Accomplishments of the Division - 2023

SIXT Rent A Car, LLC is a rental car company based in Fort Lauderdale, Florida. It operates more than one location in the metro Atlanta area, including one in close proximity to Hartsfield-Jackson Atlanta International Airport. Consumers claimed that the company (or a debt collector acting on its behalf) contacted them after the consumers returned their rental vehicles and alleged that the vehicles had sustained damage during the rental period. Although SIXT undertakes a final inspection of the vehicle upon its return, consumers report that this alleged damage was not documented on the final checklist, and that the company made the claim long after the vehicles were returned. Although the alleged damage may have been minor (the consumers refer to the damage as “scratches”), they were charged hundreds of dollars to handle repairs. There are a number of similar complaints on record with the Better Business Bureau. Having consumers pay for damage to a rental vehicle is a commonly accepted practice in the industry, but the high costs of these fees and the delay in reporting the damage to consumers were troubling. Additionally, it appears that while some consumers have these costs billed to their car insurance, others are held personally liable. The complaints suggest that SIXT was engaging in deceptive billing practices regarding damaged vehicles and failing to follow the commitments outlined in their contract, which are violations of the Fair Business Practices Act.

The company entered into a settlement with the Attorney General’s Office, which outline actions the company must take to bring its practices into compliance with Georgia law. The settlement included a civil penalty assessment of $75,000, with $25,000 due up front. A portion of the stated civil penalty can be waived in April 2024, if SIXT fulfills its obligations under the settlement and remains in compliance with Georgia law.

Our office’s investigation into the practices of this dealership revealed that for over 50% of their vehicles, Sutherlin Nissan regularly failed to honor its advertised prices. For instance, some consumers were required to pay reconditioning charges or paint protection packages, sometimes for thousands of dollars over the advertised price. Because the services for these additional charges, such as vehicle inspections or conditioning, had already been performed, these charges are required, non-government fees. Accordingly, these charges must be included within the advertised price as only government charges may be properly excluded. In other instances, the final sales price far exceeded the advertised price for no clear reason at all.

The document production substantiated the numerous consumer complaints that alleged the dealership refused to honor its advertised prices. Further, Sutherlin Nissan was on notice that these practices violate Georgia law. In 2016, the dealership executed a court-filed settlement acknowledging that these types of practices were prohibited and paid approximately $80,000 in combined penalties and restitution.

Additionally, the dealer occasionally misrepresented the fees it assessed for electronic titling services and otherwise designated these fees in confusing ways. For instance, in some sales documents, the dealer consistently assessed a “MVWRA” or “Motor Vehicle Warranty Rights Act” fee of $200-$300. Elsewhere the dealer represented those same fees as state-required titling services. Either designation was problematic. MVWRA is a reference to an earlier version of Georgia’s Lemon Law (which became effective in 2009), so the reference was inaccurately used in designating title fees and was inapplicable for used cars which are not covered by Lemon Law protections. In other documents, the dealer represented these $200-$300 charges as being charged and required by the government. While approximately $25-$35 of the charge was remitted to a licensed Department of Revenue vendor, the rest of the fee was pocketed by the dealer as a service charge.

The dealership executed a court-filed settlement and paid a $20,000 penalty to the State. Further, as evidence of the Sutherlin group’s intention to ensure compliance in all of its stores, the other three Georgia dealerships (Sutherlin Volkswagen, Sutherlin Nissan Cherokee, and Sutherlin Hyundai) have agreed to institute ongoing policy and training protocols.

We initiated an investigation of Rick Hendrick CDJ after receiving a complaint alleging that the dealership was excluding the cost of dealer-added options (including a truck lift costing over $1500) that were already installed on the vehicle and must be paid for as part of the purchase. These types of charges, much like dealer fees, are non-government fees, and if a dealership elects to require their purchase, the cost must be included within the advertised price of the vehicle. Failure to do so is a violation of the FPBA’s general prohibition against unfair and deceptive practices. In discussions with the dealer, the business acknowledged that these advertising misrepresentations were common with the dealer’s trucks.

This violation, however, is not the first with this dealership. In 2021, Rick Hendrick CDJ executed an agreement with our office, which prohibited the exclusion of non-government, mandatory fees, including dealer-option type fees, from the advertised vehicle prices. The recent violation is a clear violation of the previous agreement. The company entered into a court-filed settlement that required it to pay a $20,000 civil penalty and to rectify its advertising by including new disclosures that clearly tell consumers in writing that purchase of these options is not a requirement to buy a vehicle.

Our office first learned that Gwinnett Place Ford was misrepresenting its used vehicle certifications when we received a complaint with substantiating documents alleging that the dealer was advertising manufacturer-certified used vehicles when the vehicles had not yet been certified. Ford certification only applies to higher quality used Ford vehicles that have been repaired or reconditioned to Ford’s certification standards by Ford certified mechanics. Additionally, purchase of the certified vehicles includes an extensive service contract offered by Ford, among other benefits. Due to these heighted quality standards, vehicle reconditioning costs, and the included service contract, certified vehicles cost more than a non-certified vehicle.

The consumer complainant alleged that in order to acquire the certification, consumers would have to pay an additional $1,895 over and above the advertised price.  We conducted an undercover investigation and verified the consumer’s claims. Subsequent conversations and production of documents by the dealer indicated that at intermittent periods during the past year Gwinnet Place Ford had misrepresented its vehicles as certified prior to certification and then charged consumers for the certification. Dealership personnel had identified used vehicles that fit Ford’s certified vehicle requirements and would then advertise them as certified without including the costs of certification ($1895) to lower the advertised price. The dealership would not begin the certification repairs or reconditioning until the consumer purchased the vehicle. Some consumers, upon learning that they vehicles were not actually certified, elected not to purchase them. For those who did, some were able to negotiate the certification fee to amounts lower than $1,895, but many paid the full certification costs.

Gwinnett Place Ford entered into an Assurance of Voluntary Compliance with our office, in which it agreed to abide by numerous compliance terms, most significantly, that prior to advertising any vehicle as “Ford certified,” the dealer must (1) perform all repairs/reconditioning according to the manufacturer’s specifications for certification and (2) pay all required fees to the manufacturer to obtain the advertised certification.

The settlement required the dealership to pay a $20,000 civil penalty, plus $72,514 in consumer restitution.

An investigation by the Attorney General’s Office revealed that this vehicle dealership misrepresented its vehicle prices by adding required, non-government fees (e.g., dealer fees) on top of the advertised prices. Our review also showed that the dealer was unable to substantiate the substantive claims it had made regarding a meaningful portion of its advertised vehicles. These representations included indicating that vehicles had “full factory warranty,” were “dealer maintained,” had “no known mechanical issues,” and similar material representations regarding the vehicle’s history and condition.

Our settlement with AutoMax Atlanta required it to amend its advertising practices to ensure its prices reflect the true sales price (minus government fees and taxes) by ensuring that required options, those already installed on the vehicle, electronic filing fees, and required non-government charges are included in advertised prices. Further, the dealer is prohibited from making misrepresentations regarding the condition and history of its vehicles. In particular, the dealership cannot represent that vehicles have no accidents unless AutoMax knows this representation to be true and must be able to substantiate claims regarding the vehicle’s history and mechanical condition. In addition, the business must pay the State a penalty of $20,000.

Our office initiated this investigation following receipt of consumer complaints alleging that the company was distributing mailers that advertised, among other things, a $25,000 cash giveaway to mailer recipients. Consumers complained that they drove to the dealership for the purpose of collecting the advertised prize they believed they had won. Once there, consumers learned they had only qualified for a prize of nominal value and were directed to salesmen for pitches to purchase vehicles.

The mailer distributed by the dealership, and which prompted these visits, contained numerous violations of the Fair Business Practices Act (“FBPA”). The FBPA requires specific disclosures in these types of promotional giveaways, including disclosing the value and odds of winning prizes, and any requirement to participate in or listen to a sales presentation. The mailer failed to include several required disclosures and offered a cash prize in violation of the statute. Beyond these promotional violations, the mailer also contained numerous, more general advertising misrepresentations. For instance, the mailer advertised that recipients could receive “up to 100% of the manufacturer’s base price” in exchange for their vehicles, when few, if any, consumers would qualify for such an offer. The mailer also made use of highly misleading scratch-off icons. Consumers were directed to scratch off icons on the mailer when the only matching icons were stacks of money falsely suggesting that each of the 20,000 recipients had won the $25,000 cash prize, when only one recipient was qualified to win.

The dealership settled with our office and paid a $10,000 penalty to the State. The agreement required the dealership to comply with the numerous promotional requirements set forth in the FBPA and prohibits it from making the deceptive representations contained in the mailer.

In accordance with an Arbitration Decision issued in a Lemon Law hearing, JLNRA was ordered to repurchase a vehicle and pay the consumer in question an amount of $77,371.81. JLRNA had 30 days to appeal the decision but did not do so. Absent an appeal, JLRNA had 40 days from the decision filing date to comply with the arbitrator’s award. Despite numerous attempts by our office to contact the manufacturer about its obligation to comply, including via phone, email, and a formal notice of noncompliance sent via certified mail, the company failed to respond. Finally, a full 80 days after the compliance deadline, JLRNA complied with the arbitrator’s award.

JLRNA had failed to timely comply with a repurchase or replacement Lemon Law decision on at least three prior occasions. JLRNA had also failed to timely respond to notices of hearings and failed to timely submit filings in active Lemon Law cases.

The company entered into an Assurance of Voluntary Compliance with our office, which included injunctive terms that specified the actions that would bring the business into compliance with Georgia law. The settlement also required JLRNA to pay a civil penalty of $100,000 upon signing. The settlement documents also contained a provision for additional substantial penalties to be assessed if violations occurred within a defined time period.

ACI is a payment processor for a variety of third-party clients, including mortgage servicers, and is licensed as a state money transmitter. One former ACI client is Nationstar Mortgage which does business as Mr. Cooper. On Friday, April 23, 2021, ACI was testing a payment system when it made the critical error of submitting Mr. Cooper customer test data into the Automated Clearing House (ACH) system. This resulted in ACI erroneously attempting to withdraw multiple mortgage payments from hundreds of thousands of Mr. Cooper customers' bank accounts. While in the vast majority of instances no money was actually withdrawn from consumers' bank accounts, ACI's actions were not harmless. Some consumers were charged fees by their banks while others were not able to access their impacted money for several days. The incident involved approximately 477,000 Mr. Cooper customers and 1.4 million ACH transactions totaling $2.3 billion, which is believed to be the largest error in the history of the ACH system.

Georgia was part of a multi-agency action which included all 50 states, the District of Columbia, Puerto Rico, the Mortgage Group Executive Committee, the State Money Transmission Regulators (State Regulators), and ACI Worldwide Corp. (ACI). The settlement required ACI to implement important injunctive terms designed to prevent a similar incident from occurring again and to pay $10 million to the states. It should be noted that a separate settlement that came out of these same investigations required ACI to pay an additional $10 million to the State Regulators.

Specifically, the multistate settlement required ACI to use artificially created data, rather than real consumer data, when conducting any testing of its systems or software in the future. ACI must also maintain segregation of any testing, development, or quality assurance environment from its production environment and ensure that any ticketing system used to request or obtain consumer information cannot be circumvented. Additionally, ACI must create and maintain both a comprehensive information security program and a cybersecurity program. These programs need to be written, provided to, and easily accessible by all employees and third-party vendors. Employees and third-party vendors are further required to be annually trained on these programs, and ACI is obligated to test the effectiveness of these programs regularly. These programs must be run by a qualified individual who has the authority to escalate matters to senior management and ACI’s board of directors. Finally, the settlement imposed ongoing monitoring and reporting requirements on ACI related to any unauthorized access, unauthorized use, or inadvertent disclosure of consumer information

The Attorney General’s Office, along with 49 other attorneys general, reached a settlement with software company Blackbaud for its deficient data security practices and response to a 2020 ransomware event that exposed the personal information of millions of consumers across the United States. Under the settlement, Blackbaud agreed to overhaul its data security and breach notification practices and make a $49.5 million payment to the states. Georgia received $1,204,359 from the settlement.

Blackbaud provides software to various nonprofit organizations, including charities, higher education institutions, K-12 schools, healthcare organizations, religious organizations, and cultural organizations. Blackbaud’s customers use Blackbaud’s software to connect with donors and manage data about their constituents, including contact and demographic information, social security numbers, driver’s license numbers, financial information, employment and wealth information, donation history, and protected health information. This type of highly sensitive information was exposed during the 2020 data breach, which impacted over 13,000 Blackbaud customers and their respective consumer constituents.

The settlement resolved allegations of the attorneys general that Blackbaud violated state consumer protection laws, breach notification laws, and HIPAA by failing to implement reasonable data security and remediate known security gaps, which allowed unauthorized persons to gain access to Blackbaud’s network, and then failing to provide its customers with timely, complete, or accurate information regarding the breach. As a result of Blackbaud’s actions, notification to the consumers whose personal information was exposed was significantly delayed or never occurred at all insofar as Blackbaud downplayed the incident and led its customers to believe that notification was not required.

In addition to monetary penalties, the settlement required Blackbaud to significantly strengthen its data security and breach notification practices going forward. 

Attorney General Chris Carr, along with 32 other attorneys general, reached a settlement with health care clearinghouse Inmediata for a coding issue that exposed the protected health information (“PHI”) of approximately 1.5 million consumers for almost three years.

As a health care clearinghouse, Inmediata facilitates transactions between health care providers and insurers across the United States. On January 15, 2019, the U.S. Department of Health and Human Services’ Office of Civil Rights alerted Inmediata that PHI maintained by Inmediata was available online and had been indexed by search engines. As a result, sensitive patient information could be viewed through online searches, and potentially downloaded by anyone with access to an internet search engine.

Although Inmediata was alerted to the breach in January 2019, the company delayed notification to impacted consumers for over three months and sent misaddressed notices. Further, the notices were far from clear—many consumers complained that without sufficient details or context, they had no idea why Inmediata had their data, which may have caused recipients to dismiss the notices as illegitimate.

The settlement resolved allegations that Inmediata violated state consumer protection laws, breach notification laws, and HIPAA by failing to implement reasonable data security, including failing to conduct a secure code review at any point prior to the breach, and then failing to provide affected consumers with timely and complete information regarding the breach, as required by law.

Under the settlement, Inmediata agreed to strengthen its data security and breach notification practices going forward, including implementation of a comprehensive information security program with specific security requirements include code review and crawling controls, development of an incident response plan including specific policies and procedures regarding consumer notification letters, and annual third-party security assessments for five years.  Inmediata also agreed to pay $1.4 million to the plaintiff states. Georgia received $27,529.

Acella is a pharmaceutical manufacturer based in Alpharetta, Georgia. Acella manufactures NP Thyroid, a drug for hypothyroidism that uses desiccated thyroid extract — an animal-based thyroid extract — as its active pharmaceutical ingredient. The desiccated thyroid extract active pharmaceutical ingredient constitutes approximately ¼ of NP Thyroid’s formula.

During a joint investigation with the Nebraska Attorney General’s Office, the states uncovered multiple misrepresentations to consumers concerning NP Thyroid, which constitute violations of the Georgia Fair Business Practices Act. For instance, Acella advertised that NP Thyroid was “made” or “manufactured” in the USA, even after that claim was no longer accurate.

Further, Acella made misleading assertions regarding whether NP Thyroid complied with United States Pharmacopeia (“USP”) standards. Despite the Food and Drug Administration (“FDA”) finding hypo- and hyper-potencies outside the USP standards which resulted in three “voluntary” recalls between 2018 and 2022, Acella continued to mislead the public by asserting “USP” in the drug name and in fact advertised that it “conducted batch-to-batch testing to ensure consistency” with USP standards in its NP Thyroid.

Moreover, Acella itself, its two contract manufacturers, and its active pharmaceutical ingredient source Bioberica all received FDA warning letters at various points since 2020 for “significant violations” of the FDA’s Current Good Manufacturing Practice regulations (“CGMP”). Thus, at least one entity (and typically two entities) involved in NP Thyroid production has been in corrective action for CGMP violations since 2020. Nonetheless, until recently after we pointed it out, Acella falsely advertised that NP Thyroid was manufactured “in accordance with” CGMP.

Acella entered into a settlement with Georgia and Nebraska, agreeing to broad injunctive relief concerning the issues described above. The office also obtained restitution to consumers by requiring Acella to reopen its recall and refund process for the hyper- and hypo-potent NP Thyroid. Acella additionally agreed to pay $250,000 to Georgia, and $250,000 to Nebraska, in civil penalties.

The Attorney General joined national settlements with CVS, Walgreens, Teva and Allergan to resolve allegations that the companies contributed to the opioid crisis. By simply joining the settlements, Georgia stands to receive more than $181 million in total base payments to help fund critical treatment, prevention, reduction and recovery services.

CVS and Walgreens

The national settlements require CVS to pay $5 billion and Walgreens to pay $5.7 billion, for a total of $10.7 billion. CVS and Walgreens also agreed to court-ordered injunctive relief that requires the pharmacies to monitor, report, and share data about suspicious activity related to opioid prescriptions.

Georgia officially joined the settlements with CVS and Walgreens on Dec. 21, 2022. By doing so, the state is positioned to receive a base payment of $50.1 million from CVS and $58.7 million from Walgreens.

CVS and Walgreens were not defendants in Georgia’s ongoing litigation involving opioid distributors. Instead, the companies approached the state with these settlement offers, which Georgia then accepted.

Teva and Allergan

The national settlements require Teva to pay $4.25 billion and Allergan to pay $2.37 billion, for a total of $6.6 billion. Teva and Allergan also agreed to strict limitations regarding the marketing, promotion, sale and distribution of opioids.

Georgia officially joined the settlements with Teva and Allergan on Dec. 19, 2022. By doing so, the state is positioned to receive a base payment of $44.9 million from Teva and $27.4 million from Allergan.

Teva and Allergan were defendants in Georgia’s litigation involving opioid manufacturers.

Elite Integrated Medical, LLC, formerly known as Superior Healthcare of Woodstock, LLC d/b/a Superior Healthcare Group, Superior Healthcare Sandy Springs, and Superior Healthcare Morrow will pay $287,631 in restitution as required by a Consent Judgment obtained by the Attorney General’s Consumer Protection Division. The Judgment also permanently prohibits Elite from selling or advertising stem cell therapy products or services. This is the culmination of a lawsuit filed in September 2020 in which this office alleged that Elite violated the Fair Business Practices Act by making false and deceptive advertising representations about the effectiveness and regulatory status of stem cell therapies.

The lawsuit alleged that Elite made millions of dollars by using aggressive marketing techniques and high-pressure sales tactics to convince hundreds of consumers, most of whom were elderly and/or disabled, to purchase expensive, unproven medical treatments that are not covered by Medicare or health insurance. The complaint further alleged that Elite misrepresented the role of medical doctors in providing patient care and that it deceptively featured a customer testimonial without revealing that it came from the owner of the company’s advertising agency.

The Judgment required Elite to pay $137,631 in restitution to identified consumers who filed a complaint with the Attorney General’s Consumer Protection Division that has not otherwise been resolved. Elite also paid another $150,000 to the Consumer Protection Division for a restitution fund for consumers who filed eligible claims by August 1, 2023.

In addition to the above-mentioned restitution, the settlement permanently prohibits Elite from:

• advertising, marketing, promoting, offering for sale and/or selling any regenerative medicine treatment; and
• owning, operating, managing, or otherwise being affiliated with any business that provides marketing services on behalf of any healthcare business and/or any business that advertises regenerative medicine products, including through endorsements, social media, live seminars or other presentations, webinars, videos, emails, digital materials, and/or television and radio commercials; and
• making, or assisting others in making, representations that products or services cure, mitigate, or treat any disease or health condition, unless such representations are non-misleading and based on competent, reliable scientific evidence; and
• making, or assisting others in making, false or misleading representations about the Food and Drug Administration’s (FDA) regulation of regenerative medicine products; and
• Elite must also comply with the Federal Trade Commission’s Guides Concerning the Use of Endorsements and Testimonials in Advertising. Elite is also prohibited from making or disseminating endorsements that do not honestly reflect the opinions, beliefs, findings, or experiences of bona fide users of stem cell products or services.

The State of Georgia, along with 30 other states and the District of Columbia, participated in a $2.35 million multistate settlement with AdoreMe, Inc., a lingerie retailer that primarily sells its merchandise online. The settlement resolved claims that the company deceptively marketed its VIP Membership Program to consumers and then made it difficult for consumers to cancel their memberships. AdoreMe offered consumers discounted pricing if they enrolled in the company’s VIP Membership Program. Once enrolled in the program, consumers were charged $39.95 a month, unless before the sixth day of each month, consumers make a purchase from AdoreMe or logged into their AdoreMe accounts to “skip” the charge. The monthly charges accrued in the consumers’ accounts in the form of store credits, which could be used on future purchases.

The settlement alleged that AdoreMe failed to properly disclose to consumers the terms of its VIP Membership program and the amount of the monthly charge, specifically that it:

1. Misrepresented that AdoreMe’s discounted prices were time-limited;
2. Made it difficult for consumers to cancel their VIP Memberships; and
3. Improperly forfeited consumers’ VIP Membership store credits upon cancellation.

The settlement required AdoreMe to notify all consumers with active VIP Memberships of their ability to obtain a refund of any unused store credits. In addition, AdoreMe agreed to make certain changes to its business practices and is prohibited from engaging in any of the prior misconduct alleged in the settlement agreement.

Our office entered into a settlement with Tempoe, LLC resolving a multistate investigation into the company’s advertising and business practices.  Tempoe provided leasing to consumers through retailers across the nation, particularly retailers of durable goods, such as furniture and appliances. Tempoe also purported to lease services such as car repairs. The multistate investigation – which included 41 states and the District of Columbia – revealed that Tempoe’s marketing and sales practices often misled consumers to believe they were signing up for an installment plan or credit sale when, in reality, they were entering into a lease agreement for products that they could actually never own. The complicated structure of the lease agreements and the lack of required disclosures caused more confusion and often resulted in consumers paying two to three times the purchase price of the product or service.

Under the terms of the settlement, Tempoe is permanently banned from engaging in future consumer leasing activities. All existing leases will be cancelled, and consumers may retain the leased merchandise in their possession without any further financial obligation to Tempoe – resulting in approximately $33 million of “in-kind” financial relief to consumers nationwide. Additionally, Tempoe shall not provide negative information regarding lessees to any consumer reporting agency. Tempoe agreed to pay $1 million in penalties to the states and jurisdictions that participated in the settlement and $1 million to the Consumer Financial Protection Bureau, which agreed to a parallel settlement resolving the same alleged misconduct. 

Alpha Elements, PureHome Technologies, and Apex Home Technology (collectively “the Businesses”) offer home improvement products and services to consumers, including solar-powered fans, insulation, and other products and services purported to reduce homeowners’ energy usage, as well as mold and disaster remediation. The Attorney General’s Office alleged that the Businesses misrepresented the cost-savings consumers could expect from their products; represented that the Businesses had certifications and licenses that they did not have; and misrepresented both how long they had been in business and the number of homes/customers they had served. Our office further alleged that the Businesses falsely claimed that their competitors’ products were inferior to their own and that some of the Businesses’ products were endorsed by NASA, which was not the case. What’s more, the Businesses allegedly misrepresented the purpose of their sales presentations by promoting them as “strictly educational”; failed to provide the requisite notice of cancellation to consumers; misrepresented the finance charge associated with consumer credit transactions; and failed to properly identify and provide legally required information regarding their promotions.

In resolution of these allegations, the Businesses entered into a settlement to pay $125,000 to Georgia and to:

• Comply with the Fair Business Practices Act;
• Clearly and conspicuously disclose the purpose of any solicitation;
• Not misrepresent the benefits of their products or the qualifications of the businesses;
• Provide notices of cancellation consistent with the FTC Cooling-Off Rule; and
• Comply with the Truth in Lending Act.        

Should the Businesses fail to comply with the terms of the settlement during a multi-year monitoring period, they must pay an additional penalty of $1 million.

Choice Hotels International, Inc. entered into a settlement with our office regarding the disclosure of “resort fees.” The settlement comes alongside the settlements of five other state attorneys general namely, Colorado, Nebraska, Nevada, Oregon, and Pennsylvania.

Over the years, travelers have been reportedly misled by the published rates offered by hotels for a night’s stay only to later learn of “resort fees” through the hotel industry’s practice of “drip pricing,” where the rate initially advertised does not include additional mandatory fees. With the drip pricing method employed by many hotel chains and online travel agencies, fees are gradually disclosed to consumers as they go through the booking process. Customers often don’t learn the total price of their booking, room rate plus resort fee, until the last page in the online booking process, or sometimes until they check in at the hotel. The Attorney General’s Office argued that such a drip pricing model is deceptive and a violation of Georgia’s Fair Business Practices Act.

With these settlements, Choice committed to instituting a policy to be upfront and transparent in the disclosure of mandatory fees, including resort fees, as part of the total price of a hotel stay–which allows consumers to be able to compare total costs for hotels and find the one that is the best fit for them.  Choice agreed to prominently disclose the total price of a hotel stay, including room rate and all other mandatory fees, on the first page of its booking website as part of the total room rate.

The Attorney General’s Office alleged that Internet Networx sent businesses unsolicited, deceptive mailers prompting them to renew their website’s domain name. In actuality, these mailers prompted businesses to renew their listing on an online directory, a fact which our office alleged is not clearly and conspicuously disclosed in the solicitation. Furthermore, complainants claim they never contacted Internet Networx for service, nor did they previously have a contract with the company.

The company settled these allegations by agreeing to bring its marketing and sales practices into compliance with the Fair Business Practices Act, paying $2,522 in restitution, and paying $26,000 in civil penalties. A portion of the civil penalties will be waived if the company does not violate any terms of the settlement between the date the agreement was executed and September 2025.

ISA Plus, LLC has agreed to cease illegal collection activities against certain former Prehired, LLC students in Georgia.

Prehired operated an online software sales training program around the country, including in Georgia. Students paid for the online classes through income-sharing agreements that required graduates to pay thousands of dollars back to Prehired upon reaching a certain income threshold. However, not only did Prehired allegedly make deceptive claims concerning graduates’ employability and projected salaries, it lacked the required license to operate an educational institution, which rendered the income-sharing agreements void and unenforceable. Prehired filed for bankruptcy amid investigations by state attorneys general.

ISA Plus, LLC, a California company, had purchased a subset of these income-sharing agreements accounts from Prehired and had started collecting on them. Because the income-sharing agreements accounts for Georgia students were illegal and void, our office alleged that all collection activities against the Georgia income-sharing agreements accounts are contrary to law. Per the settlement, ISA Plus must permanently cease collection activities on all Prehired Georgia income-sharing agreements accounts that it owns, resulting in a total of $413,257.01 in relief for Georgia students.

Skybooker is a Texas-based business that offered travel services, such as airline flight booking to consumers via its website, www.skybooker.com. Skybooker had, at one point, represented that its principal office address was in Georgia, however, the business was not registered with the Georgia Secretary of State. Skybooker is now registered in Texas.

Consumers filed complaints with our office and the Better Business Bureau, alleging that Skybooker refused to issue full refunds for airline-cancelled flights that consumers booked and paid for through Skybooker. The company represented on its website that it had been issuing refunds to consumers whose flights were cancelled as a result of Covid-19, though consumer complaints suggested the business was not diligently addressing the issues and that material terms were not clear. These practices violate the Fair Business Practices Act.

Our office’s investigation revealed that Skybooker and its owner, Quereshi, to the extent that they operate in Georgia going forward, will need to significantly update their websites and advertisements to ensure that material terms are clearly and conspicuously disclosed. The business entered into a settlement that included specific injunctive provisions which require clear and conspicuous disclosures of material terms, including refunds, fees, and cancellation policies. Skybooker and Quereshi must pay a civil penalty of $10,000 immediately, and additional $40,000 will be assessed if the business fails to meet certain conditions.