http://www.ftc.gov/opa/2006/05/datacom.htm "The defendantsââ?¬â?¢ own training documents instructed their telemarketers: TWO WORLDS: REAL WORLD: THEY HAVE NOT PAID PHONE WORLD: EVERYONE HAS BOUGHT BEFORE You canââ?¬â?¢t say they have done this before, or paid for this before. That is a lie. You are leading them to believe that they have paid/done this before. It is not your fault if they think they have done this before." ... "When the telemarketers call, they often do not identify their companyââ?¬â?¢s name, but instead say they are with the ââ?¬Å?Records Departmentââ?¬Â of one of the many directories that the defendants were hawking ... The defendants ask the business to confirm its name, address, and telephone number for the directory listing. After getting the listing information, another telemarketer would call back from the ââ?¬Å?shipping departmentââ?¬Â to verify the provided information for shipping. The defendants would record this telephone call and later use the recording as ââ?¬Å?proofââ?¬Â that the directoryââ?¬â?¢s purchase was authorized. When the businesses received the directories, they typically found them to be useless, and also reported that often listings were missing, incomplete, or inaccurate. About a week after shipping a directory, the defendants sent an invoice, typically for $399. They used a mail drop in Nashua, New Hampshire, as their ââ?¬Å?U.S. Mailing Address.ââ?¬Â Businesses that did not pay were harassed by the defendants. If that failed, the defendants turned over the accounts to a third-party collection agency, which continued to harass the small businesses and non-profits that the defendants typically targeted."
