UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION

In the Matter of

COMPUTRADE LLC, a corporation, and BERNARD LEWIS, individually and as an officer of the corporation.

DOCKET NO.

COMPLAINT

The Federal Trade Commission, having reason to believe that CompuTrade LLC, a corporation, and Bernard Lewis, individually and as an officer of the corporation ("respondents"), have violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the public interest, alleges:

1. Respondent CompuTrade LLC is a Nevada corporation with its principal office or place of business at 24591 Del Prado, Dana Point, CA 92629.

2. Respondent Bernard Lewis is an officer of the corporate respondent. Individually or in concert with others, he formulates, directs, or controls the policies, acts, or practices of the corporation, including the acts or practices alleged in this complaint. His principal office or place of business is the same as that of CompuTrade LLC.

3. Respondents have advertised, offered for sale, sold, and distributed a currency trading computer program and training to the public. Respondents advise their clients to buy and sell specific foreign currencies on a daily basis. Respondents sell their program and training through their Internet Web sites, www.computrades.com and www.computrader.net.

4. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.

5. Respondents have disseminated or have caused to be disseminated Internet advertisements for their currency trading program and training, including but not necessarily limited to the attached Exhibit A, pages 1 through 8. These advertisements contain the following statements:

"Our software signals precisely when to buy and when to sell a particular currency allowing you the opportunity to make money regardless of the market going up or down."

"Your [currency trading] business does not require much capital to get started, has the potential to make huge profits . . ."

"With the ability to connect to the Internet from just about anywhere, the average individual now has the opportunity to participate in this highly profitable [currency trading] business even if you have no previous experience at all."

"The potential for profit exists as long as there is movement in the exchange rate (price). One of the sides of the pair is always gaining, and providing the investor picks the right side at the right time, money can ALWAYS be made."

"What Are My Expected Financial Rewards

Our daily objective is to gain Pips (Points) on our trade . . . 100 Pips @ $7.50 = $750.00

As you progress in your trading skills becoming more experienced and skillful, the advanced techniques covered in training and outlined in your manual, will help you to acquire the know how to maximize and increase these amounts considerably.

The potential to make a SIX or SEVEN figure annual income from trading is at the end of your fingertips."

"What Are My Financial Risks?

Our trading strategy and risk management technique, help you to maximize gains and minimize losses. Your computer and our conservative strategy helps to ensure that GAINS are maximized and losses are minimized."

[consumer testimonial]

"I have to tell you how dramatically the Forex trading system and formula have improved my trading. To give you some idea: I work full time in my contracting business during the day, at night I work with your trading system for a few hours and am averaging more than $500 a day."

6. Through the means described in Paragraph 5, respondents have represented, expressly or by implication, that:

a. Users of respondents' currency trading program can reasonably expect to earn large profits, or as much as six or even seven figures annually (i.e., more than $1,000,000).

 

b. Users of respondents' currency trading program can reasonably expect to earn profits of $500 to $750 or more per day.

 

c. Users of respondents' currency trading program can reasonably expect to earn huge profits even if they have no previous experience in currency trading.

 

d. Testimonials appearing in the advertisements for respondents' currency trading program reflect the typical or ordinary experience of members of the public who use the program.

7. Through the means described in Paragraph 5, respondents have represented, expressly or by implication, that they possessed and relied upon a reasonable basis that substantiated the representations set forth in Paragraph 6, at the time the representations were made.

8. In truth and in fact, respondents did not possess and rely upon a reasonable basis that substantiated the representations set forth in Paragraph 6, at the time the representations were made. Therefore, the representation set forth in Paragraph 7 was, and is, false or misleading.

9. Through the means described in Paragraph 5, respondents have represented, expressly or by implication that users of respondents' currency trading program can reasonably expect to trade with little financial risk.

10. In truth and in fact, users of respondents' currency trading program cannot reasonably expect to trade with little financial risk. Therefore, the representation set forth in Paragraph 9 was, and is, false or misleading.

11. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

THEREFORE, the Federal Trade Commission this day of , 2000, has issued this complaint against respondents.

By the Commission.

Donald S. Clark
Secretary

SEAL