state of florida attorney general of legal affairs office of the attorney...

STATE OF FLORIDA ATTORNEY GENERAL OF LEGAL AFFAIRS

OFFICE OF THE ATTORNEY GENERAL

IN THE MATTER O:F: Attorney General Case No. Ll0-3-1017 THE REGENT GROUP, INC., D/B/A ENCORE MARKETING INTERATIONAL

ASSURANCE OF VOLUNTARY COMPLIANCE

Pursuant to the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part 11.

Florida Statutes (2010), the STATE OF FLORIDA, OFFICE OF THE ATTORNEY GENERAL,

(''the Attorney General") caused an investigation to be made into certain business practices by

THE REGENT GROUP, INC., D/B/A ENCORE MARKETING INTERATIONAL ("ENCORE

MARKETING"), a Delaware corporation located at 4501 Forbes Boulevard, Lanham MD

20706.

Without admitting that it violated Florida law and for the purpose of resolving this matter

only, ENCORE MARKETING is now prepared to enter into this Assurance of Voluntary

Compliance ("A VC"), and the Attorney General by and through the Deputy Attorney General

accepts this A VC in termination of its inquiry pursuant to Section 501.207( 6), Florida Statutes.

MATTERS INVESTIGATED

1. ENCORE MARKETING markets and offers to Florida consumers over the

Internet and via the telephone membership programs ("Encore Membership Program(s)") which

offer benefits and advantages to members and for which ENCORE MARKETING charges

membership fees.

2. ENCORE MARKETING enters into agreements with marketing partners who

offer products and services to the public on the Internet and/or on television. When a consumer

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ORIGINAL ATTORNEY GENERAL COPY

visits the partner's website, or calls a telephone number advertised by the partner on television,

and after the consumer makes a purchase from the partner, ENCORE MARKETING offers the

consumer an opportunity to accept an offer to enroll in an Encore Membership Program.

ENCORE MARKETING generally offers a discount on future purchases from the partner or

other benefits in consideration for the consumer accepting the offer to enroll in the Encore

Membership Program.

3. Until approximately February 2010, ENCORE MARKETING obtained as a third

party post-transaction marketer consumers' credit or debit card information for purposes of

charging the activation and membership fees for the Encore Membership Program from the

marketing partner through a statement of authorization contained on the webpage or made

verbally through a call center. Since approximately February 2010, ENCORE MARKETING

required consumers to enter online or state over the phone their full credit or debit card

information for purposes of billing the activation and membership fees.

4. The Attorney General received complaints about ENCORE MARKETING from

Florida consumers who claimed they had not knowingly enrolled in Encore Membership

Programs. Pursuant to its statutory authority, the Attorney General caused an inquiry to be made

into the matters set forth above, as well as into ENCORE MARKETING's internal policies

regarding its Encore Membership Programs, including refund policies.

5. Among other things, the Attorney General reviewed records provided by

ENCORE MARKETING and interviewed constimers who had been charged by ENCORE

MARKETING. ENCORE MARKETING cooperated in all respects with the Attorney General's

investigation.



DEFINITIONS

6. For purposes of this A VC, ·'clear and conspicuous" or "clearly and

conspicuously" means readily noticeable and reasonably understandable. When evaluating

whether a statement contained within an advertisement or other representation is "clear and

conspicuous" for purposes of this A VC, the following factors must be considered and, if present,

indicate that the statement is clear and conspicuous:

(a) The statement must be sufficiently prominent in terms of size, location, color,

contrast and, if applicable, duration of appearance, sound and speed, as to be readily noticeable

to and reasonably understandable by persons to whom it is directed.

(b) Whether the statement stands alone.

( c) Whether the statement is expressed in plain and simple English.

(d) Whether the statement is in close proximity to any statement(s) that it purports to

clarify, or to which it is logically related.

(e) Whether the statement is consistent with other statement(s) within the

advertisement or other representation, and is not confusing.

(f) Whether the statement is presented without distractions that compete for the

attention of the consumer.

(g) Whether the consumer need not, in the case of a webpage, scroll down in order to

see the statement, and whether the statement is above any button the consumer must click on in

order to take action.

"Data Pass" means the passing of credit or debit card account information of a consumer

from an initial merchant to a third party for the purpose of enabling the third party to bill a sales



transaction between it and the consumer without the consumer providing or re-entering their

credit or debit card account information during that transaction.

7. Requirements concerning consumers set forth herein apply only to consumers

who are residents of Florida.

IT IS HEREBY AGREED BY THE PARTIES:

TERMS OF ASSURANCE OF VO LUNT ARY COMPLIANCE

8. ENCORE MARKETING, and its officers, directors, employees, agents and

representatives shall continue to comply with the Florida Deceptive and Unfair Trade Practices

Act, Chapter 501, Part II, Florida Statutes (2010).

9. DATA PASS. Data Pass from any marketing partner is prohibited in all

ENCORE MARKETING consumer transactions in Florida where ENCORE MARKETING acts

as a third-party Internet marketer. If any subsequent federal or Florida statute, rule or regulation

is enacted that allows the use of Data Pass by third-party Internet marketers, then Encore is

permitted to comply with that applicable law or rule. Otherwise, ENCORE MARKETING shalL

as it is currently doing, continue to obtain all consumer financial account information directly

from consumers when acting as a third-party Internet marketer.

10. ELECTRONIC MARKETING. Where it acts as a third-party Internet marketer

of Encore Membership Programs (or, if applicable, where it markets an Encore Membership

Program on the Internet without a marketing partner) ENCORE MARKETING agrees to the

following terms with respect to such marketing directed to Florida consumers:

(a) FINANCIAL OBLIGATIONS.

(i) The following statement shall appear clearly and conspicuously

immediately above any action button within any offer page for an Encore Membership Program



that indicates assent to or interest in the offer: "I agree to have my [credit or debit card, as

applicable] billed [each month or annually, as applicable] for my [name of applicable

membership program] until I contact ENCORE MARKETING [or the program] to cancel," or

terms substantially similar to this statement. ''Substantially similar" terms must include the

words "billed" or "billing," the word "cancel" and the applicable amount that the consumer

would be charged, monthly or annually as applicable, if the consumer does not cancel.

(ii) The following information shall appear clearly and conspicuously

in a stand-alone paragraph in close proximity to any action button within the offer that indicates

assent to or interest in the offer: the fact that the consumer will be charged until he or she

contacts ENCORE MARKETING to cancel; the amount the consumer will be charged initially,

if applicable, and the amount of the charge thereafter; the frequency of charges thereafter; the

name of the membership program; and a statement indicating that the consumer may cancel the

membership at any time, and providing a toll-free number and email address that may be

contacted to cancel. This information may not be provided below any action button within the

offer that indicates assent to or interest in the offer.

(iii) As well as an action button that may be used by consumers to

indicate assent or interest in the offer, every offer page shall include an action button that may be

used by the consumer to indicate a lack of assent or interest and which, if used by the consumer,

shall terminate the viewing of any further representations by ENCORE MARKETING. This

action button shall be clear and conspicuous and directly below the action button indicating

assent and viewable on the same page (without the need to scroll down) as the action button used

to indicate assent. The following statement in a stand-alone form shall appear clearly and

conspicuously immediately above or immediately to the side of the action button that indicates



lack of assent or interest: "No thanks, I am not interested in joining ENCORE MARKETING's

membership club," or a substantially similar statement. "Substantially similar" does not include

a statement to the effect that the consumer does not want a sum of money or other benefit.

(b) ACCOUNT INFORMATION.

(i) Consistent with Paragraph 9 above, the offer shall require that the

consumer provide all of the following information: The consumer's full 16-digit credit- or debit-

card number and expiration date. ENCORE MARKETING may not within any offer page

include a request to "confirm" account information. ENCORE MARKETING may not within

any offer page use any language that suggests that ENCORE MARKETING's request for

account information is necessary or required to complete any prior purchase by the consumer

from an ENCORE MARKETING marketing partner.

(c) RELATIONSHIP TO MARKETING PARTNER.

(i) ENCORE MARKETING shall clearly and conspicuously disclose

in all offer and confirmation pages, follow-up emails and fulfillment materials that it (A) is the

offerer and administrator of the membership program and (B) is unaffiliated with the marketing

partner whose dealings with the consumer led to ENCORE MARKETING's offer, using the

words "unaffiliated with [name of marketing partner]." ENCORE MARKETING shall also

clearly and conspicuously disclose in all offer pages that an offer is being made that is in

addition to any purchase the consumer made from a marketing partner.

(ii) lf a consumer is directed from a third-party retailer website to an

ENCORE MARKETING website that offers an Encore Membership Program, ENCORE

MARKETING will do one of the following:



(A) Include a disclosure on the slider indicating that by clicking it the

consumer will be leaving the retailer's website and be redirected to ENCORE

MARKETING's website;

(B) Include a separate screen that appears in the interim between the

slider and the offer page indicating that the consumer is leaving the retailer's

website and being redirected to ENCORE MARKETING's website; or

(C) Include a disclosure at the top of the offer page that states that the

consumer is no longer on the retailer's \Vebpage and is now on ENCORE

MARKETING's webpage.

11. CALL CENTEis..J0ARKETING, Where it acts as a third-party post-transaction

call center upsell marketer of Encore Membership Programs (or, if applicable, where it markets

an Encore Membership Program over the telephone without a marketing partner), ENCORE

MARKETING agrees to the following terms with respect to such marketing directed to Florida

consumers:

(a) FINANCIAL OBLIGATIONS. ENCORE MARKETING shall obtain

consumers' express agreement to be charged in the following manner: All inbound or outbound

call centers shall use, after a consumer is informed of any offer, a scripted statement that

communicates clearly and conspicuously that the consumer is being asked to agree to allow

ENCORE MARKETING to automatically charge his or her [credit or debit card, as applicable]

[the applicable charge following any trial period] every [month or year, or as otherwise

applicable] unless the consumer contacts ENCORE MARKETING to cancel. No further

language shall be communicated to the consumer unless the consumer first indicates his or her

clear and unambiguous assent, or declines to accept the offer. All scripts shall also clearly and



conspicuously inform consumers of a toll-free number that the consumer may use to cancel.

ENCORE MARKETING shall record, or cause to be recorded, all call center sales of Encore

Membership Programs and keep, or cause the call centers to keep, copies of such recordings for a

period of at least 24 months after enrollment in the Encore Membership Program.

(b) RELATIONSHIP TO MARKETING PARTNER. ENCORE

MARKETING shall clearly and conspicuously disclose in all call center scripts that (a) it is a

company separate from any marketing partner whose dealings with the consumer led to the

consumer's receipt of the ENCORE MARKETING offer, and (b) that an offer is being made that

is in addition to any purchase the consumer made with a marketing partner.

12. NOTICE OF BILLING. In membership materials sent to consumers following

their enrollment in any Encore Membership Program, the following information shall be

disclosed clearly and conspicuously: (i) that the consumer will be charged unless he/she contacts

ENCORE MARKETING to cancel, (ii) the amount of the charge, (iii) the frequency with which

the consumer will be charged thereafter unless he/she cancels, and (iv) that the consumer may

contact ENCORE MARKETING at its toll-free number or email address to cancel. This

disclosure shall be made in all welcome emails sent to consumers; these emails shall include in

the subject line: "Information about your membership in [name of applicable club)" or

''Welcome to [name of applicable club]." The disclosure shall also be made in one of the

following: (a) in the first paragraph of a welcome letter that is included in membership

packets/guides (in the same font size as the largest font size of the other language in the welcome

letter); (b) in the first paragraph on a separate sheet that comes with membership packets/guides.

which may be affixed to the top of the other materials or inserted in the first page of or directly

outside of the other materials (in the same font size as the largest font size of the other text in the



separate sheet); or (c) in the first two pages of the membership packets/guides (in the same font

size as the largest font size of the other disclosures on the page).

13. CANCELLATION AND REFUND POLICIES

(a) CANCELLATIONS.

(i) In all confirmation emails, fulfillment materials and on its

websites, ENCORE MARKETING shall provide a toll-free number, an email address and a

street address that members can use to cancel their enrollment in an Encore Membership

Program. Encore shall honor all cancellation requests it receives from consumers, regardless of

how those requests are received.

(ii) The toll-free number maintained by ENCORE MARKETING shall

be sufficiently staffed that consumers can readily speak to a representative from 10 a.m. to 7 p.m.

Eastern time Monday through Friday (excluding holidays). At all other times, E'.'-JCORE

MARKETING shall maintain an automatic answering device which allows consumers who wish

to effect a cancellation of their membership to an Encore Membership Program to communicate

their decision to do so.

(b) REFUNDS. For any Florida consumer enrolled in an Encore Membership

Program who contacts ENCORE MARKETING, states that he or she did not authorize a charge

or charges by ENCORE MARKETING and requests a full refond, ENCORE MARKETING's

customer service representative will provide a full refund without first offering a partial refund.

ENCORE MARKETING shall not represent to any Florida consumer who is enrolled in an

Encore Membership Program, who contacts ENCORE MARKETING, who makes reasonably

clear that he or she did not authorize a charge or charges by ENCORE MARKETING and who

requests a refund that refunds are not available, or that only partial refunds are available:



provided, however, nothing herein shall prohibit a Florida consumer from agreeing to receive a

partial refund. ENCORE MARKETING shall not tell Florida consumers that only a supervisor

can authorize the refund unless a supervisor is immediately made available to speak to the

consumer. This refund policy shall not apply if the Florida consumer used or afiirmatively

requested a benefit, directory or other service provided by or through ENCORE MARKETING

and ENCORE MARKETING has a record of the consumer's use or request of that benefit or

other service.

MONETARY RELIEF

14. ENCORE MARKETING shall pay the sum of One Million Dollars ($1,000,000)

for consumer restitution into a trust account of the law firm of Myron M. Cherry & Associates,

LLC, within thi11y (30) days of the Effective Date of this A VC. These funds shall be used to

make payments to consumers for refund claims made pursuant to Paragraphs 15 and 16. In the

event that any portion of the sum of One Million Dollars ($1,000,000) remains in the trust

account after the resolution of all claims filed by November 15, 2011, these funds, except for

Eighty Thousand Dollars ($80,000), shall be sent from the trust account by December 15, 2011,

to the Attorney General. The funds shall be sent via cashier's check made payable to the Legal

Affairs Revolving Trust Fund, to Allison Finn, Assistant Attorney General, Office of the

Attorney General, Department of Legal Affairs, PL-0 l, The Capitol, Tallahassee, Florida 32399-

1050, to be used for any of the purposes set forth in Section 501.207( 6), Florida Statutes. The

sum of Eighty Thousand Dollars ($80,000) shall be remitted as reimbursement to ENCORE

MARKETING for costs associated with the printing, mailing and maintenance of the account for

consumer restitution; and ENCORE MARKETING shall receive that sum of money to the extent

it remains in the trust account after payments are made to consumers pursuant to Paragraphs 15



and 16 (or, if less than Eighty Thousand Dollars ($80,000) remains after the payment of refunds,

whatever lesser amount remains in the trust account). In the event that the refunds requested by

the Florida consumers who received the letters pursuant to Paragraphs 15 and 16 below exceeds

One Million Dollars ($1,000,000.00), the refond amounts to be paid to those Florida consumers

shall be pro-rated accordingly (i.e., so that the refunds to Florida consumers who received the

letters pursuant to Paragraphs 15 and 16 below are capped at One Million Dollars

($1,000,000.00)). The Attorney General shall be provided with a detailed accounting concerning

the trust account, including a list of the names and contact information of all consumers to whom

funds were paid. Upon completion of the afore-mentioned procedures, the Attorney General

shall be given a notarized statement attesting to compliance with the terms of this A VC

concerning the trust account.

15. CONSUMER REFUND NOTICE.

(a) ENCORE MARKETING shall oversee the following consumer refund

notice and provide the Attorney General with written confirmation of the completion of all

requirements set forth in this Paragraph.

(b) Within thirty (30) days of the Effective Date of this A VC, ENCORE

MARKETING shall mail a Letter Notice in the form attached hereto as Attachment A, to all

Florida consumers who enrolled in an Encore Membership Program through the use of Data Pass

during the twenty-four (24) month time period prior to the Effective Date of this AVC and who

paid a monthly or annual membership fee to ENCORE MARKETING, except those consumers

that ( 1) used or affirmatively requested any benefit, directory or other service provided by or

through ENCORE MARKETING, or (2) have already received a full refund of their monthly or

annual membership fees.



( c) Envelopes containing the Letter Notices shall prominently state in a stand-

alone sentence on the front of the envelope, "This is a refund notice from Encore Marketing

International." The Letter Notice shall include a toll-free number, to be maintained by ENCORE

MARKETING, that consumers may call to find out the particulars of their membership(s),

including (a) the amounts they paid to ENCORE MARKETING, (b) the program(s) that they

were enrolled in and ( c) the date on which they became enrolled.

(d) ENCORE MARKETING shall provide full refunds to every Florida

consumer who requests a refund in response to this Letter Notice by November 15, 20 l l, and

may deduct from that sum any partial refund already provided to the consumer.

16. ACTIVE CONSUMER NOTICE.

(a) Within thirty (30) days of the Effective Date of this A VC ENCORE

MARKETING shall mail the letter in the form attached hereto as Attachment B to all Florida

consumers who are active members in an Encore Membership Program as of the Effective Date

of this A VC except those consumers that used or affirmatively requested any benefit directory

or other service provided by or through ENCORE MARKETlNG. The Letter attached hereto as

Attachment B shall also not be sent to consumers who are being sent the refund notice set forth

in Paragraph 15 above.

(b) The Letter referenced in Paragraph 16(a) above shall: (i) notify the

consumer that they are enrolled in an Encore Membership Program, (ii) provide a description of

the Encore Membership Program(s) (or applicable Encore Membership Program), (iii) provide

contact information for ENCORE MARKETING and (iv) be sent in envelopes that prominently

state in a stand-alone sentence on the front of the envelopes, "Notice of your paid membership in

an Encore Marketing International membership program."

12 FINAL EXECVTED COPY


(c) In the event that a Florida consumer contacts ENCORE MARKETING by

November 15, 2011, in response to the Letter referenced in Paragraph 16(a) requesting a full

refund and claiming that they did not authorize a charge or charges by ENCORE MARKETING,

ENCORE MARKETING shall provide a foll refund to such individual.

17. FEES AND COSTS. Within thirty (30) days of the Effective Date of this AVC,

THE REGENT GROUP shall pay the sum of Two Hundred Thousand Dollars ($200,000) for

attorneys' fees and costs of the investigation and future enforcement associated with this matter,

made payable to the Legal Affairs Revolving Trust Fund and sent to Allison Finn, Assistant

Attorney General, Office of the Attorney General, Department of Legal Affairs, PL-0 I, The

Capitol, Tallahassee, Florida 32399-1050, pursuant to Section 50l.2101. Florida Statutes.

RECORD-KEEPING

18. For four years after the Et1ective Date of this AVC, ENCORE MARKETING

shall retain copies of (a) complaints from Florida residents, and (b) all Encore Membership

Program representations including webpages and fulfillment materials directed at consumers in

Florida, and shall provide them to the Attorney General upon request. For two years after the

Effective Date of this A VC, ENCORE MARKETING shall retain copies of all recordings made

pursuant to Paragraph 11 (a) of this A VC, and shall provide them to the Attorney General upon

request.

MISCELLANEOUS PROVISIONS

19. Nothing in this A VC limits the Attorney General's ability to investigate and take

action regarding any business practices by ENCORE MARKETING apart from the Matters

Investigated as set forth above.



20. To the extent the provisions of this A VC conflict with any Florida, local or

federal law that exists, or is later enacted or amended, such law and not this A VC shall apply

where such conflict exists.

21. ENCORE MARKETING shall not represent directly or indirectly that the

Attorney General has approved any of its business practices.

22. This A VC is made without trial or adjudication of fact or law and is being entered

into for the sole purpose of resolving the Attorney General's inquiry without the necessity of

protracted and expensive litigation. This A VC does not constitute evidence or an admission of

any issue of fact by ENCORE MARKETING or any violation by ENCORE MARKETING of

any law, including but not limited to the Florida Deceptive and Unfair Trade Practices Act.

23. This A VC constitutes the full and final resolution between the Attorney General

and ENCORE MARKETING, its officers, directors, employees, successors and assigns of all

claims relating to ENCORE MARKETING's marketing to Florida residents that are the Matters

Investigated of this AVC, up to and including the Effoctive Date of this AVC.

APPLICABILITY

24. This A VC shall only apply to marketing directed to Florida consumers and in

connection thereto shall bind the officers, directors, employees, agents and representatives of

THE REGENT GROUP, INC., d/b/a ENCORE MARKETING INTERATIONAL as well as any

other business entity to which THE REGENT GROUP, INC. d/b/a ENCORE MARKETING

INTERA TIONAL sell, assign or otherwise transfer their assets. THE REGENT GROUP, INC.

d/b/a ENCORE MARKETfNG INTERNATIONAL shall notify any surviving corporation,

purchaser, assignee or transferee of the terms of this A VC and its binding effect upon the

surviving business, purchaser, assignee or transferee.



25. ENCORE MARKETING shall be responsible for making the substantive terms

and conditions of this A VC known to its officers, directors, employees, agents and

representatives, successors and assigns who are in any way involved in the preparation of

marketing materials for Encore Tv1embership Programs distributed to Florida consumers.

FUTURE VIOLA TIO NS

26. Violation of this A VC shall subject THE REGENT GROUP, INC. d/b/a

ENCORE MARKETING INTERNATIONAL to civil penalties and sanctions provided by law.

Pursuant to Section 501.207, Florida Statutes, a material violation of this A VC is prima facie

evidence of a violation of the Florida Deceptive and Unfair Trade Practices Act Section 50 l,

Part 11, Florida Statutes.

ACCEPTANCE

27. This A VC shall become effective upon its execution by THE REGENT GROUP,

INC. and the Deputy Attorney General (the "Effective Date").



FOR THE REGENT GROUP, I~. ,

,/f ~ ( /I~ ACCEPTED this dav of } • . VJ 2011. -- . I l/

sTATEOF M.AJL'tLAnD

COUNTY OF #vwfHl-J:)

STEPHEN KLEIN PRESIDENT OF REGENT GROUP, INC.

BEFORE ME, an officer duty authorized to take acknowledgments in the State of /1,J-fe.i~iD personally appeared _fl'c~ f;L,t:;-1.tV as f'/LeJ'/-./)E>-J/ and duly

authmized representative of ENCORE MARKETING and acknowledged before me that he

executed the foregoing instrument for the purposes therein stated, on this )151day of

J11-i .. __ 2011.

Personally Known ~ or

Produced Identification

Type of Identification Produced:

(print, type or stamp commissioned name of Notary)

Telesforol. .. NOTARY PUii.iC Howard County

-- f/I ........ Mv C.•111ton e.,. ,.,.,, ...•. , 16

FINAL EXECUTED COPY ORIGINAL ATTORNEY GENERAL COPY

FOR THE OFFICE OF THE ATTORNEY GENERAL

ACCEPTED this 3?-day of ~-A~~{-_ .. __ 2011.

-1\lM~ £1t!A_ ___ . __ ._ AC IS FINN ASSIST ANT ATTORNEY GENERAL OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS The Capitol, PL-01 Tallahassee, Florida 32399-1050 850-414-3600

TRISH CONNERS AS SOCIA TE DEPUTY ATTORNEY GENERAL OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS The Capitol, PL-01 Tallahassee, Florida 32399-1050 850-245-0140



ATTACHMENT A [Letter Notice]

[Date]

[Consumer name and address!

According to our records you enrolled in one of our membership programs, paid a recurring monthly membership fee and may continue to pay a monthly membership fee. Pursuant to an agreement with the Florida Attorney General, we are writing to inform you that if you believe that you never authorized your enrollment you may contact our office to cancel your membership and obtain a full refund or, if you have already cancelled but did not get a full refund, obtain a full refund at:

[toll-free number to be maintained by Encore Marketing] or (applicable email address] or Encore Marketing International Attn: Florida Program 4501 Forbes Boulevard Lanham, Maryland 20706

If you have any questions about your prior or current enrollment or payments, you may call us at [toll-free number to be maintained by Encore Marketing]. You may have become a member by either ( l) enrolling online after making a purchase on one of our partner's websites (in which case, after you completed your purchase, you were offered a gift code for your next purchase in exchange for agreeing to a trial membership), or (2) enrolling over the phone after making a purchase from one of our partners over the phone (in which case, after you completed your purchase, you were offered a gift card or some other benefit in exchange for agreeing to a trial membership).

If you are or were satisfied with your membership in one or more of these programs there is nothing for you to do in response to this letter. You are not eligible to seek a refund if you used or requested any of the premiums or benefits, directories or other services offered through the membership program, or if you knowingly authorized your enrollment. If you seek a refund you should keep a copy of your letter for your records, and you should allow 4-6 weeks for your refund request to be processed and issued.

Sincerely yours, [Encore Marketing International]



ATTACHMENT B

[date]

[Consumer name and address)

Dear

This letter is a reminder that you are currently a paying member of an Encore Marketing International consumer benefits program. You may be enrolled in Easy Saver, American Leisure or another one of our clubs.

[Description of ENCORE MARKETING membership programs, or applicable ENCORE MARKETING membership program in 12 lines or less].

Your membership will continue until it is cancelled. If you have any questions about your membership or Encore's benefits, please contact us at [toll-free number or email address to be maintained by Encore].

Sincerely yours,

[Encore Marketing International]



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