002-3024

UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION

In the Matter of

R.S. of HOUSTON WORKSHOP a company,
RONALD J. SCHOEMMELL, individually and as an owner and principal of the company and
VALDIMAR THORKELSSON, individually and as an owner and principal of the company.

DOCKET NO. C-3994

COMPLAINT

The Federal Trade Commission, having reason to believe that R.S. of Houston Workshop, a company; Ronald J. Schoemmell, individually and as an owner and principal of the company; and Valdimar Thorkelsson, individually and as an owner and principal of the company ("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 R.S. of Houston Workshop is an unincorporated entity, a d/b/a of Valdimar Thorkelsson, who filed a Certificate of Operation Under Assumed Name on November 17, 1997, in Harris County, TX ("company"), with its principal office or place of business at 1419 Diamond Brook Drive, Houston, TX 77062.

2. Respondent Ronald J. Schoemmell is a fifty percent owner and principal of the company respondent. Individually or in concert with others, he formulates, directs, or controls the policies, acts, or practices of the company, including the acts or practices alleged in this complaint. His principal office or place of business is the same as that of R.S. of Houston Workshop.

3. Respondent Valdimar Thorkelsson is a fifty percent owner and principal of the company respondent. Individually or in concert with others, he formulates, directs, or controls the policies, acts, or practices of the company, including the acts or practices alleged in this complaint. His principal office or place of business is the same as that of R.S. of Houston Workshop.

4. Respondents have advertised, offered for sale, sold, and distributed trading programs, trading methods and training to the public. Respondents advise their clients to buy and sell stocks on a daily basis. Respondents sell their program, method and training through their Internet Web site, www.rsofhouston.com.

5. 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.

6. Respondents have disseminated or have caused to be disseminated Internet advertisements for their trading program or trading method and training, including but not necessarily limited to the attached Exhibit A, pages 1 through 4. These advertisements contain the following statements:

"CAN TRADING REALLY BE MADE SIMPLE AND PROFITABLE? You Bet! Stop making trading more difficult than it should be. Let us show you how 4 incredibly simple techniques unlock the profit of the markets. So simple you will be amazed. You will say, "How did I never see this before , so simple yet so profitable?"

 

"This is your BEST chance of succeeding at trading. Let us show you what will last you a lifetime of profitable and enjoyable trading."

 

"Our method loves the volatility and we will show you how to trade these markets with LOW RISK."

 

"Trade a few hours in the evening or early AM and profit nicely."

 

"A more reasonable expectation is to average between $500-$750 pr. contract/day and look to make $2,500-$3,500 pr. contract/week. Of course you will have days when you make $2,000, $3,000 or even $5,000 but you won't be able to do that all the time. This is what the RS of Houston methodology is about, going for small consistent wins and hitting the occasional home run. This enables you to approach trading as a business and earn a consistent living from the markets."

 

"The RS of Houston methodology for trading works especially well for daytrading the S&P 500 due to its high intraday volatility. The methodology is also quite effective on several other markets in a daily time frame."

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

a. That users of respondents' trading program or trading method can reasonably expect to earn large profits, or as much as $2,000 to $5,000 per day on some days;

 

b. That users of respondents' trading program or trading method can reasonably expect to earn profits of $500 to $750 or more per day;

 

c. That users of respondents' trading program or training method can reasonably expect to approach trading as a business and earn a consistent living from the markets;

 

d. That users of respondents' trading program or trading method can reasonably expect to trade in volatile markets with low risk;

 

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

8. Through the means described in Paragraph 6, 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.

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

10. Through the means described in Paragraph 6, respondents have represented, expressly or by implication that users of respondents' trading program or trading method can reasonably expect to trade with little financial risk.

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

12. 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 twelfth day of January 2001, has issued this complaint against respondents.

By the Commission.

Donald S. Clark
Secretary

SEAL