SOMMERS SCHWARTZ, P.C.€¦ · LAN/WAN membership will enable individuals to get a high paying job...

CLASS ACTION COMPLAINT

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Trenton R. Kashima, Esq. (SBN 291405) [email protected] Kevin J. Stoops, Esq. (Pro Hac Vice Forthcoming) [email protected] SOMMERS SCHWARTZ, P.C. 402 West Broadway, Suite 1760 San Diego, California 92101 Telephone: (619) 762-2125 Facsimile: (619) 762-2127

Attorneys for Plaintiff and the Putative Class

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE COUNTY

MICHAEL RIANO, individually and on behalf of all others similarly situated,

Plaintiff, v.

GLOBAL NETWORKS ENTERPRISES & TECHNOLOGIES, INC. (doing business as LAN/WAN PROFESSIONAL), a California corporation; ERIC CHOI; PATRICK PULE; and DOES 1-50,

Defendants.

Case No:

CLASS ACTION COMPLAINT FOR:

1. VIOLATION CAL. CIV. CODE §§1750, et seq.;

2. VIOLATION OF CAL. BUS. & PROF.CODE §§ 17200, et seq.;

3. VIOLATION OF CAL. BUS. & PROF.CODE §§ 17500, et seq.;

4. VIOLATION OF CAL. CONST. ART.XV, § 1;

5. VIOLATION OF 15 U.S.C. §§ 1601 etseq.;

6. VIOLATION OF 18 U.S.C. §§ 1961 etseq.;

7. VIOLATION OF 15 U.S.C. §§ 1681b etseq.; and

8. VIOLATION OF 28 U.S.C. §§ 2201 etseq.

JURY TRIAL DEMANDED

Electronically Filed by Superior Court of California, County of Orange, 12/19/2019 01:57:42 PM.DAVID H. YAMASAKI, Clerk of the Court By Sarah Loose, Deputy Clerk. 30-2019-01119457-CU-BT-CXC ROA # 2

Assigned:

Dept: CX101

- 1 - CLASS ACTION COMPLAINT

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Plaintiff Michael Riano (“Plaintiff”) individually and on behalf of similarly situated, based on

the investigation of counsel and his own individual knowledge as to Plaintiff’s own circumstances,

hereby complain against defendants Global Networks Enterprises & Technologies, Inc. (doing

business as LAN/WAN Professional), Eric Choi, Patrick Pule, and Does 1-50 as follows (collectively,

“Defendants”):

I. INTRODUCTION

1. Defendants operate LAN/WAN Professional which is advertised as an exclusive

professional organization affiliated with numerous high level Information Technology (“IT”)

professionals, major corporations, and government entities. But nothing could be further from the

truth. Instead, LAN/WAN Professional is an unaccredited IT academy that makes its students lofty

promises of increase pay and career advancement through their unique training and mentorship

program. LAN/WAN Professional, however, fails to deliver on these promises.

2. Instead, Defendants charge consumers tens of thousands of dollars for a few weeks of

the most basic network training and subsequent unethical career advice. Prospective students are

then forced to repay the fees associated with Defendants’ LAN/WAN Professional “educational”

programs through illegal loans that are secured by students’ future income. Indeed, students are

forced to pay Defendants approximately 30 percent of their income until these loans are paid.

3. Plaintiff brings this proposed class action lawsuit on behalf of himself and other

individuals who were deceived by Defendants’ false and misleading advertisements, and paid for

Defendants’ unconscionable school fees secured by illegal loans

II. JURISDICTION AND VENUE

4. This Court has jurisdiction over this action pursuant to Article 6, § 10 of the California

Constitution, Code of Civil Procedure, sections 382 and 410.10, and Civil Code, section 1781.

5. This Court has jurisdiction over Defendants because they are registered to conduct,

and/or do conduct, substantial business within California and Orange County including providing

educational camps within Orange County.

6. Venue is proper in this Court pursuant to Code of Civil Procedure § 395 because

Plaintiff was provided services by Defendants in this County, and a substantial or significant portion


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of the conduct complained of herein occurred and continues to occur within this County. The

Corporate Defendant is headquartered in this County and Defendants improper business practices and

wrongful acts occurred, and continue to occur in Orange County.

III. PARTIES

7. Plaintiff Michael Riano, and at all times relevant hereto was, a resident of North

Carolina and a citizen of North Carolina. Plaintiff was a ‘student’ of LAN/WAN Professional from

April or May 2019 to the present.

8. Defendant Global Networks Enterprises & Technologies, Inc. is a California

Corporation with its headquarters in 7545 Irvine Center Dr. Suite 200, Irvine, California, 92618.

Global Networks Enterprises & Technologies, Inc. does business as LAN/WAN Professional and

markets itself as an IT mentoring and professional development organization that specializes in

helping professionals advance their career in the enterprise networking industry. Defendant Global

Networks Enterprises & Technologies, Inc. purportedly offers online and in-person network engineer

education programs, as well as IT career mentoring.

9. Defendant Global Networks Enterprises & Technologies, Inc.’s business model is to

solicit prospective students through its websites and other online marketing efforts, which promise to

drastically increase the person income by securing a job as an IT professional. However, Defendants’

program over promises and under delivers. In reality, Defendants’ services offer no appreciable

benefit.

10. To secure payment for these illusory services, Defendants enter into contracts with

prospective students that requires individuals to pay for their LAN/WAN Professional “education”

by promising to pay approximately 30 percent of their future income to Defendants. The operative

agreement between Defendants and each putative class member is the same and each contract is

expressly governed by California Law.

11. Defendant Eric Choi is the Chief Executive Officer of Global Networks Enterprises &

Technologies, Inc. and through it LAN/WAN Professional. Eric Choi is responsible for the creation

and maintained of Networks Enterprises & Technologies, Inc.’s business model, including those

unfair and unlawful business practices alleged herein.


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12. Defendant Patrick Pule is the Chief Financial Officer of Global Networks Enterprises

& Technologies, Inc. and Director of Member Relations at LAN/WAN Professional. Defendant Pule

is responsible for the creation and maintained of Networks Enterprises & Technologies, Inc.’s

business model, including those unfair and unlawful business practices alleged herein.

13. Plaintiff is informed and believes, and thereon alleges, that at all times relevant herein

each of the Defendant Does 1-50 were responsible in some manner for the occurrences and injuries

alleged in this complaint. Their names and capacities are currently unknown to Plaintiff. Plaintiff

will amend this Complaint to show such true names and capacities when the same have been

ascertained.

14. At all relevant times alleged in this matter, each Defendant acted in concert with, with

the knowledge and approval of, and/or as the agent of the other Defendants within the course and

scope of the agency regarding the acts and omissions alleged and are thus jointly and severally liable

for the allegations in this complaint.

IV. SUBSTANTIVE ALLEGATIONS

Defendants Falsely Advertise its Business as a Professional Organization

15. Defendants advertise their services primarily through online advertisements that

forward potential students to the LAN/WAN Professional’s website, https://www.lanwan

professional.com. Defendant states that it is a “nationwide professional IT membership

organization.” Defendants further state that “[w]e provide a comprehensive set of technical and

professional services designed to help individual members advance in their enterprise networking

careers, while also allowing our corporate clients access to LAN/WAN staff skills development along

with other LAN/WAN solutions services to advance their business/operational goals.”

16. Defendant Global Networks Enterprise and Technologies, Inc. represents that its

LAN/WAN Professional organization has “members” among some of the most respected companies

in the country:


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(See https://www.lanwanprofessional.com/home_index.php (last accessed on November 12, 2019).)

17. Indeed, Defendants suggest that LAN/WAN Professional is affiliated with a number of

major corporate, government, and non-profit entities:

https://www.lanwanprofessional.com/home_index.php?action=company_overview (last accessed on

November 12, 2019).

18. To create the appearance of exclusivity, Defendants advertise that their services “are

NOT AVAILABLE to the public and are ONLY AVAILABLE to our professional and corporate

members and affiliates.” But this is simply not true. Defendants are not affiliated with any legitimate

organizations, nor are its “members” top IT professionals. Instead, Defendants run an unaccredited

training program that seeks to capitalize on its students’ hopes for career advancement.1 These

advertisements are patently false and misleading, purposely designed to suggest that Defendants have

affiliations and sponsorships that it does not. Defendants only target and solicit their services to

ordinary consumers, most often with no significant IT background.

19. Defendants claim that a LAN/WAN membership is only reserve for pre-qualified

members. Defendants send applicants an email that states that they are “conditional” approved based

on the applicants’ “professional/educational history” and continue to state that “along with the skills

1 LAN/WAN Professionals is not a school or university as specifically disclaimed on its website.


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that you will acquire with LAN/WAN Professional, will enable you to secure timely employment in

LAN/WAN earning $72,000 to $90,000 per year within 1 to 2 (Unemployed Candidates) to 2 to 3

months (Working Candidates) of placement camp completion and full certification and attain

upgraded employment earning $90,000 to $120,000 within 6 to 12 months of initial LAN/WAN

employment.” (See Exhibit A.) Defendants affirmatively advertise and warrant that their exclusive

LAN/WAN membership will enable individuals to get a high paying job in enterprise level

networking.

20. In reality, a LAN/WAN membership is worthless, as is their training program.

Defendants’ only business model is to charge its students tens of thousands of dollars for a few weeks

of subpar training and advice on how to misrepresent their qualifications to future employers.

Defendants’ self-serving motivation is made clear by the fact that students are not qualified for

potential LAN/WAN membership by their “professional/educational history.” Instead, Defendants

sole qualification is a credit check, to ensure that applicants can pay Defendants’ inflated and illegal

student loans. Again, these representations are false and misleading and Defendants’ use of credit

checks without proper authorization is a violation of the Fair Credit Reporting Act (“FCRA”).

21. LAN/WAN Professional membership is also advertised a key to securing a job that

earns “$72,000 to $90,000 per year within 1 to 2 (Unemployed Candidates) to 2 to 3 months (Working

Candidates) of placement camp completion and full certification and attain upgraded employment

earning $90,000 to $120,000 within 6 to 12 months of initial LAN/WAN employment.” Defendants

have no basis for making such claims. Defendants misrepresent their employment rates and earnings

of their graduates in advertisements and other communications. Such false and misleading statements

are illegal and actionable under California law, which governs the contractual relationship between

the parties.

Defendants’ Deceptive Sales Tactics

22. To persuade potential students to spend tens of thousands of dollars on a worthless

membership, Defendants advertise that potential students can try Defendants’ services without any

commitment. Defendants warrant that consumers can try their program before committing to make

any payments. For example, Defendants state that “LAN/WAN Professional has one of the most

- 6 -CLASS ACTION COMPLAINT

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extensive vetting process for becoming a member of our organization, including receiving 100 to

over 150 hours of services over a period of 1 to 2 months BEFORE becoming a member and BEFORE

signing any significant agreements that obligates these members.” (https://www.bbb.org

/us/ca/irvine/profile/professional-services/lan-wan-professional-1126-100102804/complaints (last

accessed on November 12, 2019).) Similarly, Defendants advertise that “LAN/WAN Professional

has developed a TWO-STEP process (see below) that allows qualified candidates to personally "Test

Drive" our service prior to making any commitment and allows LAN/WAN Professional to fully

validate you before we approve you as a member.” (See https://www.lanwanprofessional.com

/home_idapp.php?service_type_id=272&gclid=CjwKCAiAzanuBRAZEiwA5yf4uhk2y_4PwlvWlB

AaQv5TGFT4mNWms6_W3Q-gfezvotrFINmm9Sah0xoCe HwQAvD_BwE (last accessed on

November 12, 2019).) The exact opposite is true.

23. When a potential student signs up for a LAN/WAN Professional membership, they

receive a “CWA HANDS-ON & 4 DAY BOOT CAMP CONFIRMATION FORM.” (See Exhibit

B.) This Conformation Form states that the student will receive a $3,600 to $3,980 “Grant” for

Defendant’s training:

This “Grant” makes students believe that they are receiving thousands of dollars of training for the

cost of lodging/meals:

However, it is clear, Defendants do charge its prospective students, and require them to sign an

agreement, before they can “try” their program.


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24. When students attend these initial training sessions, it is essentially some basis IT

instruction with a sales pitch for Defendants’ additional services. Quickly, Defendants’ students

become aware that they are required to commit to pay thousands of dollars before they can receive

any training that focuses on marketable job skills. Students are told that they are “conditional

approved” for “the comprehensive LAN/WAN Professional Membership Package” valued at

$95,885. (See Exhibit C.) The pricing of the program is advertised to include membership dues,

training, and mentoring:

(Exhibit C.)

25. In the contract materials, potential students are promised that the LAN/WAN

Professional Membership Package is a smart investment as it will “enable” the students secure a job

earning between $72,000 in one month and $120,000 in one year. (Id; see also Exhibit C [“The

combination of your 6 to 12 months of LAN/WAN employment along with the additional

credentials/skills you acquire will qualify you for an upgraded LAN/WAN position earning $90,000

to $120,000 per year.”].) In fact, few individuals receive any more than an entity level job in

enterprise network, if in the IT industry at all, and Defendants do not have a reasonable basis to make

such a claim.

26. Additionally, students are told that they are getting a substantial discount through

“credits.” These credits are actually subject to forfeiture if a candidate fails to comply with any of

the onerous, and often subjective, requirements of the program:


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(Id.) Potential students are not properly informed that they could be forced to repay these credits at

the end of the program. Because these credits are worth approximately $40,000 dollars, forfeiture of

these credits can increase the program price by almost 80 percent.

27. Additionally, to further dispel any concerns regarding the cost of the LAN/WAN

Program, potential students are told that they can defer payment of the majority of the fees due under

the LAN/WAN Professional training program:

As an approved member, 100% of the services are fully deferred until job start. The member currently has an upfront deposit as stated in the confirmation form. Upon job offer receipt, the member will be responsible for a deferred deposit of $6,700. 100% of any deposits paid will be applied to your obligations. Upon job start, the member will pay 29.95% of gross full-time monthly income for 42 months not to exceed the service value less any deposits paid and credits earned. Your first month's payment is due and payable on the first day of job start and all future payments are paid in recurring payments tied to pay dates starting with the first paid date

(Id.) However, this deferral is simply an illegal and unconscionable student loan that must be repaid

from future income regardless if Defendants’ deliver on the high paying job promised. This is not

fully disclosed to students.

Defendants Fail to Provide the Training Necessary to Get a High Paying Enterprise Network Engineer Job

28. Defendants advertise that their program contains two important elements, the first is

training. This extremely abbreviated training program is focused skills needed to secure a job in

enterprise level networking:


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(Id.) Through their training, Defendants advertise that students will receive certifications that enable

student to secure IT jobs and advance their careers. But these abbreviated training makes it unlikely

that students will pass such the relevant certification tests or be knowledgeable on enterprise level

networking at the end of the training.

29. For example, the Cisco Certified Network Associate (CCNA) certifications are

designed to validate the skills of network engineer. Generally, CCNA level certifications are

recommended for individuals with approximately one year of networking experience, not a few days

of training. Similarly, CCNP Security certification is professional-level certification designed for

network engineers that specialize in network security. CCNP candidates often have three to five

years of experience implementing security solutions. Topics that a CCNP Security certification is

expect to know include, inter alia:

• network infrastructure security methods;

• traffic redirection and capture methods;

• SPAM filtering, antimalware filtering, DLP, blacklisting, and email encryption;

• web security controls on Cisco Umbrella;

• endpoint device management and asset inventory

• outbreak control and quarantines;

• Endpoint Protection Platforms (EPP) and Endpoint Detection & Response (EDR)

solutions; and

• exfiltration techniques (DNS tunneling, HTTPS, email, FTP/SSH/SCP/SFTP, ICMP,

Messenger, IRC, NTP).


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30. Both of the CCNA and CCNP certifications are earned through completing the requisite

testing. It is simply unrealistic that any individual, especial those without prior networking

knowledge, will ever pass the exams required for these certifications after a few weeks of training.

Indeed, users on the Cisco Learning Network forum discussing LAN/WAN Professional’s training

schedule have noted that even the less competent training program would concede that “achiev[ing]

multiple CCNA's and even CCNP's in a very short time line - completely impossible to achieve even

if you are a super-human being.” (https://learningnetwork.cisco.com /thread/96946 [last accessed on

November 15, 2019].) Nevertheless, Defendants promise that individuals will have the requisite

knowledge to earn these certifications within a few weeks.

31. But even if students to manage to pass the exams, these certifications (as Defendant

recognizes) imply that the student has the “real world hands-on skill equivalent to those of a

professional with 7 to 10 years of proven work experience.” (Id.) Simply having these certification

does not prepare individuals for high paying network engineering jobs. Accordingly, Defendants

training cannot possibly delivery the promises made. A few weeks of training does not transform a

lay person into a networking professional.

To Secure Job Placement, Defendants advise their Students to engage in Unethical Practices

32. The second portion of Defendants’ services focus on mentoring and supporting students

in finding a job and advancing their career:

(Id.) Under their loan agreement, Defendants to not get pay until the student is placed in a job.

Accordingly, Defendant places extreme pressure on its “members” to get any job, even if it is not in

enterprise networking.

33. Knowing that LAN/WAN training is worthless, Defendants advise its members to

spend unrealistic amount of time on their job search. Similarly, Defendants require that its members

engage in unethical practices to secure a job. Defendants’ mentors advocate that members lie about


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the experience on their resumes and during interviews. Defendants also require that student record

interviews, without the knowledge and consent of the interviewing party. The reason that

Defendants’ require that students record interviews is to determine what technical knowledge the

student are found lacking, and teach students how to answer these questions even though the students

are not independently knowledgeable regarding the subject matter. However, recording interviews

and inducing students to lie to interviewer are often violations of state and federal law. This is

particular true when the prospective employee is a government agency that require applications to be

submitted under the penalty of perjury. If a student does not engage in these dishonest tactics, the

will suffer loss of their tuition “credits.”

Defendants Illegally Issue and Collect on Loans Secured by the Future Income of its Students

34. Furthermore, Defendants operate as an unlicensed lender with respective to the

amounts that are demanded of its students. Under its contracts, Defendants specifically require that

its students pay any amount owed for their LAN/WAN “education” through a loan that requires

repayment. This loan is secured by the future wages of their students and requires that student pay

29.95% of their gross full-time pay for 42 months or until the debt is paid. Indeed, the fact that

Defendants are issuing loans is only buttressed by the fact that Defendants run credit checks on their

students as the sole condition for their qualification for the program and report these loans to credit

reporting agencies.

35. The fact that Defendants’ are issuing loans is undisputed. Under Defendants’

“Professional Invoice Settlement Agreement (Special)” a form used for students who leave the

program, Defendant describes its debt settlement options as consumer “loans.” (See Exhibit D.)

36. Additionally, these repayment plans are fundamentally unfair. California law limits

the amount that a creditor can garnish from your wages to repay debts. Generally, under California

law, creditors can’t garnish more than 25% of an employee’s wages after deductions. However, its

restriction is even lower for lower income individuals. Defendant requires payment of about this

percentage. Accordingly, Defendant’s business practices are unfair with compared to enumerated

public policy.


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37. But even if student does not get a job they are still required to pay. If a person fails to

get a job, or violates any of Defendants’ discretionary requirements in the “parameters of the general

conditions listed on the professional services invoice, professional services invoice addendum,

package confirmation form, membership agreement and any other documents signed by the

[students]” the full amount of the person tuition becomes due. In addition, Defendant charges these

individuals a fee of 35 dollars and 1.5 percent interest.

38. Under Section 22009 of the California Financial Code, a “Finance lender” includes any

person who is engaged in the business of making consumer loans or making commercial loans. The

business of making consumer loans or commercial loans may include lending money and taking, in

the name of the lender, or in any other name, in whole or in part, as security for a loan, any contract

or obligation involving the forfeiture of rights in or to personal property, the use and possession of

which property is retained by other than the mortgagee or lender, or any lien on, assignment of, or

power of attorney relative to wages, salary, earnings, income, or commission.

39. Defendants contract with tens, if not hundreds, of students each year and regularly

securing its student loans against the future income of its students. Therefore, Defendants are holding

themselves out as “Finance lender” under California law. (See Raysinger v. Peoples Inv. & Loan

Assn. (1973) 36 Cal. App. 3d 248, 253.) California law also provided that “[n]o person shall engage

in the business of a finance lender or broker without obtaining a license… .” (Cal. Fin. Code §

22100(a).) Defendants are engaging as an illegal and predatory lender under California law.

40. If individuals do not pay these purported loans, Defendants threaten individuals with a

negative report on their credit history, another violation of the Fair Credit Reporting Act.

Accordingly, most students are forced to provide Defendants with approximately 30 percent of their

gross pay to Defendants for their illegal student “loan” program. These rates are unconscionable as

recognized by both federal and state law. Indeed, even when a creditor secured as judgment on a

creditor, they are generally only allowed to garnish up to 25 percent of a person’s net paycheck (after

taxes); well less that 30 percent of gross pay.

Defendant’s Loans are Usurious

41. Defendants advertise their program will cost substantially less, subject to a number of


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“credits.” After Defendant secures the price of their program through an unlicensed loan, the price

increases by almost two-fold. This amount must be paid through payment of 30 percent of a person

income monthly until the principle amount, plus any penalties, are recovered. These payments and

penalties often exceed the maximum amount of interest allowable under California Law.

42. “Generally, the California Constitution sets a maximum annual interest rate of seven

percent on loans and forbearances, but allows parties by written contract to set the interest rate at up

to 10 percent . . . .” WRI Opportunity Loans II LLC v. Cooper, 154 Cal. App. 4th 525, 533, 65 Cal.

Rptr. 3d 205 (2007) (citations and quotations omitted). However, Defendants’ loans far exceed the

rate allowable.

43. For example, Defendants expressly advertise and warrant that the price of the program

will be $55,885. But Defendants often secure the loans for their services for a principle in excess of

$95,885. The different between the $55,885 amount advertised and the $95,885 do not reflect any

increase in the price of the serviced provided, but simply excess charges related to a students’

deferment of payment. More simply put, the difference is “interest.”

44. Assuming that the student secures an entry level position for $72,000 per year (Exhibit

C [this is the minimum amount that Defendants advertise a person will make after the program].) that

student will be paying at least $1,797 per month for forth-two months (approximately 30 percent of

their monthly income). This payment represents an approximately 17.78% APR interest rate on the

$55,885 principle amount that the student originally agreed to pay. Such unconscionable rates are

well beyond the 10 percent allowed under the law.

Defendants’ Monetary Penalties Represent Illegal Forfeiture under the Law

45. Alternatively, if the amount paid above the $55,885 price advertised is not interest for

deferral of payment, they are unlawful penalties. Following Defendants’ training, students were

contractually required to spend a certain number of hours per week, often forty, actively looking for

a job in the IT industry. Defendants condition a number of “credits” on successfully completing these

obligation under their Contract, including:

1. $5,000 Remote Credit - $5,000 performance credit is directly tied to your remote performance. $2,500 of the credit is directly tied to timely completion of assignments. For every late assignment the member will lose $500, not to exceed 5 assignments.


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This includes attending all scheduled meeting with LAN/WAN staff. In the event that the member exceeds 5 lates, there may be an additional deposit penalty. Another $2,500 is tied to the number of assignment resubmits and your demonstration of technical knowledge during scheduled reviews. 2. $5,000 Job Search Credit - $5,000 of the performance credit is tied directly to your performance during job search. $2,000 is tied to your job search performance during camp including getting a rating of 3 (out of 5) in your job search skills out of camp. Another $3,000 is tied to your timely employment with $3,000 credit if you receive a job offer within 3 weeks of camp completion, $2,000 if you receive a job offer within 6 weeks of camp completion and $1,000 if you receive a job offer within 10 weeks of camp completion. 3. $5,000 Job Prep/Start Credit - $3,000 is tied to providing timely and thorough documentation during job prep/job start including properly following our job prep/start instructions and working closely with LAN/WAN staff including being available and prepared for scheduled meetings. Another $2,000 is tied to getting fully acclimated in the job and restarting your remote within 2 months of job start. If the member starts later than 2 months but within 4 months, the member will receive $1,000 and any time after 4 months, the credit is $0. 4. $10,000 Advocate Credit - In consideration for this credit, you will advocate 4 new members ($2,500/member) with 4 months of initial employment. The credit will be applied to the backend of the obligations. In the event that the member does not complete his obligations, the member will only receive a prorated portion of the credit. 5. $15,000 Advisor Credit - This credit is conditioned upon helping LAN/WAN Professional 3 to 5 hrs/month during the training period and for 60 months thereafter. This includes timely and positive video and written testimonials. Assistance relates to any and all items, information and activities relating to the advance of LAN/WAN Professional, its members and its services.

These commitments are often impossible for students, as they often hold other full time employment.

In total, the “credits” were worth approximately $40,000 dollars or more.

46. These credits, in actuality, are penalties for failure to a students’ failure to comply with

Defendant’s contractual standards. Defendant’s “LAN/WAN PRO MEMBERSHIP PACKAGE -

CONFIRMATION FORM” makes this clear:

CONDITIONS - In addition, the member must meet all mutually agreed upon commitments including getting CCNP Tshoot, CCNA Security and meeting all required activities/assignments deadlines including spending 30 hrs/week during remote and 40 hrs/week during job search until employed. LAN/WAN Professional reserves the right to cancel the membership and service deferment if the member does not meet mutually agreed activities as listed above and in the member/service authorization form. The member also commits to proactively job searching nationwide until employed. Finally, the member commits to work on his validation skills and professional skills with specific focus reacting to pressure situations.

(See Exhibit A.) Indeed, when a person does not preform the number of hours required, they receive

a “Deposit Penalty Deferment & Reduced Hours Authorization Form” that describes the reductions


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from the credits and deposits as a “penalty” for violating the parties’ agreement. (See Exhibit E.)

47. California Civil Code § 1671 provides that for personal services, a provision in a

contract liquidating damages for the breach of the contract is void except that the parties to such a

contract may agree therein upon an amount which shall be presumed to be the amount of damage

sustained by a breach thereof, when, from the nature of the case, it would be impracticable or

extremely difficult to fix the actual damage. A liquidated damages clauses in consumer contracts are

presumed void, the burden is on the defendant to rebut that presumption. (In re Cellphone Fee

Termination Cases (2011) 193 Cal.App.4th 298, 322.) To do so, courts “have created a two-part test

for determining whether a liquidated damages provision is valid: (1) fixing the amount of actual

damages must be impracticable or extremely difficult, and (2) the amount selected must represent a

reasonable endeavor to estimate fair compensation for the loss sustained.” (Id.)

48. Here, Defendants suffer no damage from an individual’s failure engage in the activities

included in the above listed credits. For example Defendants suffer no harm if a student does not

dedicating a few hours less than 40 hours per week “to proactively job searching nationwide until

employed” nor do Defendants suffer $500 dollars for “every late assignment.” But even if Defendants

did suffer some damages as a result of these breaches, it was not in the amount of tens of the thousands

of dollars in “credits” available under the contract. Accordingly Defendants’ practice of conditioning

their students’ performance on forfeiture of “credits” represents an illegal liquated damages penalty

that is not enforceable under the governing law.

Plaintiff’s experience with Defendants

49. In addition to completing online workshops, Plaintiff was required to travel to

California on three separate occasions, incurring over $1,000 of expenses each trip. Without any

assistance from Defendants, Plaintiff was able to land a position with the United States Postal Service

with a start date of December 2, 2019. Plaintiff’s initial offer from the U.S. Postal Service was for

over $100,000, which was then cut to $70,000 when the U.S. Postal Service’s recruiter determined

that Plaintiff’s resume, which was created by Defendants, was embellished and replete with

inaccuracies. Nevertheless, Defendants demanded that Plaintiff pay a $23,316 lump-sum payment

due two weeks from his start date (December 2, 2019). In addition to the lump-sum payment,


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Defendants demand additional repayments from Plaintiff in the form of monthly payments equal to

30% of Plaintiff’s monthly pay, approximately $1,750 per month, for the next 16 months in order to

satisfy the outstanding loan balance.

50. Plaintiff’s experience was not unique and are typical of the putative Class and

hundreds, if not thousands of other students who have contract with Lan/Wan Professional for

professional services.

Complaint’s from other Lan/Wan Professional Students

51. Indeed, Plaintiff is not the only former student complaining about Defendant’s

program. Numerous consumer complaints can be found online, including:

I saw the “advertisement” on the internet for LANWANPROFESSIONALS, and filled out their minimal questionnaire, but was not asked to submit a resume. Big mistake, contacting them at all. I missed the initial call from Bill Frey and received an email requiring me to call back before the “Deadline.” I called Bill and left a voicemail. When he returned my call, we exchanged pleasantries and then he asked me if I was north or south of 60, wanting to know my age range. When I told him I was over 60, he advised me that I would have to invest $50,000 to $60,000. Except for being aware that I had been a computer programmer for IBM for 20 years, he knew nothing about me. DO NOT contact these people unless you are ready to be suckered, skinned and scammed. (https://learningnetwork.cisco.com/message/728683#728683 (last accessed on November 12, 2019).) To everyone who took the time to read through my complaint, LAN WAN PROFESSIONAL aka Global Networks Enterprises & Technologies, is a NO GO area. You will regret your life for signing that agreement form with them. Please tell the whole world about this fraudulent company so they could be shut down for good. Oh did I tell you they made us testify on camera at the end of the 10 day workshop, how LAN WAN is the best thing that happened to us, so they could use it in court as evidence that we were satisfied with the program? Yeah, but even with that, they will never win in court for making people’s life more miserable than it was. (http://www.scamion.com/lan-wan-professional-ef (last accessed on November 12, 2019).) LAN/WAN Professional promised that they train people at least 10 to 20 times faster than traditional learning methods and help candidates to get jobs earning $60,000 to $120,000 annually in 2 to 5 months. All the service fees are tied to employment. The candidates will not owe anything before they get a job. The training includes two parts: remote training and camp training. The camp training was scheduled to start on Feb. 3, 2018 for 24 days. They asked me to pay the lodge/meals for $1584 ($66 x 24) in advance. They also asked me to pay $995 for security deposit. The total amount is $2579. After they received my payment, they cancelled my training on Jan. 13, 2018 (including remote training and camp training, which was scheduled to start on 2-3-2018). They received my payment of $2579 for camp training (lodge/meals and security deposit), but they did not provide the camp training for me. I need to get that money back.


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This is a rip-off, a scam. The learning service offered by LAN WAN is “Employment Training” does not prepare you for the Network Engineer position as advertised. I want a full refund: Total spent so far: $6,524.00, not including airfare. I have emails, stack of documentation, recordings that LANWAN Professional instructs/trains everyone to use during all phone conversations and an embellished resume. I have many LANWAN Professional instructing/collaborating where once I followed there instructions, my employer got very mad on two occasions, caused serious problems. I have several where ******* is probing for info and then makes intimidating statements, and scared tactics, Oh I forgot, I am told I am not professional when I state truthful facts/questions. Beware!!! There is no Job placement, you cold call, they do offer or not speak or interact with employers, and the so called “efficient Learning” training is questionable and I hope someone looks into these practices. I was unemployed and looking for network engineering technical training and job placement, I located LANWAN Professional, also known as Global Networks Enterprises & Technologies, at http://www.lanwanprofessional.com/ and was convinced by ******* ****, Director of Member Services, with the CWA/CCNA Grant package valued at $3980.00, but I paid $578 and then $380 for the CWA/CCNA Grant package. The deficiency in training performance in regards to the services is the so called “real world hands-on focused enterprise LAN/WAN training on that is designed to update/upgrade your LAN/WAN staff skills 10 times faster with minimal time away from work and the Job placement”. I did not learn 10X faster, a gimmick. One the hands on comes without classroom, no Cisco books, no technical lectures, no teaching, and you are in competition getting technical support, if you complain, you are told you are not learning correctly “efficient learning" (https://www.bbb.org/us/ca/irvine/profile/professional-services/lan-wan-professional-1126-100102804/complaints (last accessed on November 12, 2019).)

Accordingly, Plaintiff’s experiences with Defendants and the Lan/Wan Professional are typical of the

putative Class and hundreds, if not thousands of other students who have contract with Lan/Wan

Professional for professional services.

V. CLASS ALLEGATIONS

52. This action is brought as a class action pursuant to Code of Civil Procedure, section

382, and Civil Code, section 1781. The proposed class is defined as follows:

All individuals in the United States who contracted with Defendants for professional services and agreed to pay for such service with income from future employment.

Excluded from the class are any persons who have previously obtained a judgment or settled any

claims against Defendants concerning the types of claims asserted herein or have previously executed

releases precluding any such claims against Defendants.

53. Plaintiff is informed and believes there are thousands of potential class members, who

can be identified by Defendants’ records.

54. There are genuine questions of law and fact common to the class that predominate over


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any individual questions. These common questions, which demonstrate a community of interest

among class members, include:

a. Whether Defendants’ advertisements were false and misleading;

b. Whether the transactions Defendants entered into with class members should be

classified as loans under applicable law;

c. Whether the form contracts, drafted by Defendants and used by Defendants in their

transactions with class members, contain provisions which are unconscionable and

unenforceable;

d. Whether California law should be applied in assessing the legality of Defendants’

transactions, regardless of where the class member resides, as stated in the form contract

documents drafted by Defendants;

e. Whether Defendants’ conduct violates the Unfair Competition Law;

f. Whether Defendants’ conduct violates the Consumer Legal Remedies Act;

g. Whether Defendants’ conduct violates the Fair Credit Reporting Act;

h. Whether Defendants’ conduct violates the unlawful debt collection provisions of the

Racketeer Influenced and Corrupt Organizations Act;

j. Whether Defendants should be enjoined from continuing to offering illegal loans and

misleading educational and vocational services;

l. Whether Defendants should be ordered to provide restitution to the class;

m. Whether class members are entitled to an award of damages as a result of Defendants’

conduct, and if so, in what amount; and

n. The claims of Plaintiff are typical of the claims of the class members. Each class

member was subjected to the same illegal conduct of Defendants, was harmed in the same way,

and has claims for relief under the same legal theories.

55. Plaintiff will fairly and adequately protect the interests of the class. Plaintiff has

common interests with all members of the class and will vigorously protect the interest of the class

through qualified counsel experienced in handling class action and consumer protection cases.

Neither the named Plaintiff nor class counsel has any interests which would conflict with the interests


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of the class members.

56. A class action is a superior method for the fair and efficient adjudication of this

controversy. Most class members are unaware of the availability of legal challenge to the transactions

they entered into with Defendants. Moreover, given the common questions to be resolved, class

litigation is the superior method of resolving these legal challenges in one proceeding, thus avoiding

a multiplicity of parallel suits. A class action will avoid the possibility of inconsistent adjudications

of the same legal question.

FIRST CAUSE OF ACTION (For Violation of the Consumer Legal Remedies Act Under

California Civil Code §§ 1750, et seq.) (Against All Defendants)

57. Plaintiff hereby incorporates by reference the allegations contained in the preceding

paragraphs of this Complaint.

58. By entering into the subject transactions with Defendants involving for professional

and education services, Plaintiff and the class members are consumers as that term is defined in Civil

Code § 1761.

59. Defendants have violated Civil Code §§ 1770(a)(3), (5), (7), (9), (13), (14), (19) and

(26), through the acts alleged herein, thereby entitling Plaintiff and members of the class to relief

under Civil Code § 1780 by, inter alia:

a. Representing that goods or services have characteristics which they do not have, in

violation of § 1770(a)(3) and (5);

b. Representing that goods or services are of a particular standard, quality, or grade if they

are of another, in violation of § 1770(a)(7);

c. Advertising goods or services with intent not to sell them as advertised, in violation of

§ 1770(a)(9);

d. Making false or misleading statements of fact concerning reasons for, existence of, or

amounts of, price reductions, in violation of § 1770(a)(13);

e. Representing that a transaction confers or involves rights, remedies or obligations

which it does not have or involve, or which are prohibited by law, in violation of § 1770(a)(14);


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f. Inserting an unconscionable provision in a contract, in violation of § 1770(a)(19); and

g. Advertising, offering for sale, or selling a financial product that is illegal under state or

federal law, in violation of § 1770(a)(26).

60. Defendants’ violations of Civil Code § 1770 described above present a continuing

threat to class members and members of the public in that Defendants are continuing to engage in

these practices, are continuing to refuse to refund amounts paid by consumers, and will not cease

until an injunction is issued by the Court.

61. As a result of Defendant’s violations, Plaintiff and members of the class are entitled to

injunctive relief, including, but not limited to

62. By letter dated December 19, 2019, mailed as directed in Civil Code § 1782, Plaintiff

notified Defendants of their violations of the CLRA and demanded that Defendants provide remedies

to rectify their conduct.

63. Should, Defendants have fail agreement within a reasonable time, Plaintiff will amend

this complaint to seek sufficient remedy as set forth in California Civil Code § 1782(c) for the above-

mentioned violations of law.

64. Plaintiff and the members of the class are entitled to an award of attorneys’ fees and

costs against Defendants pursuant to the provisions of Civil Code § 1780(d).

SECOND CAUSE OF ACTION (For Fraudulent, Unfair, and Illegal Business Practices Under

California Business and Professions Code § 17200, et seq.) (Against All Defendants)



66. Defendant’s acts and practices, as alleged in this complaint, constitute unfair business

practices, in violation of the Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code § 17200, et

seq.

67. The acts complained of herein, including the disguising of loan transactions as non-

loan transactions, the insertion into contracts of numerous unconscionable and unenforceable terms,

the presentation of misleading descriptions of the purported benefits of Defendants’ services, and the


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charging of imputed interest in excess of the legally permitted rate, constitute unlawful competition

under the “unfair,” and “fraudulent” prongs of the UCL.

68. There is no countervailing benefit to competition in allowing Defendant to falsely

adverse their services and issue unlawful loans.

69. Defendant’s acts and practices, as alleged in this complaint, constitute unlawful and

unfair practices in that they violate California Civil Code section 1750, et seq., and Business and

Professions Code, § 17500, et seq.

70. Additionally, Defendants provisions of unlicensed loans violations both California a

Federal law.

71. These acts offend established public policies or are immoral, unethical, oppressive,

unscrupulous, or substantially injurious to consumers. Alternatively, these acts cause harm to veterans

which outweigh any utility flowing from them.


loan transactions, misrepresenting the nature of their sponsorship and affiliations, and

misrepresenting the nature of their services are also capable of deceiving a reasonable consumer.

73. As a result of these acts of unfair competition, over the last four years Defendants have

obtained money or property from Plaintiff and class members which they should not, in equity, be

permitted to retain, including but not limited to excess interest payments. Plaintiff and the general

public are entitled to injunctive relief, restitution, and other equitable relief.

THIRD CAUSE OF ACTION (For False Advertisement Under

California Business and Professions Code § 17500, et seq.) (Against All Defendants)



75. Defendant’s acts and practices, as alleged in this complaint, constitute unfair business

practices, in violation of the False Advertisement Law (“FAL”), Cal. Bus. & Prof. Code § 17500, et

seq.

76. The FAL states: “[i]t is unlawful for any person, firm, corporation or association, or


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any employee thereof with intent directly or indirectly to dispose of real or personal property or to

perform services, professional or otherwise, or anything of any nature whatsoever or to induce the

public to enter into any obligation relating thereto, to make or disseminate or cause to be made or

disseminated before the public in this state, or to make or disseminate or cause to be made or

disseminated from this state before the public in any state, in any newspaper or other publication, or

any advertising device, or by public outcry or proclamation, or in any other manner or means

whatever, including over the Internet, any statement, concerning that real or personal property

or those services, professional or otherwise, or concerning any circumstance or matter of fact

connected with the proposed performance or disposition thereof, which is untrue or misleading, and

which is known, or which by the exercise of reasonable care should be known, to be untrue or

misleading, or for any person, firm, or corporation to so make or disseminate or cause to be so made

or disseminated any such statement as part of a plan or scheme with the intent not to sell that personal

property or those services, professional or otherwise, so advertised at the price stated therein, or as so

advertised.” Cal. Bus. & Prof. Code § 17500.


loan transactions, the insertion into contracts of numerous unconscionable and unenforceable terms,

the presentation of misleading descriptions of the purported benefits of Defendants’ services, and the

charging of imputed interest in excess of the legally permitted rate, would mislead a reasonable

consumer.

78. As a result of these acts of unfair competition, over the last four years Defendants have

obtained money or property from Plaintiff and class members which they should not, in equity, be

permitted to retain, including but not limited to excess interest payments. Plaintiff and the general

public are entitled to injunctive relief, restitution, and other equitable relief

FOURTH CAUSE OF ACTION (The Usury Law, Cal. Const. Art. XV, § 1)

79. Plaintiff restates all prior allegations as though fully pled herein.

80. As alleged above, Plaintiff and class members have paid to Defendants interest in

excess of the maximum permissible rate authorized under Cal. Const. Art. XV, § 1. Pursuant to the


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Usury Law, Stats. 1919, p. xxxiii, Deering's Uncod. Initiative Measures & Stats. 1919-1, Plaintiff and

class members are entitled to repayment from Defendants of treble the amount of all such interest

paid within one year past.

81. The transactions entered into between Defendants, on the one hand, and Plaintiff and

class members, on the other, were in substance loans calling for usurious rates of interest. Under the

terms of these transactions, usurious interest was absolutely payable by Plaintiff and class members.

On information and belief, Defendants willfully entered into each of the transactions with Plaintiff

and class members, intending to receive the interest payments called for under those transactions.

FIFTH CAUSE OF ACTION (Violation of the Federal Truth in Lending Act,

15 U.S.C. §§ 1601 et seq., (“TILA”)) (Against All Defendants)


83. TILA and Regulation Z require that certain material disclosures be provided to a

consumer before consummation of a loan contract. 15 U.S.C. § 1638(a)-(b); 12 C.F.R. § 1026.17(a)-

(b), 1026.18.

84. Among the required material disclosures in a closed-end credit transaction are the

finance charge and APR. 15 U.S.C. §§ 1602(v), 1638(a)(3)-(4); 12 C.F.R. § 1026.18(d)-(e).

85. The finance charge is “the sum of all charges, payable directly or indirectly by the

person to whom the credit is extended, and imposed directly or indirectly by the creditor as an incident

to the extension of credit.” 15 U.S.C. § 1605(a).

86. Regulation Z requires that a contract for closed-end credit disclose the finance charge,

“using that term, with a brief description such as ‘the dollar amount the credit will cost you.’” 12

C.F.R. § 1026.18(d).

87. The APR is “a measure of the cost of credit, expressed as a yearly rate.” 12 C.F.R. §

1026.22(a)(1); see also 15 U.S.C. § 1606(a).

88. Regulation Z requires that a contract for closed-end credit disclose the APR, “using

that term, with a brief description such as ‘the cost of your credit as a yearly rate.’” 12 C.F.R. §

1026.18(e).


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89. The “discount,” “deposits,” and other fees charged by Defendants are all incident to the

extension of credit and part of the finance charge required to be disclosed to consumers and included

in calculation of the APR disclosed to consumers. 15 U.S.C. §§ 1605(a), 1606(a), 1638(a)-(b); 12

C.F.R. §§ 1026.18, 1026.22.

90. In the course of extending closed-end credit, Defendants used credit agreements that

did not include the brief descriptions of the finance charge and APR required by Regulation Z. 12

C.F.R. § 1026.18(d)-(e).

91. In the course of extending closed-end credit, Defendants used credit agreements that

failed to disclose the finance charge and APR required by TILA and Regulation Z. 15 U.S.C. §§

1605(a), 1606(a), 1638(a)-(b); 12 C.F.R. § 1026.18(d)-(e); 12 C.F.R. § 1026.22.

92. Defendants therefore violated TILA and Regulation Z. 15 U.S.C. §§ 1605(a), 1606(a),

1638(a)-(b); 12 C.F.R. § 1026.18(d)-(e); 12 C.F.R. § 1026.22.

93. Plaintiff and the members of the class are entitled to an award of actual damages, twice

the amount of any finance charge, costs and reasonable attorney’s fees pursuant to the provisions of

15 U.S.C. § 1640.

SIXTH CAUSE OF ACTION (Violation of the Racketeer Influenced and Corrupt Organizations Act,

18 U.S.C. § 1961 et seq. (“RICO”)) (Against Defendants Eric Choi and Patrick Pule)


95. This count is against Eric Choi and Patrick Pule for violation of RICO, 18 U.S.C. §

1962(c), for using Global Networks Enterprise and Technologies, Inc. (doing business as LAN/WAN

Professional) (the “Enterprise Defendant”) to collect unlawful debt.

96. RICO Section 1962(c) provides that: “It shall be unlawful for any person employed or

associated with any enterprise engaged in, or the activities of which affect, interstate or foreign

commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs

through a pattern of racketeering activity or collection of unlawful debt.”2 (emphasis added). See

2 Unlawful debt” generally means a debt that is incurred or contracted in a gambling activity or

business in violation of federal, state or local law or is unenforceable, in whole or in part, due to usury laws. 18 U.S.C. § 1961(6).


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United States v. Aucoin, 964 F.2d 1492, 1496-97 (5th Cir. 1992) (“It is clear to us that Congress

intentionally created a statutory scheme where proof of the collection of unlawful debt is a substitute

for a showing that appellants engaged in two or more predicate acts forming a pattern of racketeering

activity.”) (emphasis in original) (internal quotations and citation omitted).3

97. Defendants Eric Choi and Patrick Pule are persons within the meaning of Section

1962(c).

98. The Enterprise Defendant is enterprises within the meaning of Section 1962(c). See

Cedric Kushner Promotions, LTD., v. Don King, 533 U.S. 158 (2001) (while the enterprise required

by the statute must be more than the person operating under another name, the requisite distinctness

between respondent and his corporation was established since they were legally different entities).

99. Defendants Eric Choi and Patrick Pule are employed by or associated with the

Enterprise Defendant. Specifically, Defendants Eric Choi and Patrick Pule owns and operate

Enterprise Defendant and has complete authority, power, and discretion to make any and all decisions

regarding the Enterprise Defendant.

100. The Enterprise Defendant is engaged in interstate commerce, and their activities affect

interstate commerce. Specifically, the Enterprise Defendant advertised to, solicited, and made and

collected loans to and from Class Members across the nation.

101. The Enterprise Defendant also used instrumentalities of interstate commerce in their

daily activities, including automobiles, telephones, the internet, and the mails.

102. Defendants Eric Choi and Patrick Pule conduct or participate in the affairs of the

Enterprise Defendant through the collection of unlawful debt in violation of 18 U.S.C. § 1962(c).

Specifically, Defendants Eric Choi and Patrick Pule directed the Enterprise Defendant to make and

collect unlicensed loans to and from students in California.

103. The loans (and the interest rates charged therein) constitute unlawful debt within the

meaning of Section 1962(c) as the term is defined in Section 1961(6). Specifically,

a. A substantial portion of the interest rate is unenforceable under state usury law. Under

3 Under California law, interest will be twice the enforceable rate if it exceeds 20 percent per year. Cal. Const., Art. XV § 1.


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California law, a lender is prohibited from charging a rate greater than 10% per annum

as compensation for the use of money. Cal. Const. Art. XV, §1.

b. The Enterprise Defendant loans, which are secured by the future income of its students,

without a license or authorization as required by California law

c. The income-based loans are issued at a rate far in excess of twice the enforceable rate

allowed in California. 18 U.S.C. § 1961(6).

119. The loans occur across state lines in interstate commerce as many class members,

including Plaintiff, reside in different states than Defendants.

120. Defendants attempt to collect on the income-based loans by directly debiting accounts

and pursuing other debt collection practices.

104. As a direct and proximate result of the aforementioned acts, Plaintiff and each member

of the class he represents have suffered injury in an amount subject to proof at trial and are entitled

to recover threefold the damages sustained and the cost of the suit, including reasonable attorneys’

fees, against Defendants pursuant to the provisions of 18 U.S.C. § 1964(c). Allstate Ins. Co. v. Polack,

No. CV 08-0565 (ADS) (ETB), 2012 U.S. Dist. LEXIS 141927, at *23 (E.D.N.Y. Sep. 12, 2012)

(“an award of treble damages is mandatory”) (emphasis added) (citing Cullen v. Margiotta, 811 F.2d

698, 713 (2d Cir. 1987)) (noting that “civil RICO requires that a successful plaintiff be awarded treble

damages”).

SEVENTH CAUSE OF ACTION (Violation of the Fair Credit Reporting Act

15 U.S.C. § 1681b, (“FCRA”)) (Against All Defendants)


106. Defendant procured consumer reports, as defined by the FCRA, on Plaintiff and other

class members. These reports were reportedly procured for employment purposes without Plaintiff

or any class members being provided a clear and conspicuous disclosure made in writing, in a

document consisting solely of the disclosure, that a consumer report may be obtained for employment

purposes in violation of 15 U.S.C. § 1681b(b)(2)(A)(i).

107. The foregoing violations were willful. Defendant acted in deliberate or reckless


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disregard of their obligations and the rights of Plaintiff and other class members under 15 U.S.C. §

1681b(b)(2)(A)(i).

108. Furthermore, Section 623(a)(1)(A) of the FCRA prohibits furnishers of information to

consumer reporting agencies from furnishing any information relating to a consumer to any consumer

reporting agency if the furnisher knows or has reasonable cause to believe that the information is

inaccurate. 15 U.S.C. § 1681s-2(a)(I)(A).

109. In numerous instances, in connection with furnishing information relating to a

consumer to a consumer reporting agency, Defendants report debt resulting from unlawful loans and

unlawful penalties. Defendant has furnished such information while knowing or having reasonable

cause to believe that the information was inaccurate.

110. Plaintiff and the class are entitled to actual damages or statutory damages of not less

than $100 and not more than $1,000 for each and every one of these violations, pursuant to 15 U.S.C.

§ 1681n(a)(1)(A).

111. Plaintiff and the class are entitled to such amount of punitive damages as the Court may

allow pursuant to 15 U.S.C. § 1681n(a)(2).

112. Plaintiff and the class are further entitled to recover their costs and attorneys’ fees,

pursuant to 15 U.S.C. § 1681n(a)(3).

EIGHTH CAUSE OF ACTON (Declaratory Relief, 28 U.S.C. §§ 2201 et seq. )


114. An actual and justiciable controversy exists between the parties as to their respective

rights and obligations under the form document Agreements, which each class member has entered

into with Defendants. Plaintiff, on behalf of the class, contends that some or all of the provisions in

the Agreement are illegal, void, voidable, unconscionable, and/or unenforceable. Plaintiff is informed

and believes that Defendants contend to the contrary.

115. Plaintiff seeks the following declarations regarding his obligations, and those of class

members, under the Agreement:

a. The transaction evidenced by the Agreement is, under law and equity, a loan, subject


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to applicable laws of the State of California;

b. Any “Credits” provided for by the contract cannot be forfeited under California Civil

Code § 1671; and

c. The Agreement is unconscionable and unenforceable, and/or void as a matter of law.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff and the Class pray for relief and judgment as follows:

A. For an order declaring that this action is properly maintained as a class action and

appointing Plaintiff as a representative for the Class, and appointing Plaintiff’s counsel as Class

counsel;

B. That Defendant bear the costs of any notice sent to the Class;

C. For an order awarding Plaintiff and the members of the Class actual damages, statutory

damages, punitive damages, restitution, and/or disgorgement;

D. For an order enjoining Defendant from continuing to engage in the unlawful and unfair

business acts and practices as alleged herein;

E. For an order awarding Plaintiff and the members of the Class pre- and post-judgment

interest;

F. For an order awarding attorneys' fees and costs of suit, including expert's witnesses fees

as permitted by law4; and

G. Such other and further relief as this Court may deem just and proper.

VII. JURY TRIAL DEMAND

Plaintiff demand a trial by jury for all of the claims asserted in this Complaint so triable.

DATED: December 19, 2019 Respectfully submitted, SOMMERS SCHWARTZ, P.C

By: Trenton R. Kashima (SBN 291405)

4 The Professional Services & Alternative Payment Agreement provide for Defendants to collect

attorneys’ fees and costs. Accordingly, Plaintiff and the Class are equally entitled to such fees and costs pursuant to California Civil Code 1717.


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[email protected] Kevin J. Stoops. (Pro Hace Vice Forthcoming) [email protected] 402 West Broadway, Suite 1760 San Diego, California 92101 Telephone: (619) 762-2125 Facsimile: (619) 762-2127 Attorneys for Plaintiff and the Putative Classes


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DECLARTION OF TRENTON R. KASHIMA

I, Trenton R. Kashima, declare as follows:

1. I am an attorney duly licensed and entitled to practice law in the state of California. I

am an attorney of the law firm Sommers Schwartz, attorneys for Plaintiff, Michael Riano, in above-

captioned action. I have personal knowledge of the facts stated herein, and if called to do so, could

and would competently testify thereto.

2. Based on information from Defendant’s website and the California Secretary of State,

Defendant Global Networks Enterprise and Technologies, Inc. is a California Corporation with its

headquarters in 7545 Irvine Center Dr. Suite 200, Irvine, California, 92618, located within the County

of Orange. Defendant Global Networks Enterprise and Technologies, Inc.’s agreement with Plaintiff

and members of the Class expressly provides that any action stemming from a transaction between

Defendants and a customer shall be governed by the laws of the State of California and that “[a]ny

legal action shall be filed in the State of California, County of Orange.”

3. Accordingly, pursuant to California Code of Civil Procedure, section 1780, Orange

County is the proper venue for Plaintiff’s California Consumer Legal Remedies Act claims.

I declare under penalty of perjury under the laws of the State of California that the foregoing

is true and correct.

Executed on November 19, 2019 in San Diego, California.

Trenton R. Kashima

Exhibit A

Andrew Krick 504 Pleasant St, Three Rivers, MI, 49093

[email protected], (269) 718-9690

Dear Andrew Krick,

Thank you for considering LAN/WAN Professional as a partner in advancing your career in enterprise IT (LAN/WAN).

We are pleased to inform you that you have been CONDITIONALLY approved for the comprehensive LAN/WAN Professional MembershipPackage valued at $55,885 ($95,885 - $40,000 Credit). As you already know, 100% of the value of the service is covered through your employmentsuccess and by working part-time as a LAN/WAN Advisor (see following pages).

Your conditional approval was based on our belief that your professional/educational history, along with the skills that you will acquire withLAN/WAN Professional, will enable you to secure timely employment in LAN/WAN earning $72,000 to $90,000 per year within 1 to 2(Unemployed Candidates) to 2 to 3 months (Working Candidates) of placement camp completion and full certification and attain upgradedemployment earning $90,000 to $120,000 within 6 to 12 months of initial LAN/WAN employment.

Please note that you will need to budget for miscellaneous hard costs including exam fees, lodging/meals at camps, transportation to/from camp,necessary deposits, living expenses including a small buffer for exam retakes and related expenses until employed In LAN/WAN.

LAN/WAN Membership Package Confirmation Instructions & DEADLINE: 03/30/2019 8:00 AM (PST)

TO CONFIRM, review this document and COMPLETE and return the appropriate confirmation form by the deadline listed above.

You can do this by logging onto the website you currently have access to and click on the ''Submit Confirmation Form By DEADLINE'' link thatis located below the menu bar of the secured website you currently have access to.

Thank you for considering LAN/WAN Professional as your partner in your information technology career.

Sincerely,

Eric Choi President/CEO

LAN/WAN Professional Membership Package Overview Package Description & GoalsThe LAN/WAN Professional Membership Package is a comprehensive placement and career advancement service that combines over $50,000worth of proven effective enterprise LAN/WAN hands-on and certification training with comprehensive placement training and mentoring tofast track you into upgraded LAN/WAN employment The following is a summary of the services you receive:

Professional Package - $72,000 to $150,000 Per Year Duration ValueLAN/WAN Professional Membership N/A $995CCNP Core/ CCIE Basics & CCNP Tshoot (Upon Approval) 3 to 6 Weeks $11,975CWEA Practical, CCNA Security & Concepts (Prior To Camp) 3 to 6 Weeks $12,985CWEA Camp /Placement Mentoring (Get Initial Job) 15 Days + Remote $31,985Total to Initial Employment 2 to 5 Months $57,940CWP Hands-On & Placement Package (Upon Employment) 8 to 16 Months $37,945LAN/WAN Advisor/Performance Credit (Package Completion) N/A ($30,000)LAN/WAN Advocate Credit (4 Members) N/A ($10,000)Total Package Obligations after Credit 10 to 21 Months $55,885

*What You Pay - 100% Of Services Fees Tied To EmploymentThe total value of the LAN/WAN Professional Placement Membership Package is $55,885 ($95,885 - $40,000 Credit). This includes all trainingtuition costs, hands-on lab guides, 24/7 online access to reading and certification prep training. Please note you will be responsible for CiscoExam Fees, lodging/meals and transportation to/from camp. 100% of this program is paid through 29.95% of your full-time gross income for aperiod of 42 months, not to exceed the program value.

Please note that the average candidate should receive a minimum pay increase of 25% to 100% above his/her prior income potential. For thisreason, your increase will more than offset your fees. In effect, you will be receiving over $50,000 in enterprise Cisco training for free.

Pay For $40,000 Of Package Costs Through LAN/WAN Advisor/Performance/Advocate CreditLAN/WAN Professional understands that the best marketing for our service is a successful candidate. For this reason, candidates can qualify toreceive a $40,000 LAN/WAN Advisor/Performance/Advocate Credit to pay for the second portion of the LAN/WAN Professional Package.

$15,000 of the credit is conditioned upon helping LAN/WAN Professional approximately 3 - 7 hrs/month during your CWP remote trainingperiod and after training package completion for 60 months to include verbal and written feedbacks that are designed to help LAN/WANProfessional continually develop its services along with peer mentoring of candidates who are progressing through the service.

In addition, another $10,000 of the credit is tied to advocating 4 members within 24 months of initial LAN/WAN employment ($2,500 eachtowards Advocate Credit). Finally, $15,000 of the credit is tied directly to your performance during remote/camp, job search and job prep/start.You essentially pay for almost 50% of your service fees through your positive performance and by helping LAN/WAN Professional and othermembers. Another WIN/WIN situation.

PLACEMENT GUARANTEE CONDITIONSAll candidates must be serious about full-time employment in information technology and be committed to spending a minimum of 40 hours perweek actively seeking employment while maintaining proactive coordination with LAN/WAN Professional until employment has been secured.The goal is your timely initial employment within 2 to 8 weeks of camp completion and initial certifications. This requirement will be in effectduring any period that the candidate is not working.

15 Day CWEA Placement Camp Information

Attend 15 Day Camp & GET JOB Earning $72,000 to $90,000

Upon membership confirmation, you will continue your skills development by starting the LAN/WAN Hands-On Core that focuses on realworld hands-on that is expected of a seasoned LAN/WAN Professional. The topics covered include CCNP Core and CCIE Basics hands-on thatincludes IPv6, Redistribution, Multicast, BGP, MPLS, QOS. Your CCIE basics hands-on culminates in taking and passing the CCNPTroubleshooting exam.

Upon CCNP Troubleshooting certification, you will receive Certified WAN Enterprise Administrator (CWEA) Practical Hands-On for EnterpriseLAN and exterior WAN that includes core administrative activities you will be expected to know how to do in the real world. This hands-onincludes practical routing, switching, firewalls and VPN both on Cisco and Juniper technologies. Upon CWEA Practical Completion you willprepare for and pass your CCNA Security Certification. This is the second most sought after LAN/WAN skill set and is a must have skill for anylead level LAN/WAN roles. Your remote culminates in you attending a comprehensive 15 day intensive, full-immersion CWEA Hands-On &Placement Camp in Southern California. Your 15 day camp will begin Saturday after lunch and continue on to the third Saturday afternoon.

During the camp, you receive comprehensive hands-on training in Data Center focused Routing, Switching, Security along with Voice, Wireless,Data Center, 4 enterprise monitoring tools that culminates with you taking and passing the Certified WAN Enterprise Administrator (CWEA).This hands-on certification validates your acquisition of real world hands-on skills equivalent to those of a professional with 7 to 10 years ofproven work experience.

In addition, you will receive comprehensive, proven effective placement training, support and mentoring to fast track you into upgradedLAN/WAN employment earning $72,000 to $90,000 per year within 2 to 6 weeks (full-time) or 4 to 12 weeks (part-time) of camp completion andfull certification. Your actual compensation and employment time frame will vary significantly based on your previous credentials/skills, yourcamp performance and your employment seriousness including the number of hours you can commit to job search.

Upon job offer, you will receive comprehensive mentoring and support to ensure that you are fully functional in your new job that begins prior tojob start and will continue on to the first 1 to 3 months of initial employment until you are fully functional in your job responsibilities. Upon fullacclimation, you will finish your CCNA/CCNP Route and Switch exam and be fully certified as a CCNA/CCNP. In addition, you will receivecomprehensive hands-on refresh on core topics for routing, switching, security and monitoring.

Your remote training culminates in you attending an 8 day Placement Camp (Sat to 2nd Sat). The combination of your 6 to 12 months ofLAN/WAN employment along with the additional credentials/skills you acquire will qualify you for an upgraded LAN/WAN position earning$90,000 to $120,000 per year.

Shared Lodging/Meals & Travel To CampThe most convenient way for our out-of-state candidates to get to camp is by air travel. The airport closest to the training facility is John WayneAirport in Santa Ana, CA (airport code SNA). Please note that all candidates will be picked up at the airport on the first day of camp between12:00 and 1:00pm (PT) and dropped off at the airport at Noon (PT) on the final day of camp. Specific instructions will be provided by one of ourMember Services Representatives. For specific questions call Deborah Hastings, Member Relations Administrator @ (949)544-1355. Please emailyour flight itinerary to: [email protected].

All candidates flying to camp will be picked up at the John Wayne Airport baggage claim area. Candidates who require transportation outside thepickup/drop-off times will be charged a $50 pickup/drop off fee. To ensure that you are on time for your pickup and drop off, if you are flyinginto SNA, please schedule your arrival at or before Noon (PT) and your departure at or after 4pm (PT). Candidates arriving by vehicle shouldcontact Deborah Hastings for special instructions. Please note that all candidates must confirm their travel itinerary 1 month prior to camp startto ensure their spot.

First Name: Andrew Last Name: Krick Camp Date: 06/15/2019

Payment Method: Visa MC DISC WIRECard# Exp: 3 Digits Sec:

Complete the Two Lines below If Name/Address on Card Is DifferentAddress: City: State: Zip:Cardholder Signature: Cardholder Name: Date:

Print Name: Andrew Krick Date:Signature:

Address: 504 Pleasant St City: Three Rivers State: MI Zip: 49093 Phone: (269) 718-9690

LAN/WAN PRO MEMBERSHIP PACKAGE - CONFIRMATION FORMGeneral Information

Exam Fees, Deposit & Pay Through Income PercentageThe member listed above will pay for the Membership Package itemized below through 29.95% of his/her full-time gross monthly income for 42 months upon

employment, not to exceed the package value of $55,885 ($95,885 - $40,000). The candidate will be responsible for Cisco exam fees. In addition, you will beresponsible for a security deposit of $795 ($7,495 - $6,700 deferred to job offer) and lodging/meals fees of $1,386 ($66 X 14 + 7 nights) which will be due and

payable upon confirmation receipt. There will also be a recurring deposit of $250 starting on 04/11/2019 and every other week thereafter until camp attendance.This document must be signed and returned (via email or fax) by 8:00 AM PT on 03/30/2019.

$40,000 Credit & Package ConditionsThe member listed above can qualify to receive a $40,000 Credit. See Membership/Deferment conditions &, Credit Authorization form for details.

CONDITIONS - In addition, the member must meet all mutually agreed upon commitments including getting CCNP Tshoot, CCNA Security and meeting allrequired activities/assignments deadlines including spending 30 hrs/week during remote and 40 hrs/week during job search until employed. LAN/WAN

Professional reserves the right to cancel the membership and service deferment if the member does not meet mutually agreed activities as listed above and in themember/service authorization form. The member also commits to proactively job searching nationwide until employed. Finally, the member commits to work

on his validation skills and professional skills with specific focus reacting to pressure situations.

I Authorize LAN/WAN Professional To Charge For Fees As Described Above

Confirmation Of Services I Am Scheduled To ReceiveService Cost Status

LAN/WAN Professional Membership $995 N/ACCNP Core/ CCIE Basics & CCNP Tshoot $11,975 Upon ApprovalCWEA Practical, CCNA Security & Concepts $12,985 Prior To CampCWEA Camp /Placement Mentoring $31,985 Get Initial JobCWP Hands-On & Placement Package $37,945 Upon EmploymentLAN/WAN Advisor/Performance Credit ($30,000) Package CompletionLAN/WAN Advocate Credit ($10,000) 4 Members

Total $55,885

General Conditions & Cancellation PolicyBy signing below, I hereby state that I agree to the terms on this confirmation form and the previous pages. I understand that I may cancel this service at anytime with a written request. Cancellations within three days of confirmation processing will receive a full refund of confirmation fees. I also understand that

upon cancellation, I am only liable for any services and/or products that I have started as of the cancellation date that will begin immediately upon confirmationreceipt and processing. Any refunds will be applied to amounts owed first, and any balance left will be refunded within 30 days of effective date of withdrawal.

Candidates who cancel/reschedule less than 1 month prior to their camp start date will incur a cancellation/rescheduling fee of $950 if cancellation occursoutside of the three day grace period.

Print Name: Andrew Krick Date: Signature:

Membership/Service Deferment Conditions & $40,000 Credit Authorization FormThis document is designed to provide disclosure regarding member/service payment deferment conditions, along with parameters of the $40,000credit. Please take the time to review this page and ensure that you fully understand and agree to these parameters.

Membership/Service Payment Deferment Conditions - LAN/WAN Professional, a division of Global Networks Enterprises &Technologies, is a nationwide professional membership organization that focuses on providing a set of services to help its member progress intheir IT career. The member has been approved and by signing the attached form confirmation form, accepted the offer of membership includingconfirming that the member possesses 4 key right candidate attributes as itemized below and including meeting the following conditions.

1. Possess (1) Transferable Skills & (2) Tech Abilities - Possess (1) transferable professional skills to be employable in LAN/WANincluding the ability to interpret and follow detailed instructions and complete all assigned tasks in a timely/proficient manner and possess(2) good technical abilities including understanding the 4 part efficient learning structure and being able to apply this structure to acquireskills 20+ times faster including completing technical activities properly with minimal errors and also verbally communicate those technicalskills when asked.

2. Serious About Employment & Treat This Like A Job â€“ Member states that he/she is serious about upgraded employment includinginvesting a minimum of 40 hrs/week during job search until employed. In addition, the member commits to treat all remote and job searchactivities as if it is a serious fulltime job including making this their top priority until employed. In addition, the member will also treat thestaff of LAN/WAN as if there are technical leads and managers on a job and will properly follow our instructions as if on a job.

3. Document & Follow Methodology, Policies & Procedures - Member understands that LAN/WAN Professional has a very successful,but proprietary structure that results in timely employment but requires that the member follow very specific methodology, policies andprocedures. In addition, the member will need to provide timely and thorough documentation during remote and especially during jobsearch until employed and the member commits to doing both as requested by LAN/WAN Professional.

$40,000 Credit & Payment Deferment Explanation - The member listed below is receiving and scheduled to receive services as itemized onthe confirmation form. As an approved member, 100% of the services are fully deferred until job start. The member currently has an upfrontdeposit as stated in the confirmation form. Upon job offer receipt, the member will be responsible for a deferred deposit of $6,700. 100% of anydeposits paid will be applied to your obligations. Upon job start, the member will pay 29.95% of gross full-time monthly income for 42 monthsnot to exceed the service value less any deposits paid and credits earned. Your first month's payment is due and payable on the first day of jobstart and all future payments are paid in recurring payments tied to pay dates starting with the first paid date. In addition, the member is approvedfor a $40,000 credit. The following is an explanation of how the credit is earned.

1. $5,000 Remote Credit - $5,000 performance credit is directly tied to your remote performance. $2,500 of the credit is directly tied totimely completion of assignments. For every late assignment the member will lose $500, not to exceed 5 assignments. This includesattending all scheduled meeting with LAN/WAN staff. In the event that the member exceeds 5 lates, there may be an additional depositpenalty. Another $2,500 is tied to the number of assignment resubmits and your demonstration of technical knowledge during scheduledreviews.

2. $5,000 Job Search Credit - $5,000 of the performance credit is tied directly to your performance during job search. $2,000 is tied to yourjob search performance during camp including getting a rating of 3 (out of 5) in your job search skills out of camp. Another $3,000 is tiedto your timely employment with $3,000 credit if you receive a job offer within 3 weeks of camp completion, $2,000 if you receive a joboffer within 6 weeks of camp completion and $1,000 if you receive a job offer within 10 weeks of camp completion.

3. $5,000 Job Prep/Start Credit - $3,000 is tied to providing timely and thorough documentation during job prep/job start includingproperly following our job prep/start instructions and working closely with LAN/WAN staff including being available and prepared forscheduled meetings. Another $2,000 is tied to getting fully acclimated in the job and restarting your remote within 2 months of job start. Ifthe member starts later than 2 months but within 4 months, the member will receive $1,000 and any time after 4 months, the credit is $0.

4. $10,000 Advocate Credit - In consideration for this credit, you will advocate 4 new members ($2,500/member) with 4 months of initialemployment. The credit will be applied to the backend of the obligations. In the event that the member does not complete his obligations,the member will only receive a prorated portion of the credit.

5. $15,000 Advisor Credit - This credit is conditioned upon helping LAN/WAN Professional 3 to 5 hrs/month during the training periodand for 60 months thereafter. This includes timely and positive video and written testimonials. Assistance relates to any and all items,information and activities relating to the advance of LAN/WAN Professional, its members and its services.

By signing below I agree to all terms and conditions on this form

Exhibit B

First Name: Andrew Last Name: Krick E-mail: [email protected]: 504 Pleasant St City: Three Rivers State: MI Zip: 49093 Phone: (269) 718-9690




MUST CIRCLE ONE: Primary - 03/23/2019 - Pay $198 Secondary - 04/20/2019 - Pay $578

CWA HANDS-ON & 4 DAY BOOT CAMP CONFIRMATION FORMGeneral Information

$3,600 To $3,980 Grant & Package Value/Costs OverviewThe candidate listed above will receive the CWA Hands-On & 4 Day Camp Package valued at $3,980 to start 03/11/2019. Based on your performance during

your CWT Remote, background info as stated in your application & your commitment to upgraded employment in LAN/WAN, you are officially approved for a$3,600 to $3,980 Grant to be used for this package. Your costs after applying the grant are $0 ($3,980 - $3,980 Grant) to $380 ($3,980 - $3,600 Grant) plus $198($66 X 3) Lodging/Meals. Your package costs after grant and your lodging/meals are due and payable upon confirmation. To confirm, return a completed copy

of this form by 03/11/2019 7:00 AM (PST). Please CIRCLE the camp date you desire.

Grant Amount Explanation, Conditions & Background CheckYou are approved for a $3,600 to $3,980 Grant. $2,600 to $2,980 was determined by your performance during the CWT Remote combined with your

background, along with your time commitment/focus to upgraded employment as stated in your application to date including what you provided during thephone FILE REVIEW. Another $1,000 is conditioned your performance during the CWA Hands-On Package. $500 (CWA REMOTE) - Initial $500 isconditioned upon timely completion of ALL of your technical assignments including any scheduled communications/agreed upon commitments with

LAN/WAN Professional. For every late assignment/agreed upon commitment, you will lose $100 of your grant for a total of $500. The processing of the grantreduction will occur at the time of occurrence OR before camp attendance if not processed. $500 (CAMP PERFORMANCE) - The final $500 is determinedbased on the results of the official CWA exam result at the 4 day camp with Checkpoint 4 receiving $100 plus an additional $100 for every checkpoint above 4

for a total of $500 for Checkpoint 8. Historically, approved candidates who come prepared for camp should attain Checkpoint 6 or higher. Any grant reductionsfrom camp will be processed on the day of the CWA exam result. Background Check - Please note that background check will be conducted during the 4 day

camp to ensure that you qualify for LAN/WAN employment.

PAYMENT AUTHORIZATION & METHOD

Confirmation Of Services I Am Scheduled To ReceiveDescription ValueCertified WAN Admin (CWA) Hands-On Buildup $695CWA Hands-On Summation & Camp Prep $790CWA Hands-On & Career Advancement Camp $2,495Total $3,980

General ConditionsBy signing below, I state that I have thoroughly read, understand and agree to the information, terms and conditions of this form. I understand that I may cancelat any time from this service. Upon cancellation, my credit becomes void and I am not liable for any services I did not receive, but am liable for any services and

products I have engaged in as of the effective dates stated above. Any payments will be applied to services used and any balance left will be refunded within 1month of effective date of withdrawal. If the candidate needs to reschedule the camp date less than two weeks prior to camp attendance, there will be a $495

Rescheduling fee which is due, as we will not be able to replace your spot with such short notice.

Exhibit C

Andrew Krick 504 Pleasant St, Three Rivers, MI, 49093

[email protected], (269) 718-9690

Dear Andrew Krick,

Thank you for considering LAN/WAN Professional as a partner in advancing your career in enterprise IT (LAN/WAN).

We are pleased to inform you that you have been CONDITIONALLY approved for the comprehensive LAN/WAN Professional MembershipPackage valued at $55,885 ($95,885 - $40,000 Credit). As you already know, 100% of the value of the service is covered through your employmentsuccess and by working part-time as a LAN/WAN Advisor (see following pages).

Your conditional approval was based on our belief that your professional/educational history, along with the skills that you will acquire withLAN/WAN Professional, will enable you to secure timely employment in LAN/WAN earning $72,000 to $90,000 per year within 1 to 2(Unemployed Candidates) to 2 to 3 months (Working Candidates) of placement camp completion and full certification and attain upgradedemployment earning $90,000 to $120,000 within 6 to 12 months of initial LAN/WAN employment.

Please note that you will need to budget for miscellaneous hard costs including exam fees, lodging/meals at camps, transportation to/from camp,necessary deposits, living expenses including a small buffer for exam retakes and related expenses until employed In LAN/WAN.

LAN/WAN Membership Package Confirmation Instructions & DEADLINE: 03/30/2019 8:00 AM (PST)

TO CONFIRM, review this document and COMPLETE and return the appropriate confirmation form by the deadline listed above.

You can do this by logging onto the website you currently have access to and click on the ''Submit Confirmation Form By DEADLINE'' link thatis located below the menu bar of the secured website you currently have access to.

Thank you for considering LAN/WAN Professional as your partner in your information technology career.

Sincerely,

Eric Choi President/CEO

LAN/WAN Professional Membership Package Overview

Package Description & GoalsThe LAN/WAN Professional Membership Package is a comprehensive placement and career advancement service that combines over $50,000worth of proven effective enterprise LAN/WAN hands-on and certification training with comprehensive placement training and mentoring tofast track you into upgraded LAN/WAN employment The following is a summary of the services you receive:

Professional Package - $72,000 to $150,000 Per Year Duration ValueLAN/WAN Professional Membership N/A $995CCNP Core/ CCIE Basics & CCNP Tshoot (Upon Approval) 3 to 6 Weeks $11,975CWEA Practical, CCNA Security & Concepts (Prior To Camp) 3 to 6 Weeks $12,985CWEA Camp /Placement Mentoring (Get Initial Job) 15 Days + Remote $31,985Total to Initial Employment 2 to 5 Months $57,940CWP Hands-On & Placement Package (Upon Employment) 8 to 16 Months $37,945LAN/WAN Advisor/Performance Credit (Package Completion) N/A ($30,000)LAN/WAN Advocate Credit (4 Members) N/A ($10,000)Total Package Obligations after Credit 10 to 21 Months $55,885

*What You Pay - 100% Of Services Fees Tied To EmploymentThe total value of the LAN/WAN Professional Placement Membership Package is $55,885 ($95,885 - $40,000 Credit). This includes all trainingtuition costs, hands-on lab guides, 24/7 online access to reading and certification prep training. Please note you will be responsible for CiscoExam Fees, lodging/meals and transportation to/from camp. 100% of this program is paid through 29.95% of your full-time gross income for aperiod of 42 months, not to exceed the program value.

Please note that the average candidate should receive a minimum pay increase of 25% to 100% above his/her prior income potential. For thisreason, your increase will more than offset your fees. In effect, you will be receiving over $50,000 in enterprise Cisco training for free.

Pay For $40,000 Of Package Costs Through LAN/WAN Advisor/Performance/Advocate CreditLAN/WAN Professional understands that the best marketing for our service is a successful candidate. For this reason, candidates can qualify toreceive a $40,000 LAN/WAN Advisor/Performance/Advocate Credit to pay for the second portion of the LAN/WAN Professional Package.

$15,000 of the credit is conditioned upon helping LAN/WAN Professional approximately 3 - 7 hrs/month during your CWP remote trainingperiod and after training package completion for 60 months to include verbal and written feedbacks that are designed to help LAN/WANProfessional continually develop its services along with peer mentoring of candidates who are progressing through the service.

In addition, another $10,000 of the credit is tied to advocating 4 members within 24 months of initial LAN/WAN employment ($2,500 eachtowards Advocate Credit). Finally, $15,000 of the credit is tied directly to your performance during remote/camp, job search and job prep/start.You essentially pay for almost 50% of your service fees through your positive performance and by helping LAN/WAN Professional and othermembers. Another WIN/WIN situation.

PLACEMENT GUARANTEE CONDITIONSAll candidates must be serious about full-time employment in information technology and be committed to spending a minimum of 40 hours perweek actively seeking employment while maintaining proactive coordination with LAN/WAN Professional until employment has been secured.The goal is your timely initial employment within 2 to 8 weeks of camp completion and initial certifications. This requirement will be in effectduring any period that the candidate is not working.

15 Day CWEA Placement Camp Information

Attend 15 Day Camp & GET JOB Earning $72,000 to $90,000

Upon membership confirmation, you will continue your skills development by starting the LAN/WAN Hands-On Core that focuses on realworld hands-on that is expected of a seasoned LAN/WAN Professional. The topics covered include CCNP Core and CCIE Basics hands-on thatincludes IPv6, Redistribution, Multicast, BGP, MPLS, QOS. Your CCIE basics hands-on culminates in taking and passing the CCNPTroubleshooting exam.

Upon CCNP Troubleshooting certification, you will receive Certified WAN Enterprise Administrator (CWEA) Practical Hands-On for EnterpriseLAN and exterior WAN that includes core administrative activities you will be expected to know how to do in the real world. This hands-onincludes practical routing, switching, firewalls and VPN both on Cisco and Juniper technologies. Upon CWEA Practical Completion you willprepare for and pass your CCNA Security Certification. This is the second most sought after LAN/WAN skill set and is a must have skill for anylead level LAN/WAN roles. Your remote culminates in you attending a comprehensive 15 day intensive, full-immersion CWEA Hands-On &Placement Camp in Southern California. Your 15 day camp will begin Saturday after lunch and continue on to the third Saturday afternoon.

During the camp, you receive comprehensive hands-on training in Data Center focused Routing, Switching, Security along with Voice, Wireless,Data Center, 4 enterprise monitoring tools that culminates with you taking and passing the Certified WAN Enterprise Administrator (CWEA).This hands-on certification validates your acquisition of real world hands-on skills equivalent to those of a professional with 7 to 10 years ofproven work experience.

In addition, you will receive comprehensive, proven effective placement training, support and mentoring to fast track you into upgradedLAN/WAN employment earning $72,000 to $90,000 per year within 2 to 6 weeks (full-time) or 4 to 12 weeks (part-time) of camp completion andfull certification. Your actual compensation and employment time frame will vary significantly based on your previous credentials/skills, yourcamp performance and your employment seriousness including the number of hours you can commit to job search.

Upon job offer, you will receive comprehensive mentoring and support to ensure that you are fully functional in your new job that begins prior tojob start and will continue on to the first 1 to 3 months of initial employment until you are fully functional in your job responsibilities. Upon fullacclimation, you will finish your CCNA/CCNP Route and Switch exam and be fully certified as a CCNA/CCNP. In addition, you will receivecomprehensive hands-on refresh on core topics for routing, switching, security and monitoring.

Your remote training culminates in you attending an 8 day Placement Camp (Sat to 2nd Sat). The combination of your 6 to 12 months ofLAN/WAN employment along with the additional credentials/skills you acquire will qualify you for an upgraded LAN/WAN position earning$90,000 to $120,000 per year.

Shared Lodging/Meals & Travel To CampThe most convenient way for our out-of-state candidates to get to camp is by air travel. The airport closest to the training facility is John WayneAirport in Santa Ana, CA (airport code SNA). Please note that all candidates will be picked up at the airport on the first day of camp between12:00 and 1:00pm (PT) and dropped off at the airport at Noon (PT) on the final day of camp. Specific instructions will be provided by one of ourMember Services Representatives. For specific questions call Deborah Hastings, Member Relations Administrator @ (949)544-1355. Please emailyour flight itinerary to: [email protected].

All candidates flying to camp will be picked up at the John Wayne Airport baggage claim area. Candidates who require transportation outside thepickup/drop-off times will be charged a $50 pickup/drop off fee. To ensure that you are on time for your pickup and drop off, if you are flyinginto SNA, please schedule your arrival at or before Noon (PT) and your departure at or after 4pm (PT). Candidates arriving by vehicle shouldcontact Deborah Hastings for special instructions. Please note that all candidates must confirm their travel itinerary 1 month prior to camp startto ensure their spot.

First Name: Andrew Last Name: Krick Camp Date: 06/15/2019




Address: 504 Pleasant St City: Three Rivers State: MI Zip: 49093 Phone: (269) 718-9690

LAN/WAN PRO MEMBERSHIP PACKAGE - CONFIRMATION FORMGeneral Information

Exam Fees, Deposit & Pay Through Income PercentageThe member listed above will pay for the Membership Package itemized below through 29.95% of his/her full-time gross monthly income for 42 months upon

employment, not to exceed the package value of $55,885 ($95,885 - $40,000). The candidate will be responsible for Cisco exam fees. In addition, you will beresponsible for a security deposit of $795 ($7,495 - $6,700 deferred to job offer) and lodging/meals fees of $1,386 ($66 X 14 + 7 nights) which will be due and

payable upon confirmation receipt. There will also be a recurring deposit of $250 starting on 04/11/2019 and every other week thereafter until camp attendance.This document must be signed and returned (via email or fax) by 8:00 AM PT on 03/30/2019.

$40,000 Credit & Package ConditionsThe member listed above can qualify to receive a $40,000 Credit. See Membership/Deferment conditions &, Credit Authorization form for details.

CONDITIONS - In addition, the member must meet all mutually agreed upon commitments including getting CCNP Tshoot, CCNA Security and meeting allrequired activities/assignments deadlines including spending 30 hrs/week during remote and 40 hrs/week during job search until employed. LAN/WAN

Professional reserves the right to cancel the membership and service deferment if the member does not meet mutually agreed activities as listed above and in themember/service authorization form. The member also commits to proactively job searching nationwide until employed. Finally, the member commits to work

on his validation skills and professional skills with specific focus reacting to pressure situations.

I Authorize LAN/WAN Professional To Charge For Fees As Described Above

Confirmation Of Services I Am Scheduled To ReceiveService Cost Status

LAN/WAN Professional Membership $995 N/ACCNP Core/ CCIE Basics & CCNP Tshoot $11,975 Upon ApprovalCWEA Practical, CCNA Security & Concepts $12,985 Prior To CampCWEA Camp /Placement Mentoring $31,985 Get Initial JobCWP Hands-On & Placement Package $37,945 Upon EmploymentLAN/WAN Advisor/Performance Credit ($30,000) Package CompletionLAN/WAN Advocate Credit ($10,000) 4 Members

Total $55,885

General Conditions & Cancellation PolicyBy signing below, I hereby state that I agree to the terms on this confirmation form and the previous pages. I understand that I may cancel this service at anytime with a written request. Cancellations within three days of confirmation processing will receive a full refund of confirmation fees. I also understand that

upon cancellation, I am only liable for any services and/or products that I have started as of the cancellation date that will begin immediately upon confirmationreceipt and processing. Any refunds will be applied to amounts owed first, and any balance left will be refunded within 30 days of effective date of withdrawal.

Candidates who cancel/reschedule less than 1 month prior to their camp start date will incur a cancellation/rescheduling fee of $950 if cancellation occursoutside of the three day grace period.


Membership/Service Deferment Conditions & $40,000 Credit Authorization FormThis document is designed to provide disclosure regarding member/service payment deferment conditions, along with parameters of the $40,000credit. Please take the time to review this page and ensure that you fully understand and agree to these parameters.

Membership/Service Payment Deferment Conditions - LAN/WAN Professional, a division of Global Networks Enterprises &Technologies, is a nationwide professional membership organization that focuses on providing a set of services to help its member progress intheir IT career. The member has been approved and by signing the attached form confirmation form, accepted the offer of membership includingconfirming that the member possesses 4 key right candidate attributes as itemized below and including meeting the following conditions.

1. Possess (1) Transferable Skills & (2) Tech Abilities - Possess (1) transferable professional skills to be employable in LAN/WANincluding the ability to interpret and follow detailed instructions and complete all assigned tasks in a timely/proficient manner and possess(2) good technical abilities including understanding the 4 part efficient learning structure and being able to apply this structure to acquireskills 20+ times faster including completing technical activities properly with minimal errors and also verbally communicate those technicalskills when asked.

2. Serious About Employment & Treat This Like A Job â€“ Member states that he/she is serious about upgraded employment includinginvesting a minimum of 40 hrs/week during job search until employed. In addition, the member commits to treat all remote and job searchactivities as if it is a serious fulltime job including making this their top priority until employed. In addition, the member will also treat thestaff of LAN/WAN as if there are technical leads and managers on a job and will properly follow our instructions as if on a job.

3. Document & Follow Methodology, Policies & Procedures - Member understands that LAN/WAN Professional has a very successful,but proprietary structure that results in timely employment but requires that the member follow very specific methodology, policies andprocedures. In addition, the member will need to provide timely and thorough documentation during remote and especially during jobsearch until employed and the member commits to doing both as requested by LAN/WAN Professional.

$40,000 Credit & Payment Deferment Explanation - The member listed below is receiving and scheduled to receive services as itemized onthe confirmation form. As an approved member, 100% of the services are fully deferred until job start. The member currently has an upfrontdeposit as stated in the confirmation form. Upon job offer receipt, the member will be responsible for a deferred deposit of $6,700. 100% of anydeposits paid will be applied to your obligations. Upon job start, the member will pay 29.95% of gross full-time monthly income for 42 monthsnot to exceed the service value less any deposits paid and credits earned. Your first month's payment is due and payable on the first day of jobstart and all future payments are paid in recurring payments tied to pay dates starting with the first paid date. In addition, the member is approvedfor a $40,000 credit. The following is an explanation of how the credit is earned.

1. $5,000 Remote Credit - $5,000 performance credit is directly tied to your remote performance. $2,500 of the credit is directly tied totimely completion of assignments. For every late assignment the member will lose $500, not to exceed 5 assignments. This includesattending all scheduled meeting with LAN/WAN staff. In the event that the member exceeds 5 lates, there may be an additional depositpenalty. Another $2,500 is tied to the number of assignment resubmits and your demonstration of technical knowledge during scheduledreviews.

2. $5,000 Job Search Credit - $5,000 of the performance credit is tied directly to your performance during job search. $2,000 is tied to yourjob search performance during camp including getting a rating of 3 (out of 5) in your job search skills out of camp. Another $3,000 is tiedto your timely employment with $3,000 credit if you receive a job offer within 3 weeks of camp completion, $2,000 if you receive a joboffer within 6 weeks of camp completion and $1,000 if you receive a job offer within 10 weeks of camp completion.

3. $5,000 Job Prep/Start Credit - $3,000 is tied to providing timely and thorough documentation during job prep/job start includingproperly following our job prep/start instructions and working closely with LAN/WAN staff including being available and prepared forscheduled meetings. Another $2,000 is tied to getting fully acclimated in the job and restarting your remote within 2 months of job start. Ifthe member starts later than 2 months but within 4 months, the member will receive $1,000 and any time after 4 months, the credit is $0.

4. $10,000 Advocate Credit - In consideration for this credit, you will advocate 4 new members ($2,500/member) with 4 months of initialemployment. The credit will be applied to the backend of the obligations. In the event that the member does not complete his obligations,the member will only receive a prorated portion of the credit.

5. $15,000 Advisor Credit - This credit is conditioned upon helping LAN/WAN Professional 3 to 5 hrs/month during the training periodand for 60 months thereafter. This includes timely and positive video and written testimonials. Assistance relates to any and all items,information and activities relating to the advance of LAN/WAN Professional, its members and its services.

By signing below I agree to all terms and conditions on this form

Exhibit D

First Name: Andrew Last Name: Krick Phone: (269) 718-9690Address: 504 Pleasant St City: Three Rivers State: MI Zip: 49093

Circle One: 1 (Interest Free - Low Monthly) 2 (Interest Free w $14,000 Discount) 3 (Split Settlement)

Payment Method: Visa MC DISC WIRECard# Exp: 3 Digits Sec:Address: City: State: Zip:

Signature if name on card is different: Print Name: Date:

Candidate Signature: Print Name: Andrew Krick Date:

Professional Invoice Settlement Agreement (Special)CANDIDATE INFORMATION

Special Settlement ExplanationThe member listed above will be parting ways as a member of LAN/WAN Professional and currently has received $53,943 ($56,945 - $2,540 Deposit Payment -$462 lodging/meals credit) after applying payment credits. LAN/WAN Professional desires to part ways on a positive note and is offering 3 special settlement

options that not only includes discounts, but also options that include an interest free loan and split settlement tied to job offer. Please select from one of one ofthree settlement options listed below. Please returned the completed and signed agreement back to LAN/WAN Professional on for BEFORE 7am (PST) on

Monday, 9/16/2019 to be valid. Please note that if we do not receive this agreement by the deadline stated your special discount will be void, you will beresponsible for full balance of the $55,943 to be due and payable immediately. Please circle the special settlement option you desire.

OPTION 1 - INTEREST FREE LOAN W/ $6,000 DISCOUNT - $47,943Pay a net settlement of $47,943 ($53,943 - $6,000 Discount) through a interest free loan. An initial payment of $995 is due and payable upon settlement formreceipt. An initial recurring payment of $199 is due and payable 9/21 and every other week for 3 months or until LAN/WAN job offer receipt whichever is

earlier and then increased to just $599 until all payments are resolved.

OPTION 2 - INTEREST FREE LOAN W $14,000 DISCOUNT - $39,943Pay a net settlement of $39,943 ($53,943 - $14,000 Discount) through a interest free loan. An initial payment of $995 is due and payable upon settlement formreceipt plus a second payment of $5,995 on 9/21. Your balance is fully deferred for 6 months OR pay increase OR new job offer receipt whichever is earlier.

The remaining payment will be tied to pay checks at a reduced rate of 19.95% of gross full time income not to exceed the reduced balance with initial month'spayment to be paid on first day of work and all recurring payments tied to pay checks.

OPTION 3 - SPLIT SETTLEMENT W $24,000 DISCOUNT - $29,943Pay a net settlement of $29,943 ($53,943 - $24,000 Discount) through a interest free loan. An initial payment of $995 is due and payable upon settlement form

receipt plus a second payment of $5,995 on 9/21. Your balance of $23,953 is fully deferred for 6 months OR pay increase OR new job offer whichever is earlier.


Settlement Conditions & AuthorizationsThe settlement options stated above fully resolves all financial obligations between the candidate listed above and LAN/WAN Professional as long as the

payment amount listed on this settlement is paid in full and all conditions of the LAN/WAN Advisor obligations are met and is in positive status withLAN/WAN Professional. Please note that any payments over $6,000 made through a credit card will incur a 3% processing fee. In the event of any default

resulting from the payment obligation listed above, the candidate listed above will be liable for the original professional services invoice agreement for servicesstarted to date. In addition, the candidate will be responsible for any interest, penalties backdated to the professional services invoice date plus any costs

associated with the collection of the unpaid balance including legal, collections and related fees. If the candidate does not meet all conditions of the LAN/WANAdvisor agreement, any obligations paid by the advisor credit will be due immediately. If any provision of this Note is deemed unenforceable, in whole or in

part, for any reason, the remaining provisions shall still remain in full force and effect. The candidate authorizes the amount mentioned above to be processedthrough the payment method listed above in accordance with the parameters stated in this document. Candidate hereby agrees that LWP may assign its right to

receive payments pursuant to this contract to any other entity or person without the further consent of candidate.

By Signing Below I Agree To All Terms And Conditions On This Form

Exhibit E

First Name: Andrew Last Name: Krick Phone: (269) 718-9690Address: 504 Pleasant St City: Three Rivers State: MI Zip: 49093

Circle One: 1 (Reduced Hours) 2 (Current Hours)

Payment Method: Visa MC DISC WIRECard# Exp: 3 Digits Sec:Address:City: State: Zip:

Signature if name on card is different: Print Name: Date:

Candidate Signature: Print Name: Andrew Krick Date:

Deposit Penalty Deferment & Reduced Hours Authorization FormMEMBER INFORMATION

Deposit Penalty Deferment & Reduced Hours ExplanationThe member listed above is currently expected to job search as a reduced hours of 30 hrs/week including getting 1 client interview AND 8 resume submissions

per week including properly following our job search methodology approach and procedures AND in positive, professional and proactivecommunications/coordination with LAN/WAN staff. It has now been 2 weeks since job search started that the member has not met these goals during the first

2 weeks of job search. In addition, the member seems to have had difficulties maintaining positive and professional communications with LAN/WAN staff.Even worse, the members current job schedule may make it difficult to meet the volume goals of 30 hrs/week. Based on not meeting your weekly goals, therewould normally be an upfront deposit penalty of $2,000 ($1,000/week) that is in addition to the deferred deposits. With that stated, you are approved to have

this $2,000 deposit penalty fully deferred to job offer based on a recent positive discussion with the Executive Director and selecting one of two alternative jobsearch options listed below. Please select from one of 2 alternate job search options listed below. This document must be signed and sent back to LAN/WAN

Professional by 7:00 AM (PST) on 07/16/2019 to be valid. Please circle the alternate job search options listed below.

OPTION 1 - Reduced Job Search HoursThis options includes reducing your job search hours to 25 hrs/week including reducing your resume submissions to 5 per week (minimum) and getting .75interview per week. In other weeks, you will need to get 3 interviews every 4 weeks. A 5 hour reduction in job search is significant and normally requires a

$1,995 deposit. As a courtesy, your upfront deposit is reduced to just $495 and payable upon confirmation receipt. The remaining $1,500 is deferred to job offerreceipt along with all the other deferred deposits. If you get a job offer one or before 8/14, the $1,500 deferred deposit will be waived.

OPTION 2 - Stay With Current HoursYour will continue meeting the current job search hours of 30 hrs/week including 8 submissions/week and 1 interview per week. There is no upfront deposit

requirement for this option.

Reduced Future Deposit Penalties & ConditionsIf the member does not meet his weekly job search goals as listed above including being in positive, professional and proactive communications with all

LAN/WAN staff including and properly following the job search methodology, approach and procedures, there will be a reduced deposit payment of $499 forevery week that the goal is not met. This will be determined every every Saturday morning for the activities Monday to Friday and processed on Saturday. If themember does not get a job offer by 8/14, there will be a recurring weekly deposit payment of $99/week to be processed every Saturday until job offer receipt orthe recurring deposit penalties mentioned above whichever is higher. All deposit penalties will be processed using the payment processing method provided with

your confirmation form or using the payment method provided below.


By Signing Below I Agree To All Terms And Conditions On This Form

Andrew Krick 07/16/2019

MI

SOMMERS SCHWARTZ, P.C.€¦ · LAN/WAN membership will enable individuals to get a high paying job...

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