe

themselves as the “#1 FACTORY CERTIFIED NISSAN DEALER IN NEW ENGLAND!”—

advertise particular certified pre-owned vehicles for specific prices. For example, in one such ad

on Defendants’ website, Defendants represent that consumers can purchase a “Nissan Certified”

2021 Nissan Rogue S SUV for “Your Price” of $26,000.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 8 of 30

2021 Nissan Rogue S SUV

Stock #PC679674A

t 2 other people interested in this vehicle

335views

$26,000

Your Price

Nissan Certified

Low Mileage

0 Carfax 1 Owner

□ Bluetooth Connectivity

® Back-up Camera

Fuel Efficient

SCHEDULE MY

~ TEST DRIVE

8 Enlarge Photos (35)

.GET PRE

~ APPROVED

$ vouR

PAYMENT

"-._/. Certified Pre-owned mifJ!S

19.

Defendants also claim that certified vehicles come with an inspection and limited

warranty. For example, the above advertisement lists several items below the header “Nissan

Certified Details,” including an inspection and a “Limited Warranty: 84 Month/100,000 Mile

(whichever comes first) from original in-service date.”

- Advertised price on all Certified Nissans include NEMAC Captive Finance Rebate-, Rogue S, 4D Sport Utility, 2.5L 14 DOHC 16V, CVT with Xtronic, /JWD,

Super Black, Charcoal Cloth.

At Manchester City Nissan we want you to know that all our vehicles are priced at a competitive value position to the market. We use an independent 3rd

party software to research internet listings on all vehicles in the market so we can ensure that our prices are the most competitive out there. We do this

simply so people choose us when they start searching for their next car.

Priced below KBB Fair Purchase Price!

Cl ean CARFAX. CARFAX One-Owner.

Certified. Nissan Certified Details:

• 167 Point Inspection

• Transferable Warranty

• Plus 1 Year Pre-Paid Maintenance Included.

• Vehicle Histo,y

• Limited Warranty: 84 Month/100,000 Mile (whichever comes first) from original in.service date

• Warranty Deductible: $100

• Roadside Assistance

Our Sales, Service and Parts Departments work closely together to provide you with the most enjoyable, least stressful car-buying experience possible. The

average tenure for our sales people, managers, technicians and all other employees is over 20 years. Most of them have been career employees of

Manchester City Nissan - and with that much experience, you can be sure they'll provide you with the highest quality care for you and your vehicle. We are

also proud to be a Better Business Bureau Accredited Business with an A• rating.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 9 of 30

A true and correct copy of this ad is Attachment A to this Complaint.

20.

Based on Defendants’ ads, many consumers believe that Defendants will sell

them the advertised certified vehicle for the advertised price. In numerous instances, however,

when consumers attempt to purchase certified vehicles for the prices advertised, Defendants

charge them hundreds to thousands of dollars in additional fees for services that are part of

certifying a vehicle (e.g., fees for inspection, “CT Safety and Reconditioning,” “certification

upgrades,” and “CPO,” which stands for certified pre-owned). In many instances, Defendants

roll these costs into the price of the vehicle that appears in the agreement.

21.

For example, Defendants advertised a “Certified” 2017 Nissan Rogue for

$15,700. Defendants did not sell the car for $15,700. Instead, Defendants charged the buyer a

$5,295.65 inspection fee on top of the price advertised for a vehicle that was advertised as

already inspected as part of the certification process. In another instance, Defendants advertised a

“Certified” 2018 Nissan Altima for $14,000, but then charged the buyer a $2,525.00 fee for

“connecticut [sic] safety and reconditioning” on top of the price advertised for a vehicle that was

advertised as already reconditioned. Thus, in many instances, Defendants do not sell consumers

the advertised certified vehicles for the advertised prices.

22.

Moreover, in numerous instances, Defendants represent that consumers are

required to pay these additional inspection, safety and reconditioning, and certification fees to

purchase vehicles. For example, Defendants told a consumer that a $2,250 fee was required for

“CT Safety and Reconditioning.”

23.

In fact, consumers are not required to pay inspection, safety and reconditioning,

and certification fees to purchase vehicles that are already advertised as certified. Many

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manufacturers including Nissan specifically prohibit Defendants from separately charging for the

cost of certification. Further, the State of Connecticut does not require consumers to pay a fee for

safety and reconditioning.

24.

Additionally, in numerous instances, despite stating in advertisements that

vehicles are certified and come with a limited warranty, Defendants do not get the vehicles

certified by the manufacturer. In numerous instances, Defendants advertised a vehicle as

certified, but did not report the sale of that vehicle or pay the certification fee to the

manufacturer. Thus, the consumer did not receive a certified vehicle or the benefits of the limited

manufacturer warranty that come with certification. In other words, Defendants often charge

consumers twice for “certifying” a vehicle that they do not actually certify.

Defendants’ Unlawful Add-On Charges

25.

Once consumers have settled on a price for the vehicle, consumers who are

financing their purchase or leasing their vehicle must meet with a financing manager to go over

the terms of their financing or leasing, frequently after a lengthy wait. Defendants present

consumers with a stack of complex, highly technical documents and then rush consumers

through the closing process, which typically requires consumers to sign their name in over a

dozen places. The finance manager typically just shows the consumers where to sign. This

process – from the consumer waiting to meet with someone from finance to the consumer

signing their deal – often takes several hours.

26.

As part of these transactions, Defendants often charge consumers for add-ons,

such as GAP insurance, service contracts, maintenance contracts, and Total Loss Protection

(“TLP”). For example, Defendants tack on charges for TLP in more than 90% of their deals.

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27.

In numerous instances, Defendants have included add-on charges in the closing

documents for these deals without obtaining the consumers’ express informed consent. These

charges commonly amount to hundreds or thousands of dollars and are typically added to the

amount financed and spread out over monthly payments, making the added charges more

difficult to detect.

28.

Many consumers have complained about Defendants charging for add-ons

without authorization. For example, one consumer agreed to purchase a 2017 Nissan Rogue

Sport that was advertised for $20,500. She sat down with a salesperson and negotiated a

payment. Then she met with the finance manager, Defendant Aiham Alkhatib, to discuss

financing. He told her the monthly payment, which was higher than she had been quoted during

her negotiation, but he did not explain why the payment had increased. The consumer assumed

that the increased monthly payment was related to her credit. Defendant Alkhatib then had her

sign the contract electronically on a tablet.

29.

It was not until after she left the dealership that she realized she had been charged

for unwanted items. She was surprised to learn that, without her knowledge or authorization,

Defendants had charged her $3,300 for a Nissan service contract and $3,500 for a preventative

maintenance agreement. She also was surprised to learn that Defendants had charged her $516

for TLP, again without her knowledge or consent. The consumer sought, and eventually

obtained, a refund for some, but not all, of these charges.

30.

Defendants gave another consumer the impression that he was getting GAP

insurance and a bumper-to-bumper warranty at no extra cost. He later discovered that Defendants

had charged him $895 for GAP insurance and $4,160 for a service contract.

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31.

In some instances, Defendants have charged consumers for add-ons that they told

the consumers were free. For example, one consumer was told by the finance manager that she

would receive oil changes as a “gift.” She later discovered that, without her knowledge or

consent, Defendants had charged her $289 for a maintenance contract, which included oil

changes.

32.

In other instances, Defendants have charged consumers for add-on products that

consumers have specifically declined. For example, one consumer complained that she was

charged over $9,000 for four warranties (“Maintenance Care Protection,” “Chase Auto Care

Purchase Platinum,” “Vehicle Service Contract,” and “Security + Maintenance”) and $516 for

TLP that she specifically declined.

33.

In numerous other instances, Defendants tell consumers that the dealership or a

third party such as the finance company requires consumers to purchase add-on products or

packages to purchase, lease, or finance the vehicle.

34.

For example, Defendant Alkhatib indicated to one consumer that if she did not

buy GAP insurance, the finance company would not loan her the money to purchase the car.

Defendants added GAP insurance to her purchase.

35.

Defendants told another consumer that she had to buy GAP insurance, TLP, and

an extended warranty. But because Defendants already had the keys to her trade-in and the plates

had been already taken off the vehicle, she felt like she did not have the option to walk out, and

she ended up with charges for add-on items she did not want.

36.

As another example, Defendants charge for TLP, an optional add-on that

Defendants sometimes call “Vehicle Identification Number (VIN) Etching,” but label it as

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“Taxable Fees (Estimated)” on consumers’ paperwork. This leads consumers to believe the

charges are required taxes rather than optional add-ons.

37.

Despite Defendants’ claims that these add-on items are required, they are not.

Consumers are not required to enter into add-on product agreements to purchase, lease, or obtain

financing for a vehicle. Connecticut does not require consumers to purchase add-ons. Neither the

finance company nor the third-party add-on provider require that the add-ons be sold. And

Defendants charge some consumers for these add-ons, but not others, demonstrating that the addons are not required.

Defendants’ Junk Fees for Registration and Other State Services

38.

In the contract and purchase or lease order, Defendants list the amount of each

mandatory registration and other state fee. But, in many cases, those registration and other state

fees are a fraction of what Defendants claim. Defendants simply tack on an additional amount in

bogus fees on the consumers’ contract without the consumers’ knowledge or consent.

39.

For example, Defendants told one consumer that Connecticut registration and

other state fees were $345. But, in fact, Connecticut registration and other fees were only

$208.20. Defendants tacked on an additional $136.80 in bogus fees.

40.

In another case, Defendants told a consumer that Connecticut registration and

other state fees were $245. But, in fact, Connecticut registration and other fees were only $190.

Defendants tacked on an additional $55 in bogus fees.

41.

In numerous transactions, Defendants also double charge consumers taxes and the

documentation fee without the consumers’ knowledge or consent by charging taxes and the

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documentation fee once in negotiation and then, once the consumer has signed off on the

negotiated price including taxes and the documentation fee, again in the final contract.

Defendants Have Persisted in Their Misconduct

42.

On May 14, 2021, the Connecticut Department of Consumer Protection

(“Connecticut DCP”) sent a civil investigative demand to Chase Nissan asking the dealership to

identify various fees appearing in its sales paperwork, including “certification upgrade”, “State

of CT Inspection and Safety Charge”, and “Taxable Fees (Estimated).”

43.

On September 29, 2021, Chase Nissan responded. Chase Nissan identified the

“certification upgrade” as “an additional charge for an extended limited warranty.” Asked to

identify the “State of CT Inspection and Safety Charge,” Chase Nissan responded, “This is the

Certification Upgrade.” Chase Nissan answered that “[Taxable Fees (Estimated)] is for Vehicle

Identification Number (VIN) Etching. The Dealer assesses a fee of $516.00 for VIN Etching.

This fee is optional.” Patrick Dibre prepared the response and a swore under oath that these

answers were accurate.

44.

On June 24, 2022, the Connecticut DCP sent a letter warning Chase Nissan that it

was an illegal deceptive advertising practice to charge an additional certification fee for vehicles

advertised as certified pre-owned or to advertise that a vehicle is certified pre-owned when, in

fact, it is not certified. The Connecticut DCP also questioned Chase Nissan’s practice of labeling

a charge as a “State of CT Inspection and Safety Charge” when it “has nothing to do with the

State of Connecticut, safety of the vehicle or inspection of the vehicle” and is just another name

for a certification. Finally, the Connecticut DCP warned Chase Nissan that by calling the fee for

Vehicle Identification Number (VIN) etching “Taxable Fee (Estimated),” “a reasonable

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consumer could fairly conclude that this is a requi[r]ed tax but it is, in fact, a voluntary service

option that consumers may decline to purchase.”

45.

Defendants nonetheless have continued to charge consumers extra to certify

vehicles that were advertised as certified. And they have continued to mislead consumers into

thinking that optional add-on charges were required.

46.

Defendants’ practices have persisted despite consumer complaints made directly

to them and on public websites.

***

47.

Based on the facts and violations of law alleged in this Complaint, the FTC has

reason to believe that Defendants are violating or are about to violate laws enforced by the

Commission.

VIOLATIONS OF THE FTC ACT

48.

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts

or practices in or affecting commerce.”

49.

Misrepresentations or deceptive omissions of material fact constitute deceptive

acts or practices prohibited by Section 5(a) of the FTC Act.

50.

Acts or practices are unfair under Section 5 of the FTC Act if they cause or are

likely to cause substantial injury to consumers that consumers cannot reasonably avoid

themselves and that is not outweighed by countervailing benefits to consumers or competition.

15 U.S.C. § 45(n).

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VIOLATIONS OF CUTPA

51.

At section 42-110b(a), CUTPA states the following: “[n]o person shall engage in

unfair methods of competition and unfair or deceptive acts or practices in the conduct of any

trade or commerce.”

52.

At section 42-110a(4), CUTPA states that “trade” and “commerce” shall mean the

“advertising, the sale or rent or lease, the offering for sale or lease, or the distribution of any

service or any property, tangible or intangible, real, personal or mixed, and any article,

commodity, or thing of value in this state.”

53.

At section 42-110b(b), CUTPA also states that: “[i]t is the intent that in

construing subsection (a) of this section, the commissioner and the courts of this state shall be

guided by interpretations given by the Federal Trade Commission and the federal courts to

Section 5(a)(1) of the Federal Trade Commission Act (15 U.S.C. § 45(a)(1)), as from time to

time amended.”

54.

Defendants all operated, or have operated, from Connecticut.

55.

The acts and practices alleged in this Complaint all emanate from and are

intimately associated with Connecticut, are directed at Connecticut consumers, and affect the

marketing and sales of motor vehicles in Connecticut. Defendants are therefore engaged in trade

or commerce in the State of Connecticut.

Count I

Misrepresentations Regarding Advertised Prices

(by Plaintiff FTC against all Defendants)

56.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 17 of 30

represent, directly or indirectly, expressly or by implication, that Defendants will sell particular

vehicles at specific prices.

57.

Defendants’ representations as described in Paragraph 56 are false or misleading

or were not substantiated at the time the representations were made.

58.

Therefore, Defendants’ representations as described in Paragraph 56 constitute

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count II

Misrepresentations Regarding Certification

(by Plaintiff FTC against all Defendants)

59.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants

represent, directly or indirectly, expressly or by implication, that Defendants will sell consumers

a certified used vehicle with a limited manufacturer warranty.

60.

Defendants’ representations as described in Paragraph 59 are false or misleading

or were not substantiated at the time the representations were made.

61.

Therefore, Defendants’ representations as described in Paragraph 59 constitute

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count III

Misrepresentations Regarding Fees and Add-Ons

(by Plaintiff FTC against all Defendants)

62.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants

represent, directly or indirectly, expressly or by implication, that consumers are required to pay

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 18 of 30

certain fees or charges, such as for inspecting, reconditioning, certifying vehicles, or add-ons, to

purchase, lease, or finance vehicles.

63.

Defendants’ representations as described in Paragraph 62 are false or misleading

or were not substantiated at the time the representations were made.

64.

Therefore, Defendants’ representations as described in Paragraph 62 constitute

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count IV

Misrepresentations Regarding Authorization of Charges

(by Plaintiff FTC against all Defendants)

65.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants

represent, directly or indirectly, expressly or by implication, that charges appearing on

consumers’ sales or lease contracts are authorized by consumers.

66.

Defendants’ representations as described in Paragraph 65 are false or misleading

or were not substantiated at the time the representations were made.

67.

Therefore, Defendants’ representations as described in Paragraph 65 constitute

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count V

Misrepresentations Regarding State Registration and Other Fees

(by Plaintiff FTC against Defendants Chase Nissan, Dibre, Soboh, Hamadi, and Alkhatib)

68.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing, or sale, lease, or financing of motor vehicles, Defendants

represent, directly or indirectly, expressly or by implication, that registration and other state fees

cost a particular amount.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 19 of 30

69.

Defendants’ representations as described in Paragraph 68 are false or misleading

or were not substantiated at the time the representations were made.

70.

Therefore, Defendants’ representations as described in Paragraph 68 constitute

deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count VI

Unauthorized Charges

(by Plaintiff FTC against all Defendants)

71.

In numerous instances, Defendants charge consumers without obtaining

consumers’ express informed consent.

72.

Defendants’ acts or practices cause or are likely to cause substantial injury to

consumers that consumers cannot reasonably avoid themselves and that is not outweighed by

countervailing benefits to consumers or competition.

73.

Therefore, Defendants’ acts or practices as described in Paragraph 71 constitute

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), (n).

Count VII

Misrepresentations Regarding Advertised Prices

(by Plaintiff State of Connecticut against Defendants Chase Nissan, Dibre, Soboh, and

Hamadi)

74.

In numerous instances, in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or

indirectly, expressly or by implication, that Defendants will sell particular vehicles at specific

prices.

75.

In truth and in fact, the Defendants do not sell those particular vehicles at the

specific represented prices.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 20 of 30

76.

Defendants’ acts and practices, as described herein, were likely to mislead

consumers acting reasonably under the circumstances into believing that the Defendants’

representations concerning the specific price at which they would sell a vehicle were true and

accurate.

77.

Defendants’ representations as set forth in paragraph 74 of this Count were

material to consumers’ decisions about whether or not to purchase a vehicle from the

Defendants.

78.

Defendants have therefore engaged in unfair or deceptive acts and practices in

violation of Conn. Gen. Stat. § 42-110b(a).

Count VIII

Misrepresentations Regarding Certification

(by Plaintiff State of Connecticut against all Defendants)

79.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or

indirectly, expressly or by implication, that Defendants will sell consumers a certified used

vehicle with a limited manufacturer warranty.

80.

In truth and in fact, the Defendants did not sell those particular vehicles with a

limited manufacturer warranty.

81.

Defendants’ acts and practices, as described herein, were likely to mislead

consumers acting reasonably under the circumstances into believing that the Defendants’

representations concerning the inclusion of a limited manufacturer warranty were true and

accurate.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 21 of 30

82.

Defendants’ representations as set forth in paragraph 79 of this Count were

material to consumers’ decisions about whether or not to purchase a vehicle from the

Defendants.

83.

Defendants have therefore engaged in unfair or deceptive acts and practices in

violation of Conn. Gen. Stat. § 42-110b(a).

Count IX

Misrepresentations Regarding Fees and Add-Ons

(by Plaintiff State of Connecticut against all Defendants)

84.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or

indirectly, expressly or by implication, that consumers are required to pay certain fees, such as

for inspecting, reconditioning, or certifying vehicles, or to buy certain add-ons to purchase, lease,

or finance certified vehicles.

85.

In truth and in fact, consumers were not required to pay certain fees, such as for

inspecting, reconditioning, or certifying vehicles, or to buy certain add-ons to purchase, lease, or

finance certified vehicles.

86.

Defendants’ acts and practices, as described herein, were likely to mislead

consumers acting reasonably under the circumstances into believing that the Defendants’

representations concerning the payment of such fees and the purchase of such add-ons to

purchase, lease, or finance certified vehicles were true and accurate.

87.

Defendants’ representations as set forth in paragraph 84 of this Count were

material to consumers’ decisions about whether or not to pay such fees and purchase such addons in connection with a purchase a vehicle from the Defendants.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 22 of 30

88.

Defendants have therefore engaged in unfair or deceptive acts and practices in

violation of Conn. Gen. Stat. § 42-110b(a).

Count X

Misrepresentations Regarding Authorization of Charges

(by Plaintiff State of Connecticut against all Defendants)

89.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or

indirectly, expressly or by implication, that charges appearing on sales or lease contracts were

authorized by consumers.

90.

In truth and in fact, consumers did not authorize the charges on sales or lease

contracts.

91.

Defendants’ acts and practices, as described herein, were likely to mislead

consumers acting reasonably under the circumstances into believing that certain charges on sales

and lease contracts were mandatory and Defendants’ representations that such charges were

mandatory were true and accurate.

92.

Defendants’ representations as set forth in paragraph 89 of this Count were

material to consumers’ decisions about whether or not to authorize such charges in connection

with a purchase of a vehicle from the Defendants.

93.

Defendants have therefore engaged in unfair or deceptive acts and practices in

violation of Conn. Gen. Stat. § 42-110b(a).

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 23 of 30

Count XI

Misrepresentations Regarding Authorization of Charges

(by Plaintiff State of Connecticut against Defendants Chase Nissan, Dibre, Soboh, Hamadi,

and Alkhatib)

94.

In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, lease, or financing of motor vehicles, Defendants represent, directly or

indirectly, expressly or by implication, that registration and other state fees cost a particular

amount and charged consumers that amount.

95.

In truth and in fact, Defendants’ representations as to registration and other state

fees were inaccurate and inflated and Defendants collected funds from consumers exceeding

what was required by the state.

96.

Defendants’ acts and practices, as described herein, were likely to mislead

consumers acting reasonably under the circumstances into believing that the amounts Defendants

collected from consumers to pay certain registration and state fees were true and accurate.

97.

Defendants’ representations as set forth in paragraph 94 of this Count were

material to consumers’ decisions about whether or not to purchase a vehicle from the

Defendants.

98.

Defendants have therefore engaged in unfair or deceptive acts and practices in

violation of Conn. Gen. Stat. § 42-110b(a).

Count XII

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-18)

(by Plaintiff State of Connecticut against Defendant Chase Nissan)

99.

The allegations of Paragraphs 79 of Count VIII are incorporated by reference as

Paragraph 99 of Count XII as if fully set forth herein.

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 24 of 30

100.

Defendant Chase Nissan’s acts and practices violate § 42-110b-18(c) of the

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it

misrepresented that the motor vehicles it offered for sale are “Nissan Certified.” In truth and in

fact, Defendant Chase Nissan’s representations were false.

101.

Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and

practices in violation of Conn. Gen. Stat. § 42-110b(a).

Count XIII

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-22)

(by Plaintiff State of Connecticut against Defendant Chase Nissan)

102.

The allegations of Paragraphs 69, 79, and 84 of Counts VII, VIII, and IX are

incorporated by reference as Paragraph 102 of Count XIII as if fully set forth herein.

103.

Defendant Chase Nissan’s acts and practices violate § 42-110b-22 of the

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it

failed to conspicuously state all material contingencies, conditions, and limitations on its offer to

sell motor vehicles at the advertised price.

104.

Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and

practices in violation of Conn. Gen. Stat. § 42-110b(a).

Count XIV

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(b)(1))

(by Plaintiff State of Connecticut against Defendant Chase Nissan)

105.

The allegations of Paragraphs 69, 79, and 84 of Counts VII, VIII, and IX are

incorporated by reference as Paragraph 105 of Count XIV as if fully set forth herein.

106.

Defendant Chase Nissan’s acts and practices violate § 42-110b-28(b)(1) of the

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 25 of 30

failed to sell motor vehicles to consumers in accordance with the terms and conditions it had

advertised, including the advertised price.

107.

Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and

practices in violation of Conn. Gen. Stat. § 42-110b(a).

Count XV

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(b)(6))

(by Plaintiff State of Connecticut against Defendant Chase Nissan)

108.

The allegations of Paragraphs 69, 79, and 84 of Counts VII, VIII, and IX are

incorporated by reference as Paragraph 108 of Count XV as if fully set forth herein.

109.

Defendant Chase Nissan’s acts and practices violate § 42-110b-28(b)(6) of the

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it

advertised prices for the sale of motor vehicles without including in those prices numerous fees

and charges that it later represented to consumers were required to be paid in connection with the

sale.

110.

Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and

practices in violation of Conn. Gen. Stat. § 42-110b(a).

Count XVI

Per Se CUTPA Violation (Conn. Agency Reg. § 42-110b-28(b)(17))

(by Plaintiff State of Connecticut against Defendant Chase Nissan)

111.

The allegations of Paragraphs 69, 79, and 84 of Counts VII, VIII, and IX are

incorporated by reference as Paragraph 111 of Count XVI has if fully set forth herein.

112.

Defendant Chase Nissan’s acts and practices violate § 42-110b-28(b)(17) of the

Regulations of Connecticut State Agencies and constitute per se violations of CUTPA because it

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 26 of 30

made representations or statements of fact in an advertisement when it knew or should have

known that the representations or statements were false or misleading.

113.

Defendant Chase Nissan has therefore engaged in unfair or deceptive acts and

practices in violation of Conn. Gen. Stat. § 42-110b(a).

Count XVII

Civil Penalties

(by Plaintiff State of Connecticut against all Defendants)

114.

The allegations of Paragraphs 69, 79, 84, 89, 94, 99, 102, 105, 108, and 111 of

Counts VII through XVI are incorporated by reference as Paragraph 114 of Count XVII as if

fully set forth herein.

115.

Defendants engaged in the acts and practices alleged herein when it knew or

should have known that its conduct was unfair or deceptive, in violation of Conn. Gen. Stat. §

42-110b(a), and, therefore, is liable for civil penalties of up to $5,000 per willful violation

pursuant to Conn. Gen. Stat. § 42-110o(b).

CONSUMER INJURY

116.

Consumers are suffering, have suffered, and will continue to suffer substantial

injury as a result of Defendants’ violations of the FTC Act and CUTPA. Absent injunctive relief

by this Court, Defendants are likely to continue to injure consumers and harm the public interest.

PRAYER FOR RELIEF

Wherefore, Plaintiffs requests that the Court:

Enter a permanent injunction to prevent future violations of the FTC Act and

CUTPA by Defendants;

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 27 of 30

Award such relief as the Court finds necessary to redress injury to consumers

resulting from Defendants’ violations of CUTPA, including, but not limited to, rescission or

reformation of contracts, restitution, the refund of monies paid, civil penalties and the

disgorgement of ill-gotten monies;

Award the State of Connecticut its attorneys’ fees;

Award the State of Connecticut the costs of bringing this action; and

Award any additional relief as the Court determines to be just and proper.

Respectfully submitted,

Dated: ____________________

__________________________

Samuel Jacobson (phv207659)

Edward Smith (phv207656)

Federal Trade Commission

600 Pennsylvania Ave., NW

Mail Stop CC-10232

Washington, DC 20580

Phone: (202) 876-5590 (Jacobson)

Fax: (202) 326-3768

sjacobson@ftc.gov

esmith2@ftc.gov

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

WILLIAM TONG

ATTORNEY GENERAL

Dated: ____________________

________________________________________

Jonathan J. Blake (Juris no. ct22321)

Michael Nunes (Juris no. ct31522)

Assistant Attorneys General

Office of the Attorney General

165 Capitol Avenue

Hartford, CT 06106

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 28 of 30

Phone: 860-808-5400

Fax: 808-808-5593

Jonathan.blake@ct.gov

Michael.nunes@ct.gov

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 29 of 30

ATTACHMENT A

Case 3:24-cv-00012-JCH Document 18 Filed 01/19/24 Page 30 of 30

Web Data Collection Report

Page Title

Pre-Owned Nissan Rogue in Manchester CT | PC679674A

URL

https://manchestercitynissan.com/vehicles/2021-nissan-rogue-s-pc679674a-5n1at3abxmc831101

Collection Date

Tue Apr 11 2023 10:55:48 GMT-0400 (Eastern Daylight Time)

Browser Information

Mozilla/5.0 (Windows NT 6.2; Win64; x64) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/106.0.0.0 Safari/537.36

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SCREEN CAPTURE

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(!) '335 v;ews

$26,000

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Fuel Efficient

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'✓eh1cle Spec1f1ca-ions

Veh cle Features

Type: Pre Owred

'7" AluminumAlloyWheels

II Speakers

M.1ke: l\lissan

J,1odol: Rogu,

4-Vlfheel Disc Brakes

5.604 Me RatiJ

Trm: S

Doers: 4C Sport Utilit)

ABS brakes

ALL l'VH::EL DRIV::

Exterior: Super 8 ack

Interior. Charcoal

AM/FM ~adio

Al>IIF"1 radio

APFLE CAR-Pl.fl( &A.NDR0I0AUTO

Air CJncitioninJ

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Auto High-beam f-eadlights

M leage: 1(.476

Fuel E :onomy: 26133

Engine: 2.5L 14 0JHC 16V

-ransmission: CVTwilh )itro1ic

Fuel: Goso ine

0ri"8: A\1110

MJdel Code: 220'1

BACK UP CAMERA

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Olack Cplash Cuards (Cet of 4:,

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CLEAN Cfl.RF.WNOA.CCIDENTS

REPORTED

Clott Seat-rim

Delay-off headlig1ts

Driver door bin

Dri"8r ,anily mirror

Dual front impact airbags

Duel front ,ide impact airbags

E ec1ronic Sta bi lily Control

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rron1 anti-roll bar

F'ront read ng lights

Fully automatic headl gh1s

llluninated entry

LOCAL TRAD::

Low :ire pressure ...vamina

J~IS3AN FACTORY CERTIFIEC

ONE OV'/NER

Occupant sensing a rbog

Outs de temperature jisplar

Overhead 3irtag

o,erhead cJnsole

Panic e1arm

P3ssengerdooroIn

Pa55enger vanify mirro,

PJwer door mi Tors

ro\Ner steering

rJwerwindows

REMAll~DER :)F FACTCRYWARRAI\TY

RadiJ data system

Reor seat eerier armrest

Rear sice impact airbag

Reor >MndJw def•os:er

Rearwindo,v v<iper

Renote keyless 3nt1Y

Sleed cont·ol

Speed-Sensitive .Nipers

Sllit folcing rear seat

spoiler

s:ee11ngwreeI mounted audio comro s

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Tele~c.oping 5t~erngwh~el

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=Advertised price on all Certified Nissans include NEMAC Captive Finance Rebate=, Ro~ue S, 40 Sport Utility, 2,5l U OOHC 16V, CVT with Xtronic, AWO,

Super Black, Charcoal Cloth.

At lilanchester City Nissan we want you to know that all our vehicles are priced at a competitive value position to the market We use an independent 3rd

party software to research internet listings on all vehicles in the market so we can ensure that our prices are the most competitive out there, We do this

simply so people choose us when they start searching for their next car,

Priced below KBB Fair Purchase Price!

Clean CARFAlt CARFAX One-Owner,

r.P.rtifiP.rl. Ni.....an r.P.rtifiP.rl OP.t,.il,;:

• 167 Point ln~pection

• Tran.terable Warranty

= Plus 1 Year Pre Paid Maintenance Included.

• Vehicle History

• limited Warranty: 8~ Montb/100,000 Mile (whichever comes fin:t) from original in seovice date

• Warranty Deductible: $100

= Roadside Assistance

Our Soles, Service ~nd Parts Oep~rtenenb work closelv together to provide you with 1he most enjoyable, le~st ,1ressful car-buying experience possible. 11,e

overage tenure for our soles people, m~nogers, technicians oud all o1her employees is over 20 ye ors. Most of them hove been career employees of

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also proud to be a Bener Business Bureau Accredited Business with an A• rating,

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