- 2 -CLASS ACTION COMPLAINT
Clinically Proven and Doctor Approved Formula to give you…
Bigger, harder, longer lasting erections
Increased sexual stamina and sex drive
More powerful, intense orgasms
No more premature ejaculation
In reality, VigRX has no penis enlarging effects. VigRX does not produce bigger, harder, longer lasting erections, nor does VigRX increase sexual stamina and sex drive. Worse yet, promoted byoutrageously false advertising, the Defendants have intentionally targeted senior citizens, knowing thatthey are the consumers most likely to suffer from the type of erectile dysfunction that Defendantguarantees VigRX will alleviate. Defendants profit greatly from their consumer deception as itcharges unwary consumers upwards of $70 per box for a completely worthless product.3. Accordingly, Jason Jones (“Plaintiff”) brings this lawsuit, primarily to enjoin theongoing fraud, and secondarily to recover the money taken by this nefarious practice.
THE PARTIESA. Plaintiff.
4. JASON JONES (“Plaintiff”) is a resident of California who purchased VigRX Plus inearly 2010.
5. DM CONTACT MANAGEMENT LTD dba LEADING EDGE MARKETING INC.(“Defendant”) is the manufacturer of VigRX Plus, and is a corporation organized and existing under the laws of Canada with its principal place of business in Victoria, British Columbia. DM Contactdoes business in California and in nearly every state; it moved its purported corporate headquarters toCanada in a misguided effort to make it “judgment proof” in the United States.6. H&L WORLDWIDE, INC. (“Defendant”) is a distributor of and advertises VigRXPlus, and is a business entity organized pursuant to the laws of California that does business inCalifornia.