
“The Justice Department will hold accountable anyone who uses unlawful high-pressure sales tactics and deception to take advantage of and exploit consumers,” said Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division. “Americans deserve to be treated fairly and honestly.”
In a memorandum and order, the district court held that Carroll was at the center of an unlawful enterprise that violated the Federal Trade Commission (FTC) Act’s prohibition on unfair or deceptive trade practices, the federal Cooling-Off Rule’s requirement that consumers be given three business days to cancel certain purchases made at locations other than the seller’s regular place of business, and Wisconsin state laws concerning fraudulent misrepresentations and direct marketing.
The court found that Carroll and his co-defendants used high pressure tactics and false and misleading statements to induce consumers to pay from $5,000 to over $80,000 to businesses including Square One Group LLC, and Consumer Law Protection LLC, for a purported release or exit from the consumers’ timeshare contracts. Carroll and his co-defendants often did not actually provide those services, did not inform consumers of their right to cancel the sales contracts within three business days without penalty, and denied consumers refunds when they or law enforcement officials complained.
Carroll was the final remaining defendant in this action. The court previously also imposed permanent injunctions against seventeen other defendants. Those defendants include several interrelated corporate entities, which were also held liable for the over $140 million monetary judgment against Carroll, and four other individual defendants, who agreed to stipulated orders under which they are collectively liable for over $11 million in monetary penalties, partially suspended due to their demonstrated inability to pay.
The United States is represented in this action by Trial Attorneys Meredith L. Reiter and Zachary L. Cowan and Assistant Director Zachary A. Dietert, from the Enforcement Section of the Civil Division’s Enforcement and Affirmative Litigation Branch, in coordination with staff at the FTC. The United States was previously also represented by former Trial Attorney Wesline N. Manuelpillai. Lewis W. Beilin represents the State of Wisconsin.
For more information about the Enforcement & Affirmative Litigation Branch and its enforcement efforts visit www.justice.gov/civil/enforcement-affirmative-litigation-branch.





