STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL

DEPARTMENT OF LEGAL AFFAIRS

IN THE INVESTIGATION OF: L12-3-1121

GLOBAL CONNECTIONS, INC. a/k/a GLOBAL DISCOVERY VACATIONS, PREMIUM DESTINATIONS, LLC, GVV, FLORIDA, INC. d/b/a GLOBAL VACATION NETWORK and GLOBAL ·VACATION VENTURES, INC.,

AGENCY

RESPONDENTS.

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ASSURANCE OF VOLUNTARY COMPLIANCE FOR GLOBAL VACATION VENTURES, INC.

FILE NO.

Pursuant to the provisions of Chapter 501, Part II, Florida Statutes, the Office of the

Attorney General, Department of Legal Affairs, State of Florida ("Attorney General") has

investigated the business practices of GLOBAL VACATION VENTURES, INC. (hereafter

corporately and/or alternatively referred to as "GVV" or "RESPONDENT").

RESPONDENT has voluntarily and fully cooperated with the Department's

investigation; denies having failed to comply with any applicable provisions of Florida law and

now agrees to enter into this Assurance of Voluntary Compliance (AVC), without any admission

of wrongdoing or the adjudication of any fact or law in order to amicably resolve the Attorney

General' s investigation.

Pursuant to Section 501.207(6), Florida Statutes, the Attorney General agrees to accept

this A VC in termination of its investigation of RESPONDENT solely as to the acts and

practices which were the subject of the Investigation. All Parties to this AVC agree that the

tenns and conditions of this AVC are fair, reasonable and consistent with the public interest and

the doctrines of applicable law.

Tiris AVC is made without trial or adjudication of fact or law and is being entered into

for the sole purpose of amicably resolving disputed claims regarding this Irivestigation, absent

the necessity of protracted and expensive litigation. The Attorney General and

RESPONDENT have negotiated the terms of this A VC in good faith and have entered into this

A VC to bring this matter to an agreed resolution. Neither the fact of any provision contained in

this AVC nor any action taken hereunder shall constitute, or be construed, as an admission by

RESPONDENT for any purpose, of any fact or any violation of any state law, rule, or

regulation. Further, this AVC neither constitutes evidence of any liability, fault, or wrongdoing . by RESPONDENT or its concession as to the validity of the Investigation. Finally, this AVC

is not evidence of an approval, sanction or authorization by the Attorney General of any act or

practice of RESPONDENT.

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The obligations imposed under this AVC are continuing in nature and shall apply to and

be binding upon RESPONDENT whether it is acting through its principals, officers, directors,

shareholders, representatives, employees, agents, independent contractors, successors and

assigns, or acting through any limited liability company, corporation or other business entity

whose acts, practices or policies are directed, formulated, or controlled by RESPONDENT.

I. ATIORNEY GENERAL'S ALLEGATIONS (WITHOUT ADMISSION OF WRONGDOING OR WRONGFUL INTENT BY GLOBAL VACATION VENTURES, INC.)

1. Respondent, GLOBAL VACATION VENTURES, INC., is an active State of Florida

corporation established in or around 2004, with its principal office located in West Palm Beach,

Palm Beach County, Florida. GLOBAL VACATION VENTURES, INC. is a Florida-based . Distributor of GLOBAL CONNECTIONS, INC. vacation club and travel services products.

2. GLOBAL VACATION VENTURES, INC. is a licensed Florida seller of travel which

markets and sells vacation club and travel services products to consumers in Florida.

3. Beginning in or around at least 2010, the Office of the Attorney General for the State of

Florida began receiving complaints from consumers who claimed that they were deceptively

induced into attending vacation club and travel services seminars sponsored by certain

Florida-based distributors of vacation club and travel services products of GLOBAL

CONNECTIONS, INC. which is located in Overland Park, Kansas.

4. GVV denies it engaged in any wrongful or unlawful conduct and contends that its

·business practices were and are consistent with industry best practices and that fair and adequate

disclosures were and are made to consumers. Regardless, after the Attorney General made GVV

aware of the consumer complaints and throughout the investigation, GVV, although it disputed

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the basis for such consumer complaints, fully and completely cooperated with the Attorney

General in its investigation, addressed such consumer complaints, and made certain voluntary

modifications to its business processes and procedures to reduce or eliminate the possibility of

consumer confusion or dissatisfaction.

's. The Attorney General and RESPONDENT have negotiated the terms of this AVC in

good-faith and have entered into this AVC to bring this matter to an agreed resolution. This

A VC constitutes the full and final resolution and termination of the Attorney General's

Investigation and the release of all potential civil claims, if any, between the Attorney General

and GVV relating to the matters investigated. Neither the fact of, nor any provision contained

in this AVC; nor any action taken hereunder shall constitute, or be construed as: (a) an admission

by RESPONDENT for any purpose, of any fact or of any violation of any state law, rule, or

regulation, nor does this agreement constitute evidence of any liability, fault, or wrongdoing by

RESPONDENT; or (b) a concession by RESPONDENT as to the validity of any consumer

complaint; or ( c) an approval, sanction or authorization by the Attorney General of any act or

practice of GVV.

II. NON-MONETARY TERMS AND CONDITIONS

6. In order to promote customer confidence in RESPONDENT'S business and in

recognition of the mission of the Office of the Attorney General to promote and ensure fair

consumer trade practices in the State of Florida, RESPONDENT, whether it is acting through its

principals, officers, directors, shareholders, representatives, employees, agents, independent

contractors, successors and assigns, or acting through any limited liability company, corporation

or other business entity whose acts, practices or policies are directed, formulated, . r controlled

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by RESPONDENT, shall comply with and not violate any applicable law, rule, regulation

including, but not limited to, the provisions of Chapter 501, Part II, Florida's Deceptive and

Unfair Trade Practices Act, and F.S. § 817.415 (the Florida Free Gift Advertising Law).

7. RESPONDENT shall not distribute within the State of Florida either directly or by an

independent third party on its behalf any advertisements and/or offerings to the public which use

the word "free," including the use of terms such as "awarded," "prize," "absolutely without

charge," "free of charge," and words or groups of words of similar intent which reasonably lead

a person to believe that he or she may receive, or has been selected to receive, something of

-value, entirely or in part without a requirement of compensation in any form from the recipient, ·

unless the item or portion of an item unconditionally offered as "free" shall in fact be free,

without obligation or requirement of consideration in any form. However, any person so

receiving and accepting such offer may be required to pay any necessary transportation or

delivery charges directly to the United States Postal Service or other regulated public carrier

provided that such charges are disclosed in the offer.

8. RESPONDENT shall further not distribute or make any statements within the State of

Florida either directly or by an independent third party on its behalf any advertisements and/or

incentives to the public which offer items as free with conditions or obligations necessary to

acceptance, including travel to a pick up location, unless the advertisements and/or incentives

' clearly and conspicuously disclose all conditions and/or obligations 1 including but not limited

1 "Clear and Conspicuous" or "Clearly and Conspicuously", except as otherwise indicated, shall mean a statement that, regardless of the medium in which it is made, is readily understandable and presented in such size, color, contrast, duration, location, and audibility, compared to the other infonnation with which it is presented, that it is readily apparent to the person to whom it is disclosed. If a statement modifies, explains, or clarifies other information with which it is presented, it must be presented in proximity to the information it modifies in a manner that is readily apparent and understandable.

5 e).

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to the following:

a. Any fees or costs relating to the travel;

b. When such fees or costs are due; and

c. The ratio or percentage of marketing incentives issued to conswners who

attended one of RESPONDENT'S sales presentations during the preceding

year versus the number of conswners who attempted to redeem and who

actually received the marketing incentives provided by RESPONDENT at

sales presentations.

Failure to disclose this information in writing constitutes an unfair and deceptive trade

practice pursuant to chapter 501. Any contract entered into in violation of this subsection is void

and the purchaser is entitled to a full refund of any moneys paid to RESPONDENT.

9. RESPONDENT shall use commercially reasonable efforts to ensure that at least ninety

percent (90%), measured on a rolling 12-month basis, of all consumers who are offered, and in

turn accept, a marketing incentive or other item of value in connection with consumers'

attendance at RESPONDENT'S sales presentation, utilize said marketing incentive or other

item of value no later than one (1) year from the date upon which a consumer attends one of

RESPONDENT'S sales presentations. By way of example only, if 100 consumers are offered a

free cruise, attend a presentation and seek to attend the free cruise within one year, at least 90 of

those consumers must be able to book and/or attend the offered cruise within the year.

10. To further support compliance and the above referenced disclosures, RESPONDENT

shall publish all terms and conditions associated with each promotional item offered to

consumers by GVV within the State of Florida either on such promotional item or via an Internet

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website stated on any promotional item and shall not materially overstate the cash value of the

promotional item.

11. To the extent that GLOBAL VACATION VENTURES, INC. engages any third-party

marketing entities to prepare and distribute (or to assist in such preparation and distribution of)

advertisements or similar communications to consumers and/or schedule (or to assist in the

scheduling of) appointments with consumers to attend vacation club and travel services seminars

conducted or sponsored by or on behalf of GVV within the State of Florida, t.lien (a) GVV shall

.exercise commercially reasonable diligence in engaging only legally-compliant third party

marketing entities; (b) GVV shall provide notice to each engaged third-party marketing entity of

the requirements detailed above in Paragraphs 7 and 8; and (c) and GVV shall discontinue such

engagement in the event GVV receives written notice that such third-party marketing entity has

repeatedly failed or refused to comply with such requirements or with other applicable laws.

12. GVV agrees when advertising to the public, extending marketing incentives and/or

conducting vacation club package seminars to the public, not to misrepresent which business

background information being presented to the public relates to the local distributor and which

background information relates to any larger fulfillment provider, including, but not limited to,

GLOBAL CONNECTIONS, INC. GVV further agrees not to make any misrepresentations

to consumers with respect to: 1) the identity of the company selling the vacation club and

travel services products; 2) the identity of the company which is the actual fulfillment center

for the vacation club and travel services products; 3) which company's BBB ratings are being

displayed or provided; 4) the number of consumers served by GVV over a particular period of

time and/or length of time; and 5) the length oftime that GVV has been in the business of selling

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the product which is the subject of the vacation club and/or travel services packages seminar

and/or any other being seminar conducted by GVV.

13. Respondent, GLOBAL VACATION VENTURES, INC., agrees to provide consumers

attending sales presentations with access to view a date-specific list of destination-based

properties currently available for reservations through the travel club program during the

succeeding twelve".'month period via a web page or print-out hard copy of the webpage

containing such information. Respondent, GLOBAL VACATION VENTURES, INC.,

further agrees. to clearly disclose to consumers during sales presentations where the list may be

found on the Internet and how the list may be accessed. Consumers who purchase a

membership from RESPONDENT shall have access to the list for at least three (3) days

following the date that the consumer signs the membership purchase agreement.

14. Respondent, GLOBAL VACATION VENTURES, INC., agrees not to make false or

misleading statements of fact concerning the reasons for, existence of or amounts of price

reductions as it relates to the sale of vacation club and travel services products.

15. Respondent, GLOBAL VACATION VENTURES, INC., agrees to accurately represent

during sales presentations for vacation club and travel services products, membership and

material membership characteristics, uses and benefits as set forth in the membership documents.

Further, RESPONDENT agrees to fully describe vacation club and travel services of the

membership that is, or will be, offered for sale, including pricing and options of such

membership.

16. Respondent, GLOBAL VACATION VENTURES, INC., agrees not to make any

statements materially inconsistent with the membership documents or misrepresent any fact or

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statement of fact material to the transaction such that a conswner reasonably believes the

represented or suggested state of affairs to be better than it actually is or otherwise failing to

reveal a material fact, the omission of which would reasonably tend to mislead a conswner.

17. Respondent, GLOBAL VACATION VENTURES, INC., agrees to fully describe the

vacation club and travel services products or membership options that are, or will be, offered for

sale.

18. Respondent, GLOBAL VACATION VENTURES, INC., shall continue with its

standard business practice of providing for a right to cancel the membership purchase agreement

without penalty for a period of three (3) calendar days from the date that the consumer signs the

membership purchase agreement, such three (3) day period starting the calendar day after the

date the conswner signs the membership purchase agreement. As stated in the membership

docwnents as of the date of this AVC, if the third calendar day falls on a Sunday or legal

holiday, then the right to cancel expires on the day immediately following that Sunday or legal

holiday.

III. MONETARY TER.i'1S AND CONDITIONS

A. ATTORNEYS' FEES, INVESTIGATIVE FEES AND/OR COSTS

19. Respondent, GLOBAL VACATION VENTURES, INC., agrees to pay a total of FIVE

THOUSAND DOLLARS AND ZERO CENTS ($5,000.00) in current and future attorneys'

fees, investigative fees and/or costs made payable by cashier's check or other certified funds to

the "Legal Affairs Revolving Trust Fund" and the payment due hereunder, along with the

original AVC bearing the notarized signature of RESPONDENT, will be simultaneously

delivered to the Office of the Attorney General.

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20. The payment described above shall be made payable as stated and shall be directed to the

attention of Assistant Attorney General Carol E. A. DeGraffenreidt, Office of the Attorney

General, 1515 North Flagler Drive, Suite 900, West Palm Beach, Florida 33401.

21. RESPONDENT'S interest in funds paid in conjunction with this AVC shall fully and

completely divest when the A VC is fully executed by all Parties.

IV. FUTURE VIOLATIONS

22. Provided that Respondent, GLOBAL VACATION VENTURES, INC., complies with

the terms of this A VC, no civil penalties shall be sought against it or imposed hereunder for any

conduct arising prior to the date of the execution of this A VC. However, in the event that

RESPONDENT fails to comply with the terms and conditions of this AVC, then such actions

are by statute prima facie evidence of a violation of Chapter 501, Part II, Florida Statutes as to

RESPONDENT, and may subject RESPONDENT to any and all civil penalties and sanctions

authorized by law. For a two (2) year period commencing upon the Effective Date and

terminating two (2) years thereafter, for the purpose of resolving disputes with respect to

RESPONDENT'S compliance with this A VC, should the Attorney General have a reasonable

basis to allege that RESPONDENT failed to comply with the terms of this A VC, then the

Attorney General will notify RESPONDENT in writing of the specific failure of compliance, I

identify with particularity the term(s) of this AVC that the practice appears to violate, and

provide RESPONDENT with thirty (30) days to respond to the notification. Nothing in this

provision shall preclude the Attorney General from instituting any action or proceeding to

enforce this AVC in accordance with Florida Statute §501.207(6).

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23. Respondent, GLOBAL VACATION VENTURES, INC., moreover consents to venue

and jurisdiction for any proceedings necessary to enforce the terms of the AVC, within the

Fifteenth Judicial Circuit Court, in and for Palm Beach County, Florida.

V. MISCELLANEOUS TERMS

24. Respondent, GLOBAL VACATION VENTURES, INC., shall further ensure that the

terms and conditions detailed under "II. NON-MONETARY TERMS AND CONDITIONS"

on Page 4 of this AVC are known to its representatives, agents, employees, managers, officers,

directors, assigns, successors, independent contractors and/or any other persons acting under, by,

through or on its behalf. The obligations imposed by this AVC are continuing in nature and shall

apply to RESPONDENT'S successors and assigns as well as any and all new representatives,

,agents, employees, managers, officers, directors, assigns, successors, independent contractors,

any other person acting under, by, through or on its behalf and/or any other persons who become

engaged in the business activities of RESPONDENT whose acts, practices or policies are

directed, formulated, or controlled by GLOBAL VACATION VENTURES, INC.

25. RESPONDENT, including its officers, directors, shareholders and/or employees, shall

not implement any change in the form of doing business or the organizational identity of any of

the existing business entities or create any new business entities as a method of avoiding the

obligations and terms and conditions set forth in this A VC. This provision should not be

construed to prevent GVV from changing its name or its form of doing business so long as the

successor business is bound by the provisions of this AVC.

'26. RESPONDENT shall preserve and retain all relevant business and financial records

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relating to the acts and practices at issue in this AVC and other information reasonably sufficient

to establish compliance with the provisions of this A VC for two (2) years from the date of this

AVC, and shall make any and all books and records available to the Department within three (3)

business days of any reasonable request; provided, however, any information and/or materials

which RESPONDENT believes constitute a "trade secret", as defined in and/or are protected

from disclosure under F.S. Ch. 688, F.S. §812.081(1)(c), or §815.045 shall be brought to the

'attention of the Office of the Attorney General, and the Parties both agree to submit the disputed

matter(s) for expedited review and ruling by the Fifteenth Judicial Circuit Court, in and for Palm

Beach County, Florida.

27. Any personal or financial information of consumers and customers, in the custody,

control or possession of RESPONDENT shall be securely stored in such a manner as to

reasonably protect against inadvertent disclosure of consumer information. RESPONDENT,

including any representative, agent, employee, successor, and assign within its direction and

control, shall not, directly or indirectly, market, sell, share or otherwise disclose the name,

contact information, or financial information of any consumer or customer in its care, custody or

control except in accordance with applicable law.

28. Nothing herein shall be construed as a general waiver of any private right, cause of

action, or remedy of any private person against Respondent, GLOBAL VA CATION

VENTURES, INC. Similarly, nothing contained herein shall waive the right of Respondent,

GLOBAL VACATION VENTURES, INC., to assert any lawful defenses in response to a

consumer complaint.

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29. In consideration for RESPONDENT'S execution and delivery of this AVC and the fees

provided for in Paragraph 19, the Department is waiving pursuant to this settlement and in

consideration of RESPONDENT'S performance hereunder the civil penalties that might

otherwise be due for the alleged acts and practices at issue under Sections 501.2075 or 501.2077,

Florida Statutes, of up to $15,000 per violation in consideration of the parties' entry into this

AVC.

36. Upon entry of this A VC, and payment of all required current and future attorneys' fees,

investigative fees and/or costs and consumer restitution, the Office of the Attorney General shall

close its civil investigation into the acts and practices of Respondent at issue herein.

Notwithstanding any other provision of this AVC, nothing herein shall be construed to impair,

.compromise or affect any right of any government agency other than the Office of the Attorney

General for the State of Florida.

37. Respondent, GLOBAL VACATION VENTURES, INC., moreover consents to venue

and jurisdiction for the entry of a Final Judgment, or any other proceeding necessary to enforce

the terms of the A VC, within the Fifteenth Judicial Circuit Court, in and for Palm Beach County,

Florida.

38. The Attorney General and GVV agree that neither the existence of, nor the terms of this

AVC shall be deemed to constitute evidence, except as permitted by §501.207(6) in any action or

proceeding between the Parties involving a Released Claim to support a defense asserted by

GVV or any Releasee of res judicata, collateral estoppel, compromise and settlement, accord

'and satisfaction, release or other theory of claim preclusion, issue preclusion or other legal or

equitable defenses. This A VC shall not create any private rights or causes of action in any third

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parties.

39. This AVC is the final, complete, and exclusive statement of the parties' agreement on the

matters contained in this AVC, and it supersedes, terminates and replaces any and all previous

negotiations and agreements, injunctions, orders and instruments as may exist between the

parties. Other than any representation expressly stated in this A VC, the parties have not made

any representations or warranties to each other, and neither party's decision to enter into this

AVC is based upon any statements by the other party outside of those in this AVC. No change

or modification of this AVC shall be valid unless in writing and signed by both parties.

40. Although the Parties jointly participated in the negotiation of the terms articulated in this

AVC, no provision herein shall be construed for or against either Party on the grounds that any

one Party was more heavily involved in the preparation of the A VC and/or its terms.

41. The parties agree that nothing in this AVC shall be construed to prohibit

RESPONDENT from engaging in business in Florida in accordance with the terms of this AVC

and all applicable laws of the State of Florida in accordance with the terms of this A VC and all

,applicable laws of the State of Florida, nor shall be construed as relieving RESPONDENT of

the obligation to comply with all applicable laws. This A VC does not constitute an

endorsement or approval by the Attorney General of any of RESPONDENT'S business

practices and RESPONDENT shall make no representation to the contrary.

42. The Attorney General and RESPONDENT agree that if any of the substantive laws cited

in this AVC change due to amendment, repeal, or disposition by the legislature, an agency, or

court so that such change permits any action prohibited by any section of this A VC, that section

of this A VC shall be severed and shall no longer have any force or effect. The remaining terms

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and conditions of this A VC shall remain enforceable as if such illegal, invalid, or unenforceable

clause, section or other provision had not been contained herein.

43. It is a condition of each of the Attorney General's obligations under this AVC that

RESPONDENT has fully and timely performed all of RESPONDENT'S obligations under this

AVC.

44. Notice to either of the parties to this AVC shall made by overnight delivery or certified

mail at the addresses set forth below unless any party notifies the other party in writing of

'another address to which notices should be provided:

AS TO THE ATTORNEY GENERAL: Carol E. A. DeGraffenreidt Assistant Attorney General - Consumer Protection Division 1515 North Flagler Drive # 900 West Palm Beach, FL 33401 Office Telephone Number: (561) 837-5007 Facsimile No.: (561) 837-5109 Electronic Mail Address: carol.degraffenreidt@myfloridalegal.com

AS TO THE RESPONDENT: Matthew Inman, Director

GLOBAL VACATION VENTURES, INC. 801 S. Olive Avenue, Suite 1206 West Palm Beach, FL 33401 Electronic Mail Address: globalcri@yahoo.com

VI. EFFECTIVE DATE

45. The effective date (the "Effective Date") of this A VC shall be the date of its execution

and delivery by the Department of Legal Affairs. Acceptance by the Department of Legal

Affairs shall be established by the signature of the Division Director of the Consumer Protection

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Division. The receipt by the Department of Legal Affairs of any monies pursuant to the AVC

does not constitute acceptance by the Department of Legal Affairs, and any monies received

shall be returned to RESPONDENT in the event that this AVC is not accepted and fully

executed by the Department of Legal Affairs.

46. This AVC shall be subject to acceptance by the Office of the Attorney General,

Department of Legal Affairs, and shall be established by the signature of Deputy Attorney

General Patricia A. Conners. This A VC shall become effective on the "Effective Date," which

shall be the date upon which the Deputy Attorney General accepts and executes this AVC.

47. The receipt by the Office of the Attorney General, Department of Legal Affairs, of any

monies from RESPONDENT pursuant to this A VC does not constitute acceptance by the

Office, and any monies received shall be returned to RESPONDENT if the A VC is not accepted

and fully executed by the Office of the Attorney General, Department of Legal Affairs .

. 48. I, MATTHEW INMAN, Director of GLOBAL VACATION VENTURES, INC.,

a..ffirm, by my signature on the following page, that I have authority to execute this A VC on

behalf of GLOBAL VACATION VENTURES, INC.; that I am acting within the scope of my

authority as its corporate representative; and that I am hereby binding GLOBAL VACATION

VENTURES, INC. to the terms and conditions ofthis AVC.

48. This A VC may be signed in multiple counterparts, each of which shall be considered an

original, and all of which together will constitute one and the same agreement.

49. It is further agreed that email in .pdf format and facsimile copies of signatures and

notary seals may be accepted as original for the purposes of establishing the existence of this

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AVC, and this AVC may be executed in counterparts, the compilation of which all constitute the

full and final agreement of the Parties.

SIGNATURES FOLLOW ON SEPARATE PAGESS

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GLOBAL VACATION VENTURES, INC.

Agreed to and signed this t Sr day of tlJr'M~o 15, by the below-stated person

who stated and affirmed as follows:

BY MY SIGNATURE I hereby affirm that I am acting in my capacity and within my

authority as the Owner/Principal Officer of GLOBAL VACATION VENTURES, INC., and

that by my signature I am binding GLOBAL VACATION VENTURES, INC., to the terms and

conditions of this Assurance ofVoluntary Compliance.

By: CTOR

ON VENTURES, INC.

STATE OF FLORIDA ) 'COUNTY OF PALM BEACH )

BEFORE ME, this /Sf1'- day of IJ~. 2015, an officer duly authorized J,

to take acknowledgments in the State of fi-p1L1 ~ , personally appeared

MATTHEW INMAN who acknowledged before me that he executed the foregoing instrument

NO ARYPUBLI

M·~ T hosJiv (print, type or stamp commissioned name of Notary Public)

NORMAN T. FROSCHER

•

NOTAAYPUBUC STATE OF FLORIDA Camm# FF091505 EJCplreS 2/10/2018

.Personally known~ Produced Identification V (check one) Type of Identification Produced: fl.crt.f tfl /jf.,c(/~ Ct~~

18

FOR THE ATTORNEY GENERAL'S OFFICE

Signed this~y of~ 2015

, . -~--;~ Carol!£. A. D a nre1dt J\.ssistan.t Attorney ener Office of the Attorney General Consumer Protection Division Florida Bar No. 0642101 1515 North Flagler Drive, Suite 900 West P~ Beach, Florida, 33401 Telephone No.: (561) 837-5000 Facsimile No.: (561) 837-5109 Electronic mail: carol.degraffenreidt@myfloridalegal.com

Accepted this J. day of q~V

LKatherme . Kiziah South Florida Bureau Chief Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida.9 3340 l Telephone No.: (561) 837-5007 Facsimile No.: (561) 837-5109

'2015

Electronic mail: Katherine.Kiziah@myfloridalegal.com

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