MrFrank, I took that directly from "GlobeTel's" Wells notice... not Joe Monterosso's complaint. <a href="http://biz.yahoo.com/e/071012/gtem.pk8-k.html" target="_blank">http://biz.yahoo.com/e/071012/gtem.pk8-k.html</a> "and seeking as relief a permanent injunction, civil penalties, and disgorgement with prejudgment interest." Was "staring them in the face" to strong a characterization? Then just use the exact quote from GlobeTel's Wells Notice... "and seeking as relief a permanent injunction, civil penalties, and disgorgement with prejudgment interest."