2 2.
They do this because Defendants lie to them. Defendants represent, and have represented, that paying more than $45,000 for a six month program (nine months for night and weekend courses) makes economic sense because, upon graduation, they would be immediately eligible for and attain Chef or other “top culinary jobs” that pay $60,000 and upwards—and that would otherwise take them years to reach, absent Defendants’ expertise, prestige, and industry connections. 3.
This is not hyperbole. Plaintiffs and the Class are current or former students at Defendants’ for-profit vocational school, the International Culinary Center (“ICC”). They paid tens of thousands of dollars in tuition to attend ICC because of Defendants’ false promises. 4.
They relied upon Defendants’ own website that promised prospective students that they could “walk straight into a top culinary job” once they graduated. (
See
Exhibit A at p. 2.) 5.
Being a Chef is hard work, but becoming a Chef is even harder. The recipe for success usually requires years of dedication and arduous work, at low pay, before kitchen staff employees are given the opportunity to rise up through the ranks. And, even with tons of discipline and all the right skills, there is usually no guarantee that one will attain such a high-level position. 6.
Defendants promised Plaintiffs that their $45,000 would buy them more than just a quality education. It would also buy them the prestige of a “French Culinary Institute” diploma (although that institution was technically defunct and nonexistent) that would allow graduates to skip the years of peeling carrots and attain Chef positions or other “top culinary jobs” immediately upon graduating. 7.
Those two terms, “Chef” and “top culinary jobs,” appear frequently in
3 Defendants’ written marketing material and scripted sales pitches. Indeed, “
Become a [Successful] Chef in 6 Months
” seems to be one of Defendants’ “go-to” advertising slogans. (A selection of Defendants’ online ads is attached as Exhibit B, with those using some variation of the “
Become a Chef in 6 Months
” pitch highlighted). 8.
Defendants further promised access to exclusive job placement services that would put recent graduates in touch with employers eager to place them immediately as Chefs or in other “top culinary jobs.” 9.
Put simply, Defendants promised that investing in an ICC education made economic sense, notwithstanding the high price tag. 10.
Defendants aggressively marketed this vision of an ICC education to prospective students through a pattern of partial truths, misleading statements, significant omissions, assertions of fact that the Defendants had no reasonable ground for believing to be true, and outright lies, all of which were designed to create, in the minds of Plaintiffs, the strong impression that they would be both professionally and financially better off if they attended ICC. 11.
Unfortunately, Defendants’ promises turned out to be half-baked. 12.
In fact, Plaintiffs received an education that is effectively worthless to them and ended up, at best, with jobs they could have obtained without paying tens of thousands of dollars for ICC educations. Members of the Class have had similar experiences. Many are saddled with non-dischargeable student loans that they cannot repay or service that cumulate interest, late charges, and collection costs. The result is balances due that spiral upward to create a condition of lifelong financial ruin and indentured servitude. 13.
All of this was known to the Defendants when they solicited Plaintiffs and other prospective students, but was not disclosed. They should be held accountable.