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SEAN REIS (SBN 184044) sreis(ZiJedelson. com EDELSON MCGUIRE, LLP 30021 Tomas Street, Suite 300 Rancho Santa Margarita, California 92688 Telephone: (949) 459-2124 Facsimile: (949) 459-2123 JAY EDELSON* (jedelsoneuedelson. com) RAFEY S. BALABANIAN* (firstname.lastname@example.com) BRADLEY M. BAGLlEN* (email@example.com) CHRISTOPHER L. DORE* (email@example.com) EDELSON MCGUIRELLC 350 North Lasalle Street, Suite 1300 Chicago, Illinois 60654 Telephone: (312) 589-6370 Fax: (312) 589-6378
* Pro
hac vice Application Forthcoming
ATTORNEYS FOR PLAINTIFF AND THE PUTATIVE CLASS UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA MARTHA CORNETT, individually and on behalf of all others similarly situated, Plaintiff, ) Case No.
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DIRECT BRANDS, INC., a Delaware corporation and BOOKSPAN, a Delaware general partnership, Defendants.
) ) )
26 27 28 -CO-M-PL-AIth
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Plaintiff Martha Cornett, for her class action complaint, alleges as follows upon personal knowledge as to herself and her own acts and experiences, and, as to all other matters, upon information and belief, including investigation conducted by her attorneys.
Plaintiff brings this class action complaint against Defendants Direct Brands,
Inc. and Bookspan (collectively "Defendants") based upon their deceptive and unlawful conduct in connection with the design, marketing, and operation of numerous mail-order and online book, music and movie clubs (the "Clubs"). 2. In order to induce consumers to sign up for the Clubs, Defendants offer
introductory, "one-time" deals to new members while intentionally failing to disclose numerous costs, penalty fees, and obligations imposed by Defendants pursuant to a membership agreement that purportedly governs membership in the Clubs (the "Membership Agreement"). 3. Among the purported requirements of the Membership Agreement is that
members must purchase a minimum number of products from the subject club at "regular club prices" in the one-year period following the date of registration. Defendants use these minimum purchase requirements to systematically force members to purchase products from the Clubs at inflated prices and to charge consumers excessive penalty fees for their alleged failure to meet the minimum purchase requirements. 4. However, Defendants lack authority to impose these charges and fees on
consumers because the Membership Agreement is an invalid and unenforceable open price contract. In particular, the Membership Agreement fails to disclose a price, term or clear objective criteria to inform consumers of: a) the costs and consequences of not fulfilling the minimum purchase requirements; b) the actual cost of purchasing products that would fulfill the minimum purchase requirements; and c) which products, when purchased, will fulfill the
minimum purchase requirements. 2 3 4 5 6 7 8 9 10 11 12 13 14 6. California. 7. Defendant Direct Brands, Inc. is a corporation incorporated and existing under 5. Accordingly, Plaintiff: on behalf of herself and all others similarly situated,
brings this action to request a declaration that the Membership Agreement is invalid and unenforceable and to recover monies unlawfully retained by Defendants in connection with their operation of the Clubs. PARTIES Plaintiff Martha Cornett is a natural person and a citizen of the State of
the laws of the State of Delaware with its principal place of business located at 501 Franklin Avenue, Garden City, New York 11530. Direct Brands is a direct-to consumer marketer and seller of book, music, and video products. Direct Brands transacts business throughout the
United States, the State of California, and this District. 8. Defendant Bookspan is a general partnership existing under the laws of the
state of Delaware with its principal place of business located at 501 Franklin Avenue, Garden City, New York 11530. Bookspan is a direct-to consumer marketer and seller of book,
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music, and video products. Bookspan is an affiliate owned and operated by Defendant Direct Brands. Bookspan transacts business throughout the United States, the State of California,
and this District. JURISDICTION & VENUE 9. The Court has subject matter jurisdiction over this action pursuant to the Class
Action Fairness Act of 2005, 28 U.S.C. § 1332(d), because (a) at least one member of the 23 24 25 26 27 28 3 putative class is a citizen of a state different from Defendants, (b) the amount in controversy exceeds $5,000,000, exclusive of interest and costs, and (c) none of the exceptions under that subsection apply to this action. 10. Venue is proper in this District under 28 U.S.C. § 1391(a)(1-2) as Plaintiff
Martha Cornett resides in this District and a substantial part of the events giving rise to the 2 3
claims asserted herein occurred in this District. COMMON ALLEGATIONS OF FACT Defendants' Clubs
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Defendants operate a variety of online, mail-order book and media clubs (the
"Clubs") that purport to offer discounted books, movies, and television shows to registered members. Defendants' network of clubs includes Doubleday Book Club, Book of the Month Club, and Columbia House, among others.' 12. Defendants induce new members to enroll in the Clubs by offering one-time, In order to receive
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introductory "special offers" of highly reduced price books and movies.
the advertised prices, consumers must agree to an open price contract, the terms of which are partially disclosed to consumers only after they select discounted books or movies for purchase, and a material portion of which are never disclosed at all. 13. Unbeknownst to many consumers, Defendants require that members purchase club prices in the year following
multiple books and/or movies at inflated "regular" registration.
Additionally, unbeknownst to all consumers, Defendants also impose penalty
fees on members who fail to fulfil1 these purchase requirements for each of the Clubs. 14. Moreover, Defendants' Clubs rely heavily on a controversial practice known
as negative option billing, a process by which goods are provided automatically to consumers
20 periodically - in the case of Defendants' Clubs, approximately every 3 weeks - and the
21 22 consumer must take affirmative action to stop the shipment or he or she will receive the product and the cost will be directly charged to a credit card on file with Defendants. The
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1 The complete list of Clubs relevant to this complaint is: Black Expressions, Book of the Month, Children'S Book-of-the-Month, Columbia House, Columbia House - TV on DVD, Crafter's Choice, Crossings, Double Day Book Club, Doubleday Large Print, History Book Club, Military Book Club, HomeStyle Books, Insight Out Books, The Literary Guild, Mosaico, Mystery Guild, One Spirit, Rhapsody, Science Fixction Book Club, Scientific American Book Club, The Good Cook.
items shipped by Defendants are not expressly requested or authorized by the recipients. 2 3 4
Numerous consumer protection groups and the FTC have criticized the
practice of negative option billing, as it causes consumers to frequently receive unwanted goods when they are unable to timely decline the unsolicited product.
The Registration Process for Defendants' Clubs
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Defendants maintain functionally identical websites for each of the Clubs, all
of which employ the same methods and procedures to encourage new members to register for the clubs and immediately purchase additional products from Defendants. 17. When consumers first navigate to one of Defendants' websites, they are
encouraged to immediately select several books and/or movies for highly reduced, introductory prices. For example, the landing page for Doubleday Book Club urges
prospective members to select four books for $0.99, and presents an additional "Special Offer" and "Bonus" deal for two additional books for $5.99 each. However, Defendants charge inflated shipping prices ($13.70 for five books) that are nearly double online competitors (e.g. five full size hardcover books from amazon.com ship for $7.95). 18. Prospective members are only able to view the introductory, "special" prices
prior to registering for any of the Clubs. While Defendants require that consumers become members in the subject club to obtain the advertised introductory prices, Defendants do not conspicuously disclose information on what books or movies will cost once their membership term begins. 19. Throughout the entire selection and initial sign up period, Defendants provide
virtually no details regarding the full terms of membership governing the Clubs. Rather, Defendants encourage prospective members to immediately take advantage of the introductory deals and quickly proceed to checkout. Specifically, nowhere on the face of the pages of the Clubs' multi-step registration process does it disclose any the following: (1) that there is a purchase requirement; (2) the time frame in which those purchases must take place;
(3) the cost per item to fulfill the purchase requirement; (4) the penalties for failing to fulfill 2 3 4 5 6 7 8 9 10 11 12 13
any purchase requirement; (5) that "featured selections" will be automatically sent on a periodic basis; (6) that affirmative action will be required to stop the shipments and prevent a consumer from being charged; and (7) the actual cost of any "featured selections." 20. Only after prospective members complete their initial selections, and provide
an of the personal information required for membership, do Defendants present a link to the terms and conditions that purportedly govern membership in the Clubs (the purported terms and conditions, which are functionally identical for all of the Clubs, are identified by Defendants and are referred to herein as the "Membership Agreement"). However, a
consumers' purported assent to the Membership Agreement occurs on a page prior to and separate from the credit card submission page, an intentional design meant to decrease the number of prospective consumers who will actually attempt to read the Membership Agreement.
The Membership Agreement
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Defendants have intentionally designed the Membership Agreement in a
manner intended to confuse and mislead consumers regarding the obligations and costs associated with membership in the Clubs. While Defendants claim to provide the full terms of "Hassle Free Membership" therein, the Membership Agreement is most notable for the information that it fails to provide to consumers. 22. Under the heading "Easy Membership," the terms of the Membership
Agreement purport to require that new members purchase a select minimum number of books at "regular Club prices" in the one-year period following the date of registration. However, the Membership Agreement provides no indication of what "regular Club prices" actually are, forcing consumers to agree to membership in the Clubs without understanding how much they must spend to meet the purchase requirements during the initial membership period. Indeed, Defendants unilaterally set "regular club prices" and the Membership
Agreement allows Defendants' to manipulate those prices to any level without notice and 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
without reference to any objective criteria. 23. Moreover, the Membership Agreement tails to inform consumers of any
penalty, automatic charge, or other consequence that may result from a member's failure to fulfill the purported purchase requirements of the Membership Agreement. Despite this, Defendants systematically charge penalty fees to members who do not meet the purchase requirements within the one-year membership period. 24. In a further attempt to mislead consumers, Defendants fail to conspicuously
inform members that they will receive periodic, unsolicited "featured selections" from Defendants, the price of which will be automatically charged to members who fail to promptly and expressly decline the selection. To discover this material term of membership, consumers must scroll down to the bottom of the Membership Agreement, where Defendants' minimal disclosure appears under the separate misleading heading "Hassle Free Membership." 25. Defendants intentionally designed the Membership Agreement to be deceptive
that it contains two separate headings detailing the terms of the agreement: "Easy
Membership" and "Hassle Free Membership." These two sections are separated by two other headings and do not both visibly appear on the screen simultaneously when the Membership Agreement is opened. The clear impact of this design is that a consumer could read the "Easy Membership" section and understand it to be the total requirements set forth by agreement (although that section itself omits material terms). 26. Additionally, the "Hassle Free Membership" section begins with the word
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FREE in all capital letters and describes the catalogs consumers will receive; buried within that section, however, is a notification that consumers will be required to take affirmative action to prevent being charged on at least a monthly basis. 27. As a result, numerous consumers join the Clubs without knowledge of the fact
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that they must actively monitor their account and communications with Defendants to avoid 2 3 4 5 6 7 8 9 10 ]1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 whether unwanted products and charges. 28. While Defendants fail to conspicuously disclose any information regarding
"regular club prices," the Membership Agreement promises "up to 50%" savings through the purchase of discounted "Club Editions," which Defendants represent to be "full-length
books, sometimes changed in size to save you more." 29. In reality, "Club Edition" copies are substantially inferior in quality to
traditional retail books, with club editions being smaller in size, featuring thinner paper and cheaper, less durable bindings, and using a small, less legible typeface throughout the book. These material deficiencies in the quality of the product are never disclosed to consumers. Operation of Defendants' Clubs 30. Once enrolled in the Clubs, Defendants encourage members to accept their
highly priced "featured selections," while making it difficult for consumers to meet the purported purchase requirements with lower priced selections chosen by members
themselves, which are rarely counted toward the total. 31. When members browse for books or movies, they are given no indication of purchase will count towards the purchase requirements of the
a particular
Membership Agreement.
This includes browsing "clearance" or "reduced price" sections,
adding the items to the online shopping cart, and actually checking out. At each step along the way, Defendants specifically and intentionally omit any warning that these items will not count towards the purchase requirements. Accordingly, members frequently purchase a book
or movie expecting that it will count towards their purchase requirement, only to find out too late that it did not. 32. Even more flagrantly, if consumers know to visit the "featured selection"
section of their Clubs' website, they are provided an opportunity to "buy it now" and accept the "featured selection" at a reduced price rather than regular club price. On information and
belief, if a consumer purchases a "featured selection" at the reduced price, the item will not 2 3 4 5 6 7 8 9 10 11 12 ]3 14 15 16 17 18 19 20 21 22 23 24 25 26 count towards their minimum purchase requirements. disclosed to consumers. This material difference is not
This effectively punishes a customer for actively monitoring their
account and following Defendants' suggestions. 33. Defendants' "featured selection" system is further designed to increase the
likelihood that consumers will not deny the offerings in a timely manner and be forced to receive and pay for books they do not want. Such tactics include sending multiple "featured selections" as many a three or four in a one-month period - in contrast to Defendants' own This requires members to constantly return to the Club's website or
Membership Agreement.
contact Defendants by phone to deny the selection. 34. Likewise, each "featured selection" often includes more than just a single
book or movie, commonly two, and potentially as many as four. This again runs afoul of Defendants' own Membership Agreement, which describes the "featured selection" as a Based on consumer experience, members may receive notice of four
single "selection,"
impending selections, two of which can be denied by email, and two others that must be denied through the Club's website or over the phone. Accordingly, if a consumer fails to
deny a set of four books, the member may include charges as high as $80. 35. To add to consumer frustration, even though members are instructed to call or
use the website to deny the "featured selection," a customer service number is extremely difficult to find and requires members to locate a link among fifty-one others on the help page (oddly, the contact phone number is not listed on the "contact us" page). consumers regularly complain that requests, questions, and complaints Likewise,
go completely
unanswered through Defendants' customer service email. 36. Even if a consumer can navigate all of these hurdles, denial of featured
selections as well as cancellation requests are regularly ignored, resulting in unsolicited and unwanted goods, in addition to unauthorized charges.
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37. 2 3 4 5 6
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As the end of a yearly membership approaches, Defendants do not notify
members if they have satisfied all the purchase requirements during the membership period. Nor do Defendants warn members that they are in danger of failing to meet the purchase requirements. 38. Accordingly, consumers are left with little control over their compliance with
the purchase requirements of the Membership Agreement, outside of simply accepting Defendants' highly priced featured selections. 39. Defendants unilaterally determine whether a member has met the purchase
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requirements of the Membership Agreement at the conclusion of the member's initial oneyear membership term. If Defendants conclude that a consumer has failed to purchase a sufficient number of books or movies at "regular Club prices," Defendants immediately and without warning charge the credit or debit card on file for that consumer for the purported value of the books, plus shipping and handling charges. 40. Specifically, after Defendants charge consumers, Defendants send a letter
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providing the consumer a chance to pick books or movies in exchange for the charge already placed on their account. Defendants only provide a limited list to choose from, and notably, the total charge is unrelated to and disconnected from the actual price of books chosen. This means that a consumer is charged an inflated penalty price regardless of what books or movies are chosen. Defendants never disclose this penalty to consumer during or after the registration process, and consumers only become aware after they are charged.
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41. 23 24
www.doubledaybookclub.com, a website owned and operated by Defendants. Pursuant to Defendants' introductory deal, Plaintiff selected five books for purchase and was charged a totalof$14.69.
Plaintiff believed that she was required to purchase three additional books to
fulfill her membership 2 3
Defendants did not disclose how much the three
additional books would cost or what would occur if she failed to meet the purchase requirements. 43. On or about July 21, 2010, Plaintiff placed an order through
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for three additional books. Plaintitfbelieved
that the purchase of
these books would satisfy her additional purchase requirements
under the Membership
Agreement, and Plaintiff was not informed otherwise by Defendants at the time of purchase. 44. On or about December 17, 2010, Plaintiff placed an order through
for two additional books.
Plaintiff believed that the purchase of under the
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these books would satisfy, and exceed, her additional purchase requirements
Membership Agreement, and Plaintiff was not informed otherwise by Defendants at the time of purchase. 45. Because Plaintiff had purchased five books during her initial one-year
membership period, she did not believe that she was required to purchase additional books prior to June 20,2011. 46. On or about June 22, 2011, Plaintiff received an unsigned letter from
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"Doubleday Book Club" informing her that Defendants "recently applied a charge of$63.63" to Plaintiffs [Plaintiffs] 47. credit card representing membership agreement." Plaintiff did not authorize Defendants to charge her credit card as described in "the three remaining books required to complete
the June 22, 2011 letter. Prior to her receipt of the letter, Plaintiff was given no notice that Defendants intended to charge her credit card or that Plaintiffhad failed to meet the purchase
requirements of the Doubleday Book Club Membership Agreement. 48. The letter further informed Plaintiff that she could select three books from an for [Plaintiffs] payment." Defendants requested that
enclosed brochure in "consideration
Plaintiff communicate her order through the mail.
49. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 52.
Plaintiff was not interested in any of the selections provided in the enclosed at the
brochure. Shortly thereafter, Plaintiff contacted a customer service representative
phone number provided in Defendants' June 22,2011 letter, and was informed that she could pick three books from the Doubleday website. Plaintiff selected three books, bringing her
total purchased books to eight for the year, not including the initial five she purchased during registration. 50. The price of each book Plaintiff chose was $10.99, plus shipping and handling. When Plaintiff complained that the $63.63 charge was far too high based on a
per book cost of $10.99, she was informed that the cost of each book did not matter and that the charge of$63.63 would remain on Plaintiffs and informed Plaintiff that she was required credit card. Defendants refused any refund to pay $63.63 to fulfill her purchase
commitment under Plaintiffs membership agreement. 51. Prior to receiving the June 22,2011 letter, Plaintiff was never informed of the
amount she would be charged for "required purchases" under her Membership Agreement with Doubleday Book Club. CLASS ACTION ALLEGATIONS Plaintiff Martha Cornett brings this action pursuant to Federal Rule of Civil
Procedure 23(b )(2) and Rule 23(b )(3) on behalf of himself and a Class defined as follows:
Club Class: All persons in the United States who enrolled in Defendants' Clubs online. Penalty SubClass: All members of the Club Class who have been charged by Defendants for failure to fulfill their membership commitment.
Excluded from the Classes are Defendants, their legal representatives, assigns, and successors, and any entity in which Defendants have a controlling interest. Further excluded are Plaintiff's attorneys. Also excluded is the judge to whom this case is assigned and the
judge's immediate family. 2 3 4 5 6 7 8 9
Upon information and belief, there are thousands of persons in the Classes,
such that joinder of all members is impracticable. 54. Plaintiff will fairly and adequately represent and protect the interests of the
Class members. Plaintiff has retained counsel with substantial experience in prosecuting complex litigation and class actions. Plaintiff and his counsel are committed to vigorously prosecuting this action on behalf of the members of the Classes, and have the financial resources to do so. Neither Plaintiff nor his counsel have any interest adverse to those of the other members of the Classes. 55. Absent a class action, most members of the Classes would find the cost of The class
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litigating their claims to be prohibitive, and will have no effective remedy.
treatment of common questions of law and fact is also superior to multiple individual actions or piecemeal litigation in that it conserves the resources of the courts and the litigants, and promotes consistency and efficiency of adjudication. 56. Defendants have acted and failed to act on grounds generally applicable to the
Plaintiff and the other members of the Classes in transmitting the wireless spam at issue, requiring the Court's imposition of uniform relief to ensure compatible standards of conduct toward the members of the Classes. 57. The factual and legal bases of Defendants' liability to Plaintiff and to the other
members of the Classes are the same, resulting in injury to the Plaintiff and to all of the other members of the Classes as a result of the unlawful conduct alleged herein. Plaintiff and the other Class members have all suffered harm and damages as a result of Defendants' unlawful and wrongful conduct alleged herein.
There are many questions of law and fact common to the claims of Plaintiff
and the other members of the Classes, and those questions predominate over any questions 26
that may affect individual members of the Classes. Common questions for members of the
Classes include but are not limited to the following: 2 3 4 5 6 7 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 59. forth herein. 60. For the reasons detailed throughout this complaint, and stated below, the FIRST CAUSE OF ACTION Declaratory Relief -Invalidity of Membership Agreement (d) (e) (f) (g) (h) (c) (b) (a) Whether Defendants' Membership Agreement is invalid and unenforceab le; Whether Defendants' conduct alleged herein constitutes violations of Cal. Civ. Code §§ 1750, et seq.; Whether Defendants' conduct alleged herein constitutes violations of Cal. Bus. & Prof. Code §§ 17200, et seq.; Whether Defendants' conduct constitutes fraud by omission; Whether Defendants' conduct constitutes fraud in the inducement; Whether Defendants' conduct constitutes negligent misrepresentation; Whether Defendants' conduct constitutes unjust enrichment; Whether Defendants' conduct alleged herein constitutes violations of CaL Civ. Code. § 1671.
(Individually and on behalf of the Class and SubClass) Plaintiff incorporates by reference the foregoing allegations as if fully set
Membership Agreement is invalid and unenforceable. 61. The Membership Agreement contains open price terms that are not stated in Specifically, the Membership
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connection without any objective method of determination.
Agreement does not contain a price, term or clear objective criteria to: a. Inform consumers of the cost and consequences of not fulfilling
the purchase requirements;
Inform consumers of the actual cost of purchasing products to
fulfill the purchase requirement; c. Inform consumers of which products, when purchased, will
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fulfill the purchase requirements; d. Inform consumers of the cost and consequences of failing to
deny a "featured selection." 62. Moreover, the Membership Agreement allows Defendants to unilaterally set
"regular club prices" and Defendants are free to alter those prices without notice and without reference to any objective criteria. 63. Members of the Classes and Defendants have adverse legal interests, and there
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is a substantial controversy between members of the Classes and Defendants of sufficient immediacy and reality to warrant the issuance of a declaratory judgment Defendants' Classes. 64. Plaintiff desires a judicial determination of the respective rights and duties of as to whether
Membership Agreement is invalid and unenforceable against Plaintiff and the
Plaintiff and Defendants with respect to the Membership Agreement and a declaration that Defendants' Membership Agreement is invalid and unenforceable. 65. Pursuant to Code of Civil Procedure 1060, such a declaration is necessary and
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appropriate at this time in order that Plaintiff and Defendants may ascertain their relative rights and duties with respect to the Membership Agreement. SECOND CAUSE OF ACTION Violation of the Consumer Legal Remedies Act Cal. Civ. Code § 1750 et seq. (Individually and on behalf of the Class and SubClass} 66. forth herein. Plaintiff incorporates by reference the foregoing allegations as if fully set
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67. 2 3 4 5 6 7 8 9 10 11 12 13
The Consumers Legal Remedies Act ("CLRA") by any person of any deception,
prohibits the act, use or misrepresentation,
fraud, false pretense,
concealment, suppression, or omission of any material fact with intent that others rely upon such act in connection with the sale or advertisement of any merchandise whether or not any person has in fact been misled, deceived or damaged thereby. 68. The CLRA applies to Defendants' actions and conduct as described herein
because it extends to transactions that are intended to result, or which have resulted, in the sale of goods or services to consumers. 69. 70. Defendants are "persons" as defined by CaL Civ. Code § 1761(c). Plaintiff and each member of the Classes are "consumers" as defined by CaL
Civ. Code § 1761(d). 71. Defendants' Clubs and the products provided therefrom are "goods" and/or
"services" within the meaning of CaL Civ. Code § 1761(a) and (b), respectively. 72. As described herein, Defendants have engaged in deceptive practices,
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unlawful methods of competition, andlor unfair acts as defined by Cal. Civ. Code §§ 1750 et seq., to the detriment of Plaintiff and the Classes. 73. Defendants, acting with knowledge, intentionally and unlawfully brought
harm upon Plaintiff and the Classes by deceptively inducing Plaintiff and the Classes to sign up for its Clubs without fully disclosing the terms of membership and the costs to be borne by members. 74. Specifically, Defendants violated Cal. Civ, Code § 1750 in at least the
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following respects: a. In violation of § 1770(5), representing that the Clubs has characteristics,
ingredients, uses, benefits, or quantities which it does not have. b. In violation of § 1770(7), representing that the Clubs are of a particular standard, quality, or grade of which they are not.
In violation of § 1770(9), advertising the Clubs with the intent not to sell them as advertised.
3 4 75.
unfair or deceptive acts or practices
occurred repeatedly
Defendants' business, and were capable of deceiving a substantial portion of the public who registered for Defendants' Clubs. 76. The facts misrepresented and/or omitted by Defendants to Plaintiff and the
Classes are material in that a reasonable consumer would have considered them to be important in deciding whether to purchase products from Defendants and join Defendants' Clubs. Had Plaintiff and the Class known the full extent of the membership terms of the
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Clubs, the consequences for not meeting the purported purchase requirements, and the full costs of fulfilling the Membership Agreement, they would not have purchased goods from Defendants or joined the Clubs. 77. The fun terms of membership in Defendants' Clubs, including the costs of
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fulfilling the membership requirement and the penalty for failing to fulfill the membership requirement, is and was a material consideration for consumers in deciding whether to join Defendants' Clubs.
Defendants' false representations and omissions about the Clubs were likely
to mislead Plainti ff and the members of the Classes. 79. As a direct and proximate result of Defendants' violation of CaL Civ. Code §
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1750, et seq., Plaintiff and each member of the Classes have suffered harm in the form of monies paid to Defendants. Plaintiff: on behalf of herself and the Classes, seeks injunctive
relief For the sake of clarity, Plaintiff explicitly disclaims any claim for damages under the 23
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CLRA at this time.
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Violation of the Unfair Competition Law Cal. Bus. & Prof. Code § 17200 et seg (Individually and on behalf of the Class and SubClass) 80. forth herein. 81. California's Unfair Competition Law ("DCL") protects both consumers and Plaintiff incorporates by reference the foregoing allegations as if fully set
competitors by promoting fair competition in commercial markets for goods and services. 82. The DCL prohibits any unlawful, unfair or fraudulent business act or practice. unfair
A business practice need only meet one of the three criteria to be considered competition.
An unlawful business practice is anything that can properly be called a business
practice and that at the same time is forbidden by law. 83. As described above, Defendants have violated the unlawful prong of the UCL
by violating the CLRA. 84. As described herein, Defendants have violated the unfair prong of the UCL by
inducing Plaintiff and members of the Classes to sign up for Defendants' Clubs and purchase products from Defendants. As described herein, Defendants failed to disclose the full terms
of membership of the Clubs, including the requirements needed to fulfill the membership commitment and the consequences from failing to fulfill the purchase requirements. The
injuries caused by Defendants' conduct are not outweighed by any countervailing benefits to consumers or competition, and Plaintiff and members of the Classes could not have
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reasonably avoided the injuries they sustained. 85. As described herein, Defendants have also violated the fraudulent prong of the
UCL by knowingly and willfully making false and misleading statements, and failing to disclose material terms, regarding the terms of membership of Defendants' Clubs. 86. Defendants' false representations and omissions were likely to mislead and
Plaintiff and members
of the Classes acting reasonably
under the circumstances,
constitute a deceptive trade practice in violation of the VCL. 2 3 4 5 6 7 8 9
As a direct and proximate
result of Defendants'
unfair, and
fraudulent acts, Plaintiff and each member of the Classes have suffered injury in fact and lost money by joining Defendants' Clubs and buying books and media from Defendants. 88. Pursuant to Cal. Bus. & Prof. Code § 17203, Plaintiff seeks an order enjoining
Defendants from continuing to engage in the unfair and unlawful conduct described herein. Plaintiff seeks an order requiring Defendants to (1) immediately cease the unlawful practices alleged in this Complaint; (2) make full restitution of all funds wrongfully obtained; and (3) pay interest, attorneys' fees, and costs pursuant to Cal. Code Civ, Proc. § 1021.5. FOURTH CAUSE OF ACTION Fraud by Omission (Individually and on behalf of the Class and SubClass) 89. forth herein. 90. Based on Defendants' material omissions, Plaintiff and members of the Plaintiff incorporates by reference the foregoing allegations as if fully set
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Classes were not informed of the full terms of membership prior to joining Defendants' Clubs, including but not limited to the fact that numerous purchases would not count toward satisfying the membership purchase requirements, the regular price of books and media that satisfied members' purchase requirements, and the consequences of failing to fulfill purchase requirements at the end of a one-year period of membership. 91. Defendants knew that they concealed from and failed to disclose to Plaintiff
and members of the Classes the full terms of membership of the Clubs. 92. Defendants were under a duty to disclose to Plaintiff and the members of the
Classes the full terms of membership in the Clubs, including the regular price of books and media that could be used to fulfill members' purchase requirements and the consequences of failing to meet such purchase requirements, because: (1) Defendants were in a superior
position to know the true state of facts regarding the Membership Agreement; (2) Plaintiff 2 3 4 5 6 7 8 9 10
and class members could not reasonably have been expected to learn or discover that they were not presented with the fun terms of membership prior to joining the Clubs; and (3) Defendants knew that Plaintiff and members of the Classes could not reasonably have been expected to learn or discover the full terms of membership prior to joining the Clubs. 93. The facts concealed or not disclosed by Defendants to Plaintiff and the
Classes are material in that a reasonable consumer would have considered them to be important in deciding whether to join Defendants' Clubs. 94. Plaintiff and members of the Classes justifiably relied on the omissions of
Defendants to their detriment. 95. That detriment is evidenced from the monies paid from Plaintiff and Class
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Members to Defendants. 96. As a direct and proximate result of Defendants' misconduct, Plaintiff and the
Classes have suffered and will continue to suffer actual damages in the form of monies taken by Defendants. FIFTH CAUSE OF ACTION Fraud in the Inducement (Individually and on behalf of the Class and SubClass) 97. forth herein. 98. As described herein, Defendants misrepresented andlor failed to disclose Plaintiff incorporates by reference the foregoing allegations as if fully set
material provisions of the Membership Agreement, including the price of books and media required to be purchased during the member's commitment term and the consequences of
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failing to meet the purchase requirements of the Membership Agreement. 99. Through the misrepresentations and omissions detailed herein, Defendants
wrongfully induced Plaintiff and the Class to join the Clubs and subsequently purchase books
from andlor pay penalty fees to Defendants. 2 3 4 5 6 7 8 9 10 1] 12
13 14 15
Defendants knew or should have known that its misstatements and omissions
regarding the terms of membership of the Clubs rendered the Membership Agreement incomplete and misleading to Plaintiff and the Class. 101. Defendants intended that consumers rely upon their misstatements and
omissions regarding the Membership Agreement. 102. In deceiving Plaintiff and members of the Classes regarding the full terms of
membership in the Clubs, Defendants have engaged in fraudulent practices designed to induce consumers to register for Defendants' Clubs. 103. As a proximate result of Defendants' violations oflaw and wrongful conduct
alleged herein, Plaintiff and members of the Classes have suffered damages in the form of monies paid to Defendants.
SIXTH CAUSE OF ACTION Negligent Misrepresentation (Individually and on behalf of the Class and SubClass)
16 17 18 19 20 21 22 23 24 25 26
104. forth herein. 105.
Plaintiff incorporates by reference the foregoing allegations as if fully set
Through its public representations and omissions, Defendants failed to
disclose the full terms of membership governing Defendants' Clubs, including the price of books and media required to be purchased under the Membership Agreement, the price of products automatically sent to Plaintiff and members of the Classes via the catalog, and the consequences or damages imposed for failing to fulfill the purchase requirements of the Membership Agreement. 106. At all material times, Defendants knew or should have known of their failure
to fully disclose an material terms of the Membership Agreement. 107. Defendants intended that Plaintiff and the members of the Class rely on their
misrepresentations and omissions by joining Defendants' Clubs. 2 3 4 5 6 7 8 9
10 11
Plaintiff and members of the Classes justifiably relied on Defendants'
representation that the terms disclosed on Defendants' websites represented the full terms of membership governing Defendants' Clubs, and were unaware of additional terms at the time that they agreed to join the Clubs. 109. As a direct and proximate result of Defendants' misrepresentations and
omissions, Plaintiff and members of the Classes suffered damages in the form of monies paid to Defendants.
SEVENTH CAUSE OF ACTION Uniust Enrichment (Individually and on behalf of the Classes)
12 13 14 15 16 17 18 19 20 21
110. forth herein. 1] 1.
Plaintiff incorporates by reference the foregoing allegations as if fully set
Plaintiff and the Classes have conferred a benefit upon Defendants.
Defendants have received and retained money belonging to the Plaintiff and the Classes as a result of its unlawful and deceptive practices. 112. 113. Defendants appreciate or have knowledge of said benefit Under principles of equity and good conscience, Defendants should not be
permitted to retain money belonging to Plaintiff and the Classes that it unjustly received as result of its actions. 114. Plaintiff and members of the Classes have suffered financial loss as a direct
result of Defendants' conduct. 23 24 115. Plaintiff: on behalf of herself and the Classes, seek restitution for Defendants'
unlawful conduct.
27 28 22
3 4 5 6 7 116.
Alternative Claim for Violation of Cal. Civ. Code § 1671 (On behalf of Plaintiff and the SubClass) Plaintiff incorporates by reference the forgoing allegations, excluding
paragraphs 110-115. 117. In the alternative to Count Seven, Defendants' unilateral charging of Plaintiff
and members of the SubClass a cost above and beyond the actual costs of the items necessary to fulfill any Membership Agreement obligations are prohibited penalties in violation of Cal. Civ.Code§167I. 118. The imposition of an unstated penalty fee for a failure to purchase the a
9 10 11 12 13 14
certain number of products within a single year constitutes a prohibited penalty in the case of a customer's breach under Cal. Civ. Code. § 1671. 119. Imposing additional charges above and beyond the cost of items purchased yearly quota is unreasonable in light of the
from Defendants to complete a consumer's
16 17 18 19 20 21 22 23 24 25 26
circumstance existing at the time the contract was made. No such requirement existed at that time. Defendants' Membership Agreement specifically omits any provisions related to what will happen if a customer fails to purchase the necessary amount of items in a single year. 120. Plaintiff and members of the SubClass utilized Defendants' services for
consumer, and not business, purposes. 121. To the extent the contract is considered one for the retail purchase of personal
services primarily for personal purposes, even if there were an express contractual provision allowing for the imposition of the penalty fees, the fees are impermissible given the nature of the case because it would not be impracticable or extremely difficult to fix the actual damage that Defendants would experience from a customer's quota. 122. failure to fulfill her yearly purchase
As an actua1 and proximate result of Defendants' imposition of the unlawful
penalties, Plaintiff and the SubClass suffered actual damages in the amount of the fees,
2 3
4 5
interest, lost opportunity, and other actual and consequential damages. 123. Plaintiff, individually and on behalf of the SubClass, respectfully pray for a
declaration that Defendants' charges above and beyond the cost of items necessary to fulfill its Membership Agreement is an unlawful penalty in violation of Cal. Civ. Code § 1671, and award actual and consequential damages in an amount to be proven at trial, plus interest, costs, and reasonable attorneys fees. PRAYER FOR RELIEF WHEREFORE, Plaintiff Martha Cornett, on behalf of herself, the Class, and SubClass, prays for the following relief: 1. An order certifying this case as a class action on behalf of the
7 8 9 10
12 13 14 15 16 17 18
Class and SubClass as defined above; appointing Plaintiff Cornett as the Class Representative of the Class and SubClass; and appointing her counsel as Class Counsel; 2. Declare that Defendants' Membership Agreement is invalid and
unenforceable as against Plaintiff and members of the Classes; 3. Declare that Defendants' actions, as set out above, violate Cal.
Bus. & Prot: Code §§ 17200 et seq., Cal. Civ. Code §§ 1750 et seq., Cal. Civ. Code § 1671, and constitute unjust enrichment, negligent misrepresentation, fraud by omission, and fraud in the inducement. 4. Award injunctive relief as necessary to cease Defendants'
20 21
23 24 25
unlawful conduct as described herein; 5. 6. 7. just. Award Plaintiff and the Classes actual damages and costs; An award of reasonable attorneys' fees and costs; and Such further and other relief the Court deems reasonable and
Plaintiff requests trial by jury of all claims that can be so tried.
Dated: August 4, 2011
Respectfully submitted,
7 8 9
SeanP. Rel One of the Attorneys for Plaintiff
II 12 13 14 l5 16 17 18 19 20 21
JAY EDELSON* (firstname.lastname@example.com) RAFEY S. BALABANIAN* (rbalabanian@edelson. com) BRADLEY M. BAGLIEN* (firstname.lastname@example.com) CHRISTOPHER L. DORE* (firstname.lastname@example.com) EDELSON MCGUIRELLC 350 North LaSalle Street, Suite 1300 Chicago, Illinois 60654 Telephone: (312) 589-6370 Fax: (312) 589-6378 * Pro hac vice Application Forthcoming SEAN REIS (SBN 184044) email@example.com EDELSON MCGUIRE, LLP 30021 Tomas Street, Suite 300 Rancho Santa Margarita, California 92688 Telephone: (949) 459-2124 Facsimile: (949) 459-2123
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El Presidente
And the answer is Ela Rose. This was her Grammy's outfit. Preposterous in an unbelievably awesome way. Just ass out of the boys.
"Give me two 225 pound black guys built like tanks and my uncle going at it and I'm happy" – bowler32
God bless her father and the years of mental scars he inflicted.
Her date's skin tone is the least surprising news of the day.
That red carpet dude looks like such a tool
Wish I had the dick for an ass like that
I would suck on her pooper until last weeks breakfast came out
"Ass out of the boys" – Must have had Bieber on your mind Pres.
Yes there are nudes, Google away
Solid turd cutters
What is that thing she went with?
She's dating an other, shocker
Every "Her dad must be on a ledge" commenter will have a daughter that fucks blacks/light-skinneds/caramels/darks.
really hope "ass out for the boys" becomes a thing (and only hope girls do it- I'm no big cat)
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Fresh flashy 2 yr old filly. Green broke. Fast but lazy. Needs work. Calm as a 2 yr old can be. Need to move, but not in a hurry. Would trade. Been on…$500
Beautiful and confident gelding. Spunky and fast as any race horse. Qh grade. Been on the barrels and at rodeos. Just don't get along with him. Wanting…$550
Meet Artie, Bay Thoroughbred gelding Born in April 2004 Artie is a Jumping/Dressage gelding, reg. Name (Party Hardy Artie) He Schools around 3'6…$2,500
If your looking for a horse with plenty of color and a funny personality you've found her. She loves getting attention and is currently being worked with…$2,500
This outstandingly gorgeous colt is truly blue blooded! He is homozygous for both the roan gene and the black gene. Every foal by "He's Blue Blooded" will…Stud Fee: $600
This is a 10 yr old PAINT GYPSY VANNER CROSSBRED mare that is broke to ride & drive. This mare stands 15.1 hands tall. She rides gentle for all level…$2,500
This is FLASHY OPINION, an APPENDIX REGISTERED AQHA sorrel mare that is well broke to ride. This mare has been patterned on the barrels and hauled to the…$2,000
15.2 hh, 13 yr old, black appendix gelding for sale! If you're looking for a " been there, done that" kind of horse, look no farther! Blackjack is an excellent…$3,500


text:
VIP Access™ Hotel
We carefully hand-picked this hotel based on its dedication to service and excellent guest reviews.
Orbitz Platinum members receive free room upgrades and Platinum and Gold members get other perks upon availability at check-in.See details
Located in 600 Hectareas, La Cantera Jungle Lodge is within 2 miles (3 km) of sights such as Aripuca and Punto Iguazu Shopping Mall. This 30-room, 4-star hotel has free breakfast along with conveniences like an outdoor pool and free in-room WiFi. It's near the airport and also near Guira Oga and Imagenes de la Selva.
Free hot/cold buffet breakfast is included with your stay. Sit down for a leisurely bite to eat at the onsite restaurant, or enjoy a drink at the bar/lounge. Order from room service to satisfy your hunger without leaving your room.
All of La Cantera Jungle Lodge's 30 rooms are recently renovated and have an array of amenities, including balconies, phones, and desks. Guests can enjoy free WiFi and cable TV. Rooms also include free toiletries.
Property features
Guests staying at La Cantera Jungle Lodge enjoy an outdoor pool, a rooftop terrace, and free WiFi in public areas. There's free parking if you drive. The 24-hour front desk has multilingual staff ready to assist with dry cleaning/laundry, concierge services, and luggage storage. Other amenities at this boutique hotel include laundry facilities and a garden.
- Free hot/cold buffet breakfast
- Free WiFi in rooms and public areas
- Free parking
- Onsite dining
La Cantera Jungle LodgeSelva Iriapu Misiones Iguazu Misiones 33700
Hotel Amenities
Hotel Amenities
The hotel offers a restaurant. A bar/lounge is on site where guests can unwind with a drink. A complimentary breakfast is offered. High-speed wireless Internet access is complimentary.
This boutique hotel also offers an outdoor pool, a rooftop terrace, and spa services. Complimentary self parking is available on site.
- 24-hour front desk
- Total number of rooms - 30
- Bar/lounge
- Concierge services
- Dry cleaning/laundry service
- Tours/ticket assistance
- Free WiFi
- Laundry facilities
- Multilingual staff
- Rooftop terrace
- Garden
- Luggage storage
- Restaurant
- Free self parking
- Spa services on site
- Outdoor pool
- Free breakfast
Family Friendly Amenities
- Family Hotel
- Outdoor pool
- Free Wi-Fi
- Laundry facilities
- Cribs/infant beds (complimentary)
Available in all rooms: Free WiFi
Available in some public areas: Free WiFi
Free self parking
Room Amenities
- Balcony
- Air conditioning
- Phone
- Daily housekeeping
- Free toiletries
- Desk
- Cable TV service
- Free WiFi
- Room service (limited hours)
- Free cribs/infant beds
Where to Eat
Guests are offered a complimentary hot/cold buffet breakfast.
Onsite venue - This restaurant serves breakfast, lunch, and dinner.
Room service (during limited hours) is available.
Nearby Things to Do
The recreational activities listed below are available either on site or nearby; fees may apply.
- Hiking/biking trails nearby
Spa Services
- Massages
Hotel Policies
Check-in time starts at 2 PM
Check-in time ends at midnight
Minimum check-in age is 18
Check-out time is 10 AM
Payment types
- Pets not allowed
You need to know
Extra-person charges may apply and vary depending on hotel policy.
Government-issued photo identification and a credit card or cash deposit are required at check-in for incidental charges.
Special requests are subject to availability upon check-in and may incur additional charges. Special requests cannot be guaranteed.
No rollaway/extra beds available
Hotel Name
- Cantera Jungle Lodge
- La Cantera Jungle
- La Cantera Jungle Iguazu
- La Cantera Jungle Lodge
- La Cantera Jungle Lodge Iguazu
- La Cantera Jungle Hotel Puerto Iguazu
- Cantera Jungle Lodge Iguazu
- Cantera Jungle Iguazu
- Cantera Jungle
We should mention
Children 2 years old and younger stay free when occupying the parent or guardian's room, using existing bedding.


text:
• Three hundred eight patients who underwent operation for hyperparathyroidism were studied. Fifty-two (17%) were identified who had a concomitant thyroid nodule. All 52 underwent parathyroidectomy and thyroid resection in a single operation. Eleven of these patients (21% of those with a thyroid nodule) had differentiated thyroid cancer. One patient with parathyroid hyperplasia developed permanent hypocalcemia. None had permanent vocal cord paralysis and none required tracheostomy. Thorough visual inspection and palpation of the entire thyroid gland should be performed during operations for hyperparathyroidism. Incidentally discovered thyroid nodules should prompt formal lobectomy with frozen section diagnosis; unanticipated thyroid malignancies should then be treated as independent entities. Treating simultaneous hyperparathyroidism and nodular thyroid disease with a single operation can be done safely; it avoids the expense and risk associated with neck reexploration and can detect unsuspected cancers.
(Arch Surg. 1990;125:1327-1331)
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Honorary Degree Recipients
Dear Knox Community,
It is my privilege today to announce this year's honorary degree recipients, who will receive their degrees at the College's Commencement exercises on June 5. In addition to our Commencement speaker United States Senator Dick Durbin, Knox will confer honorary degrees on Brenda J. Child, a leading scholar of American Indian history, [...]
Alumni Hall is LEED Gold
Dear Knox Community,
I'm delighted to share with you the wonderful news that Alumni Hall has been awarded LEED Gold certification. As some of you may know, LEED stands for Leadership in Energy and Environmental Design. This green building rating system, developed by the U.S. Green Building Council, measures the extent to which a building [...]
Campus water testing update
On April 13, I wrote to the campus with information on the Knox College water supply, noting that the College had made arrangements to test the water in all College buildings serviced by older water lines. This morning, I received the results of those tests from an independent laboratory and am writing to share the [...]
April is Sexual Assault Awareness month
Dear Knox Community,
April is Sexual Assault Awareness month. Since 2001, SAAM (Sexual Assault Awareness Month) has been organized and promoted nationally by the National Sexual Violence Resource Center (NSVRC), with a teal ribbon and a themed campaign designed to be positive and action-oriented, with concrete tools to help end violence. Each year the [...]
Campus water quality update
Over the weekend, some of you may have seen the Associated Press (AP) article regarding lead in Galesburg's drinking water, as well as additional coverage in our local and regional media. Facilities Services has received a few questions from members of the community regarding Knox's water, and I'd like to provide the full campus with [...]
Reminder: Knox 101, April 12
Dear Knox Community,
This special session of the Knox 101 series will focus on a broader liberal arts college landscape and how the Knox educational experience fits within it. Why do students choose one college over another? What more can Knox do to attract and retain students? How are other schools innovating to integrate learning [...]
Knox 101: Series Special Session, April 12
Dear Knox Community,
This special session of the Knox 101 series will focus on a broader liberal arts college landscape and how the Knox educational experience fits within it. Why do students choose one college over another? What more can Knox do to attract and retain students? How are other schools innovating to integrate learning [...]
Galesburg Portrait Project Unveiling, March 31
We hope many of you will be able to join us at the Box, Kellogg and Simmons Streets, on Thursday, March 31, from 5-7 for the 'unveiling' of the Galesburg Portrait Project. There will be a time for brief remarks by the artist and others, starting about 6:15 p.m.
At 7 p.m., (following the [...]
Galesburg residents are invited to attend one of these focus groups:
The City of Galesburg and the Galesburg Downtown Council are seeking community members who have an interest in downtown public improvements. The project will focus on a geographically defined downtown area and will look at the streets, sidewalks, public parks, plazas and parking areas. [...]
Rep Term XVII Peformances
The Repertory Theatre Term XVII productions of Neil Gaiman's Neverwhere and The Secret in the Wings continue to perform through Saturday.
adapted by Robert Kauzlaric
directed by Liz Carlin-Metz
video trailer = https://www.youtube.com/watch?v=-Z3icbuhJIY
Under the streets of London there's a city inhabited by the people who [...]
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Senior Database Specialist
Leader Communications Incorporated (LCI) - Washington, DC
The DBA manages and maintains the Oracle 11.2/12.1 databases including Grid Infrastructure:. Works closely and collaborate with other members of DBA middleware...
Oracle DBA
Common Securitization Solutions - Bethesda, MD
We are seeking a talented Oracle DBA who has experience in performing the following activities:. Professional IT experience of 8+ years with minimum 3 years of...
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CGI - Herndon, VA
We have an immediate need for an Application DBA to join our financial services team in Herndon, VA. Shared Services plays the backend DBA role i.e. database...
Softthink Solutions, Inc. - Reston, VA
PostgreSQL Database DBA will be responsible for installation, designing, development, maintenance, administration of physical PostgreSQL ORDBMS within GSA-s SAM...
SQL Server DBA, Infrastructure
Common Securitization Solutions - Bethesda, MD
Common Securitization Solutions (CSS) is seeking an experienced SQL DBA to join our team of talented professionals in Bethesda, MD....
Database Administrator (DBA)
CGI - Manassas, VA
Join the CGI Federal team! CGI Federal is looking for a Database Administrator (DBA) to support operations at our Manassas, VA location. Other potential
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CGI - Crystal City, VA
Oracle DBA administration. DBA experience for both COTS applications and custom development. CGI is seeking a Oracle DBA to support our DOJ Customer in Crystal...
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CAT Technology, Inc - Reston, VA
Need 15 Oracle DBA candidates to start project in VASkills:. Proficient knowledge of Oracle, RAC, and Golden Gate, Unix Shell scripting • 5+ years of...
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Akima, LLC - Herndon, VA
Akima LLC's subsidiary employees form one of the broadest skill sets in all of government and industry. Supporting customers across the U.S., Middle East,
SQL Server Database
Edgesource Corporation - Washington, DC
Edgesource Corporation is seeking a Microsoft SQL Server DBA to join our project team in Washington, DC to monitor and maintain SQL Server databases that...


text:
Dancer sues over 2003 film Honey
A dancer has sued the producers behind Jessica Alba's 2003 movie Honey over allegations the plot was inspired by her life. In a new lawsuit, Honey Rockwell claims the filmmakers used her story as the basis for the project, in which Alba plays a Hispanic hip-hop dancer from the Bronx, New York, without permission.
According to TMZ.com, the dancer is seeking damages and a share of the $70 million (£43 million) box office revenue brought in by the film and its 2011 sequel.
Rockwell runs her own dance academy in the Big Apple.


text:
Iron Giant SE, The
Maine, Rockwell 1957. Hogarth Hughes is a nine-year-old with a lot of imagination. He lives together with his mother who works as a waitress and although both get along good, on the financial part things aren't too great. When Hogarth goes out at night, he finds a colossal robot that crashed from outer space and now eats everything that's made out of iron. Hogarth makes friends with the robot but quickly finds out that he'll need to find food for it as its path of destruction hasn't gone unnoticed in town. Meanwhile, a secret agent has come to Rockwell to investigate the matter and has found out that Hogarth knows the robot…
Sound and Vision:
The animation is well-done and throughout the movie we didn't spot anything disturbing. Compression errors or grain are absent.
The soundtrack is dynamic and vivid. Especially when the robot starts to run, the subwoofer gets its piece of attention. However, some more aggressive sound wouldn't have hurt. The surround speakers nicely do their job with some atmospheric sound and effects while dialogues are well-centered, clear and understandable.
– The Making Of The Iron Giant: documentary that gives a good insight on how the movie was created. Quite informative.
– Music video Cha Hua Hua
– Trailer
The Iron Giant is a great animated movie that portrays the atmosphere that was hanging around in the US during the cold war right after WW2. The paranoya of the US government towards everything that was unknown, the fear people had, the economical problems the US underwent, … all wrapped in a movie that's targeted towards children but is still more than interesting enough to have adults watch it as well. Technically things are very much okay but the "special edition"-title is a bit stretching things seeing that the amount of extras is a bit on the small side
Spartan Scooby Doo 2: Monsters Unleashed
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Patricia Cornwell delivers the newest engrossing thriller in her high-stakes series starring medical examiner Dr. Kay Scarpetta. Depraved Heart: ?Void of social duty and fatally bent on mischief.? ?Mayes v. People, 806 III. 306 (1883) Dr. Kay Scarpetta is working a suspicious death scene in Cambridge, Massachusetts when an emergency alert sounds... more...
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After working on one of the worst mass killings in US history, Chief Medical Examiner Kay Scarpetta returns home to recover, but an unsettling call drives her straight back to work. The body of a young woman has been discovered inside the sheltered gates of MIT, draped in an unusual cloth and posed in a way that is too deliberate to be the killer's... more...
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Now in a new premium edition, #1 New York Times bestselling author Patricia Cornwell?s suspense fiction classic, featuring gutsy medical examiner Kay Scarpetta. A reclusive author, Beryl Madison finds no safe haven from months of menacing phone calls?or the tormented feeling that her every move is being watched. When the writer is found slain... more...
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?A knockout? ( People ) of a thriller from #1 New York Times bestselling author Patricia Cornwell featuring medical examiner Kay Scarpetta. ?Killing me won?t kill the beast? are the last words of rapist-murderer Ronnie Joe Waddell, written four days before his execution. But they can't explain how Dr. Kay Scarpetta finds Waddell's fingerprints on... more...
PostmortemScribner 2009; US$ 9.99
Under cover of night in Richmond, Virginia, a human monster strikes, leaving a gruesome trail of stranglings that has paralyzed the city. Medical examiner Kay Scarpetta suspects the worst: a deliberate campaign by a brilliant serial killer whose signature offers precious few clues. With an unerring eye, she calls on the latest advances in forensic... more...
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#1 bestselling author Patricia Cornwell returns to the chilling world of gutsy medical examiner Kay Scarpetta in this suspense classic. Little Emily Steiner left a church meeting late one afternoon and strolled toward home along a lakeside path; a week later, her nude body was discovered, bound in blaze-orange duct tape. Called by the North Carolina... more...
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It is the week before Christmas. The effects of the credit crunch have prompted Dr Kay Scarpetta to offer her services pro bono to New York City's Office of the Chief Medical Examiner. But in no time at all, her increased visibility seems to precipitate a string of dramatic and unsettling events. She is asked live on the air about the sensational... more...
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Build a Website
This project received 101 bids from talented freelancers with an average bid price of $2583 AUD.Get free quotes for a project like this
Skills Required
Project Budget$1500 - $3000 AUD
Total Bids101
Project Description
We're an International Company dealing in Car Loans.
You can check our website at [url removed, login to view]
As you can see, our logo and website is quite outdated and we need something more funky, yet simple.
We like the minimalistic idea of [url removed, login to view]
As you will see from both websites we will need to be able to take applications online.
In short we would like our new website to operate and function like [url removed, login to view] and have the same online application process.
Looking forward to getting some great freelancers here.
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12 Reviews
YUM! I used Crystal Light lemonade to decrease the carb count and enjoyed immensely. Wouldn't of thought of this combo myself. Thats why I love Zaar:) Thanks!
I was going to make this after dinner and well, uuummm uuummmm I started sipping and never did get to making dinner. I promised my husband once my bottle of Midori's gone, it's gone.
This has a great taste but for me it would have been better with only 1/2 ounce of Midori : less sweet. I used pink lemonade. Not the best look but at least, the taste is the same. Thanks Nora Marie. Made for Bevy tag
Mild and refreshing! The melon and lemon flavors balance well here. This is definitely a drink for those who enjoy a lighter alcohol and a sweeter drink. This is not too sweet- just right. The lemonade balances the sweet Midori well. Thanks NoraMarie! *Made for Bevy Tag*
I bought a mini bottle of the Midori melon a few months back to tag, but then never got to tag the drink. I wasn't sure if I would it and found out that I sure do!!! I used crystal light lemonade and then mixed with the Midori, and it was delicious light and fruity drink. Thanks NoraMarie for a great new drink. Made for bevy tag.
Very tasty drink. Ive had other drinks with midiro melon and I like this one the best. I doubled the ingredients and made it in a very tall glass. Next time I will add a squeeze of fresh lemon. Thanks for sharing this recipe.
A very pretty color and loved the flavor!! Will definately be making this again.
This is a good drink. I thought the flavor was a bit weak but it might have been the lemonade I used. A very pretty color!
I made this a little while back and thought I reviewed it. This is a good drink. I have made it a couple of times. Easy to make and not too strong. I will be making this again. Thanks for sharing your recipe. Made for Bevy Tag.


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The Spectrum was more than just an indoor sports arena.
Since 1967, the drab, oval-shaped building on South Broad Street hosted some of the best events Philadelphia could offer - rock concerts, ice shows, the circus.
One of the best things about the Spectrum was its unadorned name. Today, we have mouthfuls such as Lincoln Financial Field, Citizens Bank Park, and the Wachovia, er, Wells Fargo Center.
But even when it had corporate sponsors - Core States, First Union, Wachovia - people just called it the Spectrum, an indication that the arena belonged to the people, not a bank.
Countless people saw their first Springsteen concert at the Spectrum. Supertramp, 1979? It was an awesome concert. Of course, no one used the word "awesome" that way back then. But it was.


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Many thanks to our hosts in Mammoth Lakes. We appreciate all you did for us. The skiing was great, the cocktail party lots of fun, and the audience for our concert was just terrific. Again, many thanks.
The Crown City Brass Quintet
The Crown City Brass Quintet, formed in Los Angeles, California in 1992, has enjoyed a reputation among its audiences for both the brilliant performances of established quintet repertoire and energetic performances introducing new works. Each member has virtuosic skill on their instrument and experience ranging from...
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Copyright © 2007-2008 - Crown City Brass Quintet


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Written on: 16/10/2013
This being the first time I have used this company I was by nature wary. However the goods were promptly dispatched, just as described and fantastic value, with the cheapest I could find anywhere. There is nothing about the process of quality / description of the goods or the way they do business I would change. Good job keep it up.
As rated by our community of reviewers
" Brilliant build delivered quickly " Read More
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Written by Beverly1960


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Packaging firm blamed over baby choking
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An organic baby food maker told the High Court in Auckland her dream of being a premium and ethical exporter was left in tatters when Australian mothers complained of plastic choking hazards appearing in their baby food.
Charlotte Rebbeck, chief executive of Green Monkey, and her business partner, Andy MacBeth, are suing the company's former packaging producer, Aperio, to recover nearly $1 million in costs associated with a 2011 pre-Christmas product recall, lost sales and brand damage.
Rebbeck said international media coverage included headlines on at least three South Korean news channels that "roughly translated to 'Choke. Baby. Dead.' "
Rebbeck said a doctor told her an Australian baby choked on a small plastic disc that made its way into a baby-food pouch. At the time, in 2011, the baby was first diagnosed as having an allergic reaction but a doctor later said the incident was more likely related to two earlier complaints where mothers found small plastic discs in Green Monkey baby food.
Under cross-examination Rebbeck said she knew that Aperio would use a Malaysian manufacturer to create the pouches when she first ordered, but Aperio had said they would meet stringent EU packaging regulations.
Green Monkey, now branded as Green Zoo, recalled hundreds of thousands of dollars worth of stock while Aperio shirked its responsibilities and costs, the court heard.
Rebbeck said Green Monkey wanted to recall products after the first incident, but Aperio said it was a one-off incident.
Rebbeck told Justice Susan Thomasthat Aperio's New Zealand representative, Allan Ching, first told her to keep using the pouches. When complaints continued he said Aperio would help "set things right". However, Aperio told Green Monkey that they did not have the resources to support an international recall.
Rebbeck said that, at the time of the recall, Green Monkey had distributors in Hong Kong, Taiwan, the United States and the United Arab Emirates. It also supplied Woolworths supermarkets in Australia. The company lost all its international customers at the time.
She said the recall meant Green Monkey effectively had a six-month gap in supplying products to any distributors that still wanted the products and strained relationships with suppliers.
"This completely ruined our brand, but left Aperio completely undamaged."
- BusinessDay
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Design an App Mockup
This project received 10 bids from talented freelancers with an average bid price of $ USD.Get free quotes for a project like this
Skills Required
Project Budget$30 - $250 USD
Total Bids10
Project Description
Hello freelancers. We are looking for experienced artist, who could create responsive UI design for our upcoming game. In this game will be wide variety of characters. From fantasy knights and mages to future robots.
We need neutral comics style game graphics with detailed paintings in high resolutions (wide variety of iOS devices, retina including) Result will be UI kit in psd format, so our game designers can simply take container graphic a make new UI element. From this kit, we should create new elements with ease. Design should follow 9 patch graphics design.
UI Design should include:
- Containers with great frames
- Buttons
- Arrows
- Input boxes
- Frames
And much more…
We need someone who has experience, so we need you to show some of your work with similar focus.
Looking to make some money?
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- Outline your proposal
- Get paid for your work
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My Spirits gifted me with the name "Owl Woman" because I see in both worlds. I see in the dark things that are hidden. I am the "hollow bone" allowing Spirit to work through me to find what is troubling you.
The session being offered is SOUL RETRIEVAL
Soul Retrievalby Sandra Ingerman
"Imagine yourself sitting in a circle with members of your community. You have gathered together to support one community member who is suffering from a traumatic experience. You know that if one person is suffering and is ill it effects the entire community. So you have come to help hold the space for healing to happen.
It is dark and the stars are shining bright in the night sky. The air is still. Everyone feels held in the loving arms of the universe and there is no doubt that healing will happen for all gathered here.
The shaman begins to drum and dance calling the power of the universe to her as she puts her egoic self aside and becomes an empty vessel that fills with the help of the spirits.
The client lies quietly in the center breathing deeply to be in a receptive state to receive back his lost soul; his lost vitality.
The shaman sings her journey out loud as she tracks down where the soul has fled. And on finding it returns and blows it deeply into the heart of the client filling the entire body with the light of life.
There is a great joy for all as one heals all are healed. The community is now whole again and can be in peace and harmony. The work is done."
It is believed that whenever we suffer an emotional or physical trauma a part of our soul flees the body in order to survive the experience. The definition of soul that I am using is soul in our essence, life force, the part of our vitality that keeps us alive and thriving.
The types of trauma that could cause soul loss in our culture would be any kind of abuse sexual, physical, or emotional. Other causes could be an accident, being in a war, being a victim of a terrorist act, acting against our morals, being in a natural disaster (a fire, hurricane, earthquake, tornado, etc.), surgery, addictions, divorce, or death of a loved one. Any event that causes shock could cause soul loss.
Some of the symptoms that would indicate soul loss to a Shamanic Practitioner include: depression, a feeling of incompleteness, an inability to move forward on some issue, lost memories, feeling like your not in control your life, people who say I felt like part of me died when..., or people who say I feel like so and so stole my soul. Soul loss is often accompanied by a feeling that something is missing from life. I lost something when I lost my job, I never felt the same after my accident..
These sessions are offered on a sliding scale of: $40-$60. Follow-up calls will be made a few days after your session. If you are called to this session and the sliding scale is a challenge for you please e-mail me (Dee)
Times offered:
10:[masked] (Jamie's time)
12:00- 1pm (Marta's time)
2 pm-3pm (Eveleen's time)
If you are interested, please list the time you want in the note of your RSVP. IF you RSVP and are not able to attend, please change your RSVP ASAP! Thanks Dee
I have been a Shamanic Practitioner for over 10 years. I have many teachers and have had many teachers. My travels have taken me far and wide to the ends of Mother Earth learning natural medicine in Africa. Learning love of life, culture, and spiritual enchantment in the Virgin Islands. I crossed lake Atatlan in Guatemala surrounded by extinct volcanoes to learn Trance Dance and Tantric Shamanism. I lived in an open air hut in the jungle of Belize to listen to my Mayan ancestors. I am a registered member of the Chinook and Quinault tribes in Oregon and Washington, a Sun-dancer, and the tree is my healer. They have all taught me well. I also have a Bachelor of Science Nursing Degree with a current Arizona Nursing License working in a local Tucson Hospital.
Hi Dee, I would like to reserve the 2 pm to 3 pm spot.
Thank you!
0 · July 18, 2013
Would it be possible to keep my name in mind as an alternate in case someone cancels? I don't know if I can commit to a session right now, but I am sure I can commit to being an alternate (if that makes sense).... that way I'm not occupying a time slot when someone else might need it more....
0 · July 5, 2013
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Matching: threadsafe X
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Is your program Threadsafe?
sarahbertram Tags: rentpgm tcb rent threadsafe cics 4,384 Views
Working in CICS level 2, we see a variety of different problems that are related to threadsafe issues. Specifically, where a program is marked threadsafe, but is really not. These can cause unpredictable results, and can be difficult to diagnose. ...Modified on by SteveWebb
Web and Legacy, CICS's Two sides of the Coin
systemzblogger Tags: threadsafe cics 2,723 Views
<!-- /* Font Definitions */ @font-face {font-family:"Cambria Math"; panose-1:2 4 5 3 5 4 6 3 2 4; mso-font-charset:1; mso-generic-font-family:roman; mso-font-format:other; mso-font-pitch:...


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In 2007, I wrote the "Top 10 Things to Measure on Your Website" for Larry Chase's Web Digest for Marketers email newsletter.
The TL;DR version is:
1. How Fast Is It?
But back then, that was out of concern for your customers without a thought about search engine results placement.
2. How Often Does It Spit Up or Fall Over?
From timeout errors to 404s, these errors are still with us.
3. How Many People Show Up?
True, the numbers are not precise, but the trends are your friends in telling you if your promotions are working.
4. Which Are the Most Popular Pages?
What on your website is so interesting? What's not?
5. Which Way Did They Go?
From bounce rates to path analysis, you need to know if people seem to be acting the way you expected when you designed your site.
6. What Are They Looking For?
From the search that drives the visit to the follow-up on-site search, knowing prospective customer intent is a big eye-opener.
7. How Did They Get Here?
Where are the right kinds of people (real prospects and actual customers) coming from? Go back and get more.
8. Did We Achieve Our Goals?
Did you end up with more subscriptions, registrations, customers, orders, profits, or whatever else you were hoping for when you built your site?
9. Are They Happy About Their Visit?
Customer satisfaction is a crucial metric to layer over behavioral data. Lots of visits and pageviews does not mean you're doing a good job unless people say you are.
10. Are We Using Our Own Metrics?
How do you know if your measurements are working? Time to measure the number of times your metrics are used.
That was then.
Today, my list might look like this:
1. Calculate Your Culture
Is yours truly a data-informed company or, as Andrew Lang famously warned against, are you merely, "using statistics as a drunkard uses a lamppost, for support rather than illumination"? If the corporate executives are only playing lip service to analytics, it's time to find an executive who will act as your sponsor and make it possible to create – and show off – your analytical success.
2. Catalog Your Collaborators
If the C-suite is on board, you're headed in the right direction. Your next step is to make really good friends with people in IT. Their internal culture will be critical to your success. Are they willing and able to respond to marketing emergencies even if they have parallel payroll problems? Do they insist on maintaining tight control or are they willing to educate you and yours on ways you can administer self-service?
3. Investigate Your Infrastructure
Even if the top brass is all excited about metrics, they must invest in the necessary tools. You can write a novel in Word, in Notepad, on a typewriter or by hand. But you cannot produce a useful analysis with Excel alone.
4. Detail Your Data Quality
Lots of data is wonderful, but trustworthy data is everything. Do you know where your data is coming from? Who has modified it? How current it is? Do you have a data governance program? What used to be Garbage In, Garbage Out is now Big Data Garbage In, Big Data Garbage Out. That makes detecting it that much harder.
5. Tally Your Testing
Testing is one of the most tactical, data-driven things you can do. You can start simply with a few A/B split tests and work your way up to a sophisticated, formal multivariate testing program on a formal testing platform.
6. Investigate Your Insight Generation
Are you and yours spending more time cranking out reports than insights? That's a sign that your culture isn't where it needs to be. Some reports are necessary and can be automated – that's fine. But the ad-hoc requests for this number and that number without a solid strategy are diminishing the potential power of
your analytical efforts.
7. Itemize Insight Exploitation
Congratulations: Your team came up with dozens of insights that can really move the needle when it comes to corporate goals. But were they understood? Were they accepted? Did they get adopted? Do your insights translate into business decisions that have a material impact on raising revenue, lowing expenses, increasing customer satisfaction, or adding to the capabilities of the company?
8. Mull Over Your Maturity
Where does your organization fall on the Online Analytics Maturity Model? Are you stronger in some areas and weaker in others? Time to find out and take action.
9. Scrutinize Sales
Did you sell anything? Alternatively, did you stimulate donations, get people to vote for your candidate, generate qualified leads, or whatever your firm's goals are? Do your online endeavors help the company?
10. All of the Above
Click-throughs, pageviews, and all the rest are still valuable, but unless you have this new list in order, you're just counting for the sake of counting. What was true back in 2007 is true today: Set goals. Make changes. Track results. Repeat. Those are the instructions for a bigger, better, faster, stronger website.
Related reading
Tencent's Emily Ma on the challenges for marketers in China
Emily Ma, product director of Tencent's advertising platform products department, was a keynote speaker at ClickZ Live Shanghai where she discussed the ... read more
Seven ways to future-proof your digital strategy
Nurcin Erdogan Loeffler, head of strategy and innovation, Vizeum China, outlines the seven ways businesses can future proof their digital strategies.
14 ways to reduce your site's bounce rates
I've often looked at bounce rates and associated metrics as a way to measure the general stickiness and appeal of a website. ... read more
11 lessons you can learn from your site search data
The terms that customers type into your site search function can help you to gain an understanding of user behaviour and can be used to optimise ... read more


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N J S Enterprises, Inc.
Phone: (847) 839-1300 Fax: (847) 839-8504 1000 E State Pkwy Ste E, Schaumburg, IL 60173 http://www.njs-ent.com
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Business ManagementMr. Bill Sorrentino, President
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Hotels near Al-Hosn Palace
Search hotels near Al-Hosn Palace in Abu Dhabi
Trending now in Abu Dhabi
Hotels within 0.5 miles of Al-Hosn Palace
35 people looked at this hotel in the last hour
Most recent review
"We loved our stay at the Courtyard. We arrived early after an all night flight and drive from Dubai and fortunately our rooms were available. Our accommodations were lovely and the staff were excellent without exception. Our rate included breakfast each day which was outstanding. The breakfas..."
A Traveller, Sep 2016, US
- Tulip Inn Al RahbaNo Guest Reviews yet
7 people looked at this hotel in the last hour
- Baynunah Abu DhabiNo Guest Reviews yet
5 people looked at this hotel in the last hour
Hotels within 1 mile of Al-Hosn Palace
87 people looked at this hotel in the last hour
Most recent review
"nice location very friendly staff well maintain hotel."
A Traveller, Jun 2016, GB
66 people looked at this hotel in the last hour
Most recent review
"The Cristal is our "go to" hotel. We've stayed in many hotels in Abu Dhabi. Cristal Hotel is our favorite. The staff know us by name. They treat us like family not just a customer. We visit the Cristal every four to five weeks. "
A Traveller, Aug 2016, US
- Paragon HotelNo Guest Reviews yet
55 people looked at this hotel in the last hour
Most recent review
"very nice days at Paragon hotel too close to markets and shopping center"
A Traveller, Jan 2016, US
29 people looked at this hotel in the last hour
Most recent review
"This is my third stay on this hotel. It is a nice 3-4 star hotel that is close to a lot of things. World Trade is within walking distance. The malls are only around 5-6 dirhams on a taxi. The staff are wonderful especially the front staff Princess and Mary. They are very helpful. Housekeeping is..."
A Traveller, Jul 2016, US
27 people looked at this hotel in the last hour
Most recent review
"Great Hotel Apartment for family, the only thing the SPA was under renovation and not open, otherwise no problem what so ever. will stay again if we ever travel to AUH."
A Traveller, Oct 2015, US
11 people looked at this hotel in the last hour
Most recent review
"Very helpful staff, clean and quiet rooms, good location in the city. Abu Dhabi seems to be well planned and has some beautiful architecture."
A Traveller, Oct 2013, GB
10 people looked at this hotel in the last hour
Map of hotels near Al-Hosn Palace
- The Corniche
- Yas Marina Circuit
- Abu Dhabi National Exhibition Centre
- Ferrari World
- Abu Dhabi Mall
- Sheikh Zayed Grand Mosque
- Open Beach
- Yas Waterworld
- Al Wahda Mall
- Abu Dhabi (ZVJ-Abu Dhabi Bus Station)
- Shaikh Khalifa Medical City
- Madinat Zayed Shopping Center
- Marina Mall
- Khalidiyah Mall
- Abu Dhabi Golf Club
- Mushrif Mall
- Khalifa Park
- Higher Colleges of Technology-Abu Dhabi Men's College
- Abu Dhabi University
- Abu Dhabi Commercial Bank
Hotels in Abu Dhabi near Al-Hosn Palace
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Our maps are based on hotel search and display areas and neighborhoods of each hotel so you can see how close you are from Al-Hosn Palace and refine your search within Abu Dhabi or United Arab Emirates based on closest public transportation, restaurants and entertainment so you can easily get around the city. All the hotels details page show an option for free or paid onsite parking.
If you wish to see the hotels with the highest featuring discounts and deals near Al-Hosn Palace, simply filter by price/ average nightly rate. We recommend you filter by star rating and read our genuine guest reviews so you can get the best quality hotel with the best discount.
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Make the most out of your family vacation when you book your accommodation with Hotels.com – book your hotel near Al-Hosn Palace, Abu Dhabi after reviewing the facilities and amenities listed for each hotel.
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Abu Dhabi travel guides
An Abu Dhabi travel guide - Arabian tradition with cool, contemporary luxury in the UAE's understated capital
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When it comes to staying in Abu Dhabi, this enchanting city offers a wide variety of accommodation t...
Abu Dhabi shopping guide – where and what to shop and buy
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Tiger striped coconut shell heishe. Beads measure approximately 5mm x 3.5mm.
Sold on 16 inch strands.
Made in the Phillipines.
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