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What travelers can expect this holiday season

Why FAA staffing cuts and AI “travel agents” are changing how you plan—and protect—your next trip

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FAA staffing cuts and government disruptions may lead to delays—and open the door to more travel scams targeting stressed flyers.

AI is being used by both legitimate travel services and scammers, making it critical for travelers to verify messages, calls, and customer service contacts before acting.

Travelers should adopt a “zero-trust” mindset, use credit cards for stronger protection, avoid unfamiliar payment methods, and go directly to airline or hotel sites to confirm ...

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2017
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Florida shuts down 'deceptive' travel club

February is prime vacation travel time, with many people seeking warmer temperatures in the tropics. So it's probably a good time to remind consumers about the prevalence of travel scams.

In Florida, Attorney General Pam Bondi has announced a settlement that permanently shuts down a travel company operation that she says was deceiving consumers with its sales tactics.

The agreement bars Map Destinations, LLC and its owners, operators, and managers from marketing travel club memberships. The company is based in St. Augustine, Fla.

No legal way to operate

After Bondi obtained a temporary injunction against Map Destinations, LLC, the court appointed a receiver, which determined that there was no way for it to legally operate.

According to Bondi, the company marketed travel club memberships to consumers, and these memberships often cost thousands of dollars. The company promised its customers that their memberships would give them discounted travel and access to expert travel advice.

But Bondi says her office got reports from consumers who said that Map Destinations and its owners overstated the savings and nature of the benefits. They also didn't like the way the memberships were marketed.

“Tourism is vital to Florida’s economy and we will not tolerate anyone using deceptive or unfair trade practices to take advantage of people trying to take a vacation,” Bondi said. “This settlement will help better protect travelers no matter their vacation destination.”

For the next five years, the company and its owners are prohibited from selling travel club memberships in Florida. It also agreed to give up any legal claim to its assets that were seized by the state during the investigation.

Grievances are common

The Federal Trade Commission says it routinely receives many reports about travel scams, most of which make victims believe they have won a free vacation. A telemarketer congratulates the victim on "winning" two tickets on a luxury cruise, but to claim their prize they must first wire several hundred dollars to cover fees and taxes.

When shopping for a vacation, the FTC suggests getting recommendations, calling to verify reservations and arrangements, and obtaining a copy of the cancellation and refund policies.

One final tip -- always pay with a credit card. If a problem arises, you can dispute the charge and usually get your money back.

2016
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Florida cracking down on travel club companies

Summer is normally the season associated with vacation travel, but plenty of snow birds travel in the winter, usually seeking the warmer climate of Florida or the desert southwest.

That keeps lawyers and investigators in Florida Attorney General Pam Bondi's office pretty busy, as they try to protect consumers from shady travel promoters and outright scammers.

In December, Bondi's office took action to shut down three travel companies it said were deceiving consumers. Now, the attorney general has obtained preliminary injunctions against several other travel related companies she accuses of doing the same thing.

“Unscrupulous sales tactics”

The latest complaint filed by Bondi’s Office accuses Reservation Services International of knowingly allowing its two distributors, Map Destinations, LLC and Florida Beaches Destinations Club, LLC, which operated as Suite Journeys and Diamond Vacations International, “to employ unscrupulous sales tactics to induce consumers into purchasing its vacation club memberships.”

Vacation clubs are a common source of travel grievances. Very often they are marketed the same way timeshares are – requiring consumers to sit through long and sometimes intense sales presentations.

Jeanette, of Boca Raton, Fla., says she recently attended a presentation by a travel company called IIG Promotions.

“Like everyone else on here, we too sat through the travel presentation in Florida,” Jeanette wrote in a ConsumerAffairs post. “When we were there it looked like they had solicited people who had just retired through Social Security. They got a list somehow.”

Jeanette says she and her husband were pitched a travel package costing $5,000, but they declined.

Something for free

Consumers are often lured into attending travel club sales presentations by the suggestion that they can get something free, or at a reduced price. It hardly ever works out that way.

Bondi says the companies named in her complaint allegedly exaggerated the true savings, nature, and value of the club memberships. She said some consumers paid several thousands of dollars for these travel club memberships that the companies claimed offered deeply discounted wholesale pricing on hotels, condominiums, cruises, rental cars, and vacation packages.

After making the purchase, consumers reported to Bondi's office that they could have gotten the same or better pricing on other free publicly available travel booking websites.

Bondi says the temporary injunction against Reservation Services International includes the appointment of a monitor to oversee the operations. It also freezes company assets and appoints a receiver against the affiliate companies.

Meanwhile, the Federal Trade Commission (FTC) cautions consumers to get plenty of details about the true status of promoted accommodations and promised benefits and, if you end up making a travel club purchase, always pay with a credit card.  

2014
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Illinois sues alleged vacation travel club

The state of Illinois is taking a Kansas-based company and two of its Chicago area sales agents to court, charging that they scammed Illinois residents out of at least $80,000 for membership in a bogus travel club that failed to deliver on its promises of vacation destinations across the globe.

Attorney General Lisa Madigan filed the lawsuit in Cook County Circuit Court against Global Connections of Overland Park, Kan., Madmol Inc., based in Crystal Lake, Ill., and GVN Illinois, based in Tinley Park, Ill.

According to the lawsuit, the companies operate a bogus travel club called Global Discovery Vacation Program. Madigan maintains the club scams as much as $8,000 in upfront payments and $398 annual fees from consumers for membership in the program that in reality provides no discounts and -- instead -- charges consumers even more money to book vacations.

Phony checks from phony companies

The Global Discovery Vacation Program is sold through direct mail solicitations and telemarketing calls that claim recipients have won a free prize or free roundtrip airfare. Many consumers reported receiving a fake check or letter made out to them from legitimate-sounding airlines, including “US Airlines” or “American Airways.”

When consumers contacted the company to claim their free prize and airfare, they learned they first had to attend a sales presentation for the Global Discovery Vacation Program. The presentation billed the program as an exclusive club, promising consumers access to hundreds of properties across the country and around the world for a discount.

“This operation has all the makings of a scam,” Madigan said. “Any time you are offered a ‘free’ prize or a supposed award, that’s a red flag. If you receive solicitations like this, your first and only move should be to throw it in the trash.”

The suit alleges consumers who signed up for the travel club had access to few of the promised vacation properties -- if any at all. The few consumers who were able to book a vacation found substandard conditions of the vacation properties, including reports of hotels infested with cockroaches and broken appliances.

The lawsuit seeks to ban the companies from operating in Illinois, provide full restitution to affected consumers and assess penalties based on violations of the Consumer Fraud and Deceptive Business Practices Act.

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Sea to Ski Vacations ordered to pay $7 million in penalties, restitution

Travel club memberships can be great when they work. But when they don't, they can be a major source of frustration and monetary distress.

Take Sea to Ski Vacations. It's been ordered to pay $7 million in fines and consumer restitution for violating the Colorado Consumer Protection Act. 

Denver District Court Judge Robert McGahey also prohibited the club's owners from owning, managing, or operating travel-related businesses again because of their deceptive business practices.

“Consumers complained that they were told membership in the travel club would entitle them to deep discounts on condos and cruises,” said Attorney General John Suthers. “Yet, after paying as much as $9,000 for a membership, the Sea to Ski ‘deals’ were no better than what the consumer could purchase on popular internet travel sites."

According to testimony from ex-employee witnesses, Sea to Ski employees regularly used Expedia and Priceline to book travel while pretending to be working with an exclusive provider of travel services. 

Sea to Ski attracted its customers by mailing postcards claiming that the recipient had won two free airline tickets. The “free airline ticket” offers often require substantial up-front fees, and such onerous travel restrictions that consumers are unable to redeem the travel vouchers. American Airlines sued the club for copyright infringement for the unlawful use of their logo.

The Colorado Attorney General warns that similar postcards using the Southwest, United, and Delta logos have also been used to attract consumers to other travel club presentations. Consumers should carefully read any fine print or conditions attached to “free” offers received by mail or email. Anyone who believes they may have been scammed is encouraged to file a complaint by calling the Colorado Consumer Protection Hotline at 800-222-4444.

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Dreamworks Vacation Club owner sentenced to seven years in prison

The owner of Dreamworks Vacation Club has been sentenced to seven years in prison by a New Jersey judge. Daryl Turner, 42, stole millions of dollars from customers of his travel club, Acting New Jersey Attorney General John J. Hoffman charged.

Turner, who pleaded guilty August 7, 2013, admitted that he pitched phony vacation travel membership packages to customers. He executed a consent judgment to pay restitution of approximately $2.6 million to his victims.

Turner’s wife, Robyn Bernstein, 44, who helped run his travel companies, was sentenced to five years of probation. She had also pleaded guilty to theft by deception. Under their plea agreements, Turner and Bernstein agreed to forfeit their home in Marlton and other assets seized in the investigation, including bank accounts, cars and a boat.

“Turner carried out one fraudulent scheme after another, stealing from hundreds of unsuspecting customers who thought he would make traveling more affordable for them,” Hoffman said. “Instead, he ruthlessly stole the money they had set aside for their vacations. This sentence puts Turner safely behind bars, where he can no longer deliver his devious sales pitches, and it requires him to pay full restitution to his victims.”

The state’s investigation revealed that Turner and Bernstein falsely promised large discounts and benefits to those who bought vacation packages, which typically cost between $2,200 and $6,500. They knew that the promised discounts and benefits were not available. In addition, they failed to deliver “free” round-trip airline tickets and cruises after customers paid them hundreds of dollars in “fees and surcharges” to qualify for the “free” promotional trips. They laundered more than $700,000 in criminal proceeds through their personal bank accounts and used the money to buy their luxury home in Marlton, according to testimony and court documents.

Back to his old tricks

“After law enforcement shut down Turner’s shady travel companies, he opened a new one and went back to his old tricks,” said Director Elie Honig of the Division of Criminal Justice. “By sending Turner to prison, we have ended his fraud spree and warned the public that this is not a man you want to trust with your money.”

“We remain committed to getting money back to the consumers who were defrauded, through liquidation of the ill-gotten assets seized from Turner and Bernstein,” said Eric T. Kanefsky, Director of the State Division of Consumer Affairs. “The civil and criminal cases are concluded but we do not consider this matter closed until restitution is in the hands of these consumers.”

The state’s investigation revealed that Turner and Bernstein recruited customers using mass postcard mailings that offered recipients a “complimentary cruise for two” and/or “complimentary airfare for two.”

When recipients called the toll-free number on the card, they were told they must visit one of defendants’ business locations for a 90-minute presentation, which turned out to be a high-pressure sales pitch to purchase vacation packages. 

2012
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New Jersey Shuts Down Travel Membership Company

If you receive a postcard inviting you to a presentation on how to saving big money on travel, you might be wise to show some skepticism. These come-ons, usually offering some kind of incentive to attend -- can end badly for consumers.

A suit filed by the state of New Jersey claimed Global Travel Solutions, LLC and its owner, Jason A. Krieck, took payments from consumers for costly travel club memberships that promised steep discounts on vacation packages and other travel benefits, and then failed to deliver the contracted-for services.

Consumers were also charged monthly fees for the memberships. The defendants allegedly invited consumers to attend sales presentations for the memberships with free promotional items, and then failed to deliver the items.

Must pay $350,000

In a settlement with the state Global Travel Solutions is required to direct all billing and reservations companies to immediately stop trying to collect payments from consumers on the company’s behalf. The company is also required to pay $350,000 to the state.

In addition, for a period of 5 years, Krieck is required to post a bond of at least $250,000 with the division if he opens, owns or operates any business in the state that sells merchandise to consumers. The defendants entered into the settlement without any admission of liability but has agreed to dissolve the business.

“We have stopped the sale of these allegedly worthless travel club memberships in the state and the continued collection activity against consumers who previously purchased memberships,” said New Jersey Attorney General Jeffrey Chiesa.

He also advised consumers to be extremely careful when listening to an attractive sales pitch for any product, including travel and vacation packages.

Beware of travel scams

“Travel scams, offering free amenities and big discounts for cruises and airfare, can be shockingly effective at separating consumers from their hard-earned money,” Eric T. Kanefsky, Acting Director of the New Jersey Division of Consumer Affairs, said. “These operations often begin with postcards inviting consumers to attend a presentation at which they will hear about amazing deals that really are too good to be true.”

Kanefsky says consumers who purchased memberships based on sales presentations lost thousands of dollars. He said any consumer who receives a similar solicitation should be extremely skeptical.

To date, New Jersey has identified more than 700 affected consumers, the majority of whom paid between $995 and $9,995.00 for the Global Travel memberships, plus a $29.95 monthly fee.

Suit Claims Vacation Travel Club Defrauded Consumers

Being invited to attend a presentation on vacation travel packages is like being invited to a presentation on timeshares. Chances are you're going to be sold something you don't really want that doesn't turn out nearly the way it's presented.

A five-count complaint alleges that Global Travel Solutions, LLC, and its owner, Jason A. Krieck, violated the New Jersey Consumer Fraud Act and the Advertising Regulations, among other laws, by committing "unconscionable commercial practices and deception, making false promises or misrepresentations, and engaging in the knowing omission of material facts in their advertisement and sale of memberships."

“We allege the defendants’ deceptive business practices began with postcards the company mailed offering complimentary cruises and roundtrip airfare, and continued right through their sales presentations,” Chiesa said. “Rather than getting away on a vacation, these consumers ended up stuck at home, dealing with the loss of their hard-earned money.”

Complaints

To date, the Division has received complaints from 54 New Jersey consumers, the majority of whom paid between $995 to $8,500 for the membership, plus a $29.95 monthly fee. After discovering that the memberships did not provide the represented deep discounts and availability of accommodations and other travel services, consumers attempted to cancel their memberships but were unable to do so for varying reasons.

Some consumers who contacted the company said were told cancellation papers would be mailed to them but no papers were received. Others went to the company’s Montvale, N.J., location during listed business hours but found the office was closed.

Empty promises

“According to our lawsuit, the defendants lured consumers into purchasing memberships through empty promises of discounted vacation services and free cruises and airfare, all with the purpose of defrauding consumers and enriching themselves,” said Thomas R. Calcagni, Director of the State Division of Consumer Affairs. “We allege that consumers paid significant money for sham memberships that were essentially worthless. In fact, consumers could find lower vacation travel prices through free internet sites.”

The alleged violations of the Consumer Fraud Act include inducing consumers to attend presentations for memberships by offering a complimentary cruise and airfare that are, in fact, not complimentary. The suit also charges the company failed to book the complimentary cruise and airfare even after the consumer submitted the requisite paperwork and paid the requisite deposits.

With vacation season approaching, consumers should be on the lookout for vacation deals that sound too good to be true. Unfortunately, most of them are.

2011
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New Jersey Travel Club Owner Arrested, Charged with Theft

Daryl Turner

Police have arrested the owner of numerous New Jersey vacation travel companies with a long history of consumer complaints. Daryl Turner, 39, of Cherry Hill, is accused of stealing more than $75,000 from consumers for vacation packages and travel benefits that were never provided.

Criminal Justice Director Stephen J. Taylor said Turner was arrested at his home and charged with second degree theft by deception.

It is alleged that since 2008, Turner, through his vacation travel companies, took payments from numerous consumers and then repeatedly failed to provide the contracted-for travel packages, or refund the money. Turner also allegedly failed to deliver various promotional items promised to consumers in return for their attendance at promotional seminars.

That's what happened to Donald of Edgewater Park, N.J.

“Sat in on a 90-minute presentation in return we were to receive a free cruise for 8 days 7 nights and airfare,” Donald told ConsumerAffairs.com. “We filled all information, sent in $603.00 for port charges, government taxes” but never received confirmation of the cruise and soon found that the company's telephone number had been disconnected.

Turner also allegedly used the corporate logos of airlines, hotels, and car rental companies in promotional materials without those companies' permission.

Under terms of a February 2011 agreement with the New Jersey Office of the Attorney General and the New Jersey Division of Consumer Affairs, Turner is barred from doing business in the state for no less than five years and cannot open or operate any such business in the future without state approval.

Under the agreement, Turner is responsible for over $2,188,000 in consumer restitution and $478,000 in civil penalties. Turner also is required to reimburse the state $419,780.10 for its attorneys’ fees and investigative costs.

The vacation trav el companies named as defendants in the state’s civil lawsuit included Dreamworks Vacation Club, Dreamworks Vacations, Bentley Travel, Modern Destinations Unlimited, Blue Water, Vacation Clubs LLC d/b/a La Bonne Vie Travel, Five Points Travel Company, Dream Vacations International, Inc., and Away We Go Promotions, LLC.

The Division of Consumer Affairs last month filed a six-count Complaint in Burlington County Superior Court that charges Turner, individually and d/b/a Reservations, his wife Robyn B. Bernstein, and their Marlton-based company, Travel Deals Limited Liability Company, as well as VIP Executives, LLC, with violating the New Jersey Consumer Fraud Act and Advertising Regulations by failing to fulfill promises of complimentary cruises and airfare used to induce attendance at sales presentations, and failing to provide the luxury vacation packages at discounted prices represented during the sales presentations.

New Jersey Sues Travel Company Owner (Again)

The State of New Jersey has filed a lawsuit against travel company owner Daryl Turner alleging deceptive marketing practices. The process was familiar because the state sued Turner and his company previously for the same reason.

In February New Jersey settled a multi-million dollar lawsuit alleging a pattern of deceptive business practices carried out by Turner's numerous vacation travel membership companies.

Failed to fulfill promises

The six-count complaint filed this week charges Turner, individually and d/b/a Reservations, his wife Robyn B. Bernstein, and their Marlton-based company, Travel Deals Limited Liability Company, as well as VIP Executives, LLC, with violating the New Jersey Consumer Fraud Act and Advertising Regulations, by failing to fulfill promises of complimentary cruises and airfare used to induce attendance at sales presentations, and failing to provide the luxury vacation packages at discounted prices represented during the sales presentations.

A judge temporarily enjoined the defendants from transferring or disposing of any assets related to the matter, and specifically enjoined Turner from any involvement in the business operations of Travel Deals or from otherwise engaging in the advertisement, offering for sale, and sale of vacation packages to consumers in and outside of New Jersey.

At the same time, the New Jersey attorney general is taking Turner back to court on the state's allegation that he is in violation of the recently agreed-to settlement.

Too-good-to-be-true offers

“As we allege in our lawsuit, Turner is in clear violation of his settlement with the State,” said Attorney General Paula T. Dow. “Every indication points to Travel Deals being yet another of Turner’s companies that dangles too-good-to-be-true offers of free cruises and international vacations in front of consumers, defrauds consumers of their hard-earned money, and then leaves them with little more than heartache and frustration.”

Dow's office says it has received complaints from 15 consumers, the majority of whom paid between $2,500 and $5,194 for vacation packages, which as alleged in the State’s new lawsuit, turned out to be essentially worthless.

Dow says the alleged scheme is similar to the one that was the subject of the previous lawsuit against Turner. According to that lawsuit, filed in 2009, Turner and his various vacation travel companies took payment from consumers and then repeatedly failed to provide the contracted-for vacation packages, or refund the money.

More than 670 consumers affected

The defendants also failed to deliver various promotional items promised to consumers in return for their attendance at promotional seminars. More than 670 affected consumers were identified in that lawsuit, which named Turner and his travel companies as defendants, namely Dreamworks Vacation Club a/k/a Dreamworks Vacations a/k/a Dreamworks, Five Points Travel Company, Bentley Travel, Modern Destinations Unlimited, Blue Water, Vacation Clubs LLC d/b/a La Bonne Vie Travel, Dream Vacations International, Inc., and Away We Go Promotions, LLC.

This week's lawsuit seeks to bar Turner from the travel business and require him to repay consumers nearly $2.2 million for vacation packages and/or complimentary items never provided.

New Jersey Travel Clubs Banished from the Garden State

The owner of numerous vacation travel club companies with a long history of consumer complaints in New Jersey has been barred from doing business in the state for no less than five years.

According to a lawsuit filed by the New Jersey Attorney General in 2009, defendants Daryl T. Turner, 39, of Cherry Hill, and his vacation travel companies took payments from numerous consumers and then repeatedly failed to provide the contracted-for travel packages, or refund the money.

The defendants also failed to deliver various promotional items promised to consumers in return for their attendance at promotional seminars. To date, over 670 affected consumers have been identified. The lawsuit further charges Turner and his companies with using in their promotional materials the corporate logos of airlines, hotels, and car rental companies without those companies’ permission.

Besides being barred from doing business for five years, Turner cannot open or operate any such business in the future without state approval, under terms of a settlement with the Office of the Attorney General and State Division of Consumer Affairs.

The vacation travel companies named as defendants in the state’s lawsuit include Dreamworks Vacation Club, Dreamworks Vacations, Bentley Travel, Modern Destinations Unlimited, Blue Water, Vacation Clubs LLC d/b/a La Bonne Vie Travel, Five Points Travel Company, Dream Vacations International, Inc., and Away We Go Promotions, LLC.

The civil complaint, filed in Morris County, was amended several times as Consumer Affairs investigators uncovered additional travel club companies owned or controlled by Turner throughout New Jersey. The Final Consent Judgment includes nine of Turner’s travel companies, all of which are now shut down.

We’ve reached a settlement that immediately puts an end to Mr. Turner’s business activities and prevents him from offering vacation travel club memberships and services here for at least five years, Attorney General Paula T. Dow said.

Under the settlement, Turner is responsible for over $2,188,000 in consumer restitution and $478,000 in civil penalties. Turner is also required to reimburse the state $419,780.10 for its attorneys’ fees and investigative costs.

Not only does this Judgment make Turner a ‘persona non grata’ in the New Jersey vacation travel industry, it clears the way for the Division of Consumer Affairs to investigate and seize any assets Turner has or may come into -- and that is precisely what we intend to do until every last consumer is made whole, until every last dollar is paid,” said Thomas R. Calcagni, Acting Director of the State Division of Consumer Affairs.

To assist in getting immediate relief to affected consumers, the Division of Consumer Affairs has identified those consumers who used credit cards to pay Turner and his companies for vacation packages, and will be contacting the credit card companies to inform them of the Consent Judgment to facilitate reimbursements to those consumers through credit card charge-backs.

Should consumers wish to pursue reimbursements from their credit card companies themselves, they may obtain an electronic copy of the Final Consent Judgment by contacting Consumer Affairs Investigator Murat Botas at murat.botas@lps.state.nj.us or(973) 273-8038.

Delaware Sues Serenity Travel, Destination Vacations

The Delaware Attorney General’s Office says it is moving forward with lawsuits against two travel companies that allegedly defrauded dozens of Delawareans.  According to complaints from consumers, Serenity Travel and Destination Vacation International failed to provide promised discounts and incentives to consumers who joined their travel clubs, and failed to pay refunds to consumers and change their business practices under a binding May 2010 agreement with the office.

“Delawareans deserve to be treated with fairness by the companies they do business with,” said Timothy Mullaney, Sr., Director of the Attorney General’s Fraud and Consumer Protection Division. “We’re taking action in court to ensure that customers receive the refunds they deserve and to protect all consumers from deceptive and misleading marketing practices.”

The Attorney General’s Office received more than 70 consumer complaints between June 2009 and May 2010 alleging the travel companies offered discounts on cruises, lodging and other travel products if they attended the companies’ marketing presentations, but then either failed to provide promised incentives or required customers to pay previously undisclosed fees.  

Customers also complained they were pressured to pay to join the travel clubs before they could research the companies, were not provided price quotes at marketing presentations, and that the companies opened credit cards in their names without permission. Serenity, customers said, claimed to have a strong rating from the Better Business Bureau when, in fact, the company had lost its accreditation. Customers also complained of difficulty acquiring the services the clubs advertised.

In May, 2010 the companies agreed to reimburse within 30 days the consumers who had filed complaints for the fees they paid to join their travel club.  The companies also agreed to provide additional customers with discounts that were promised but never delivered, change their marketing practices by clearly disclosing all of the terms and conditions for receiving incentives through written promotions, oral presentations, and the companies’ websites, provide fixed pricing; and make only truthful statements regarding their Better Business Bureau status. 

After the companies failed to provide the promised refunds to a number of consumers, the Attorney General’s Office filed a lawsuit against the companies in August, 2010 seeking customer refunds they had not yet paid along with additional penalties for violating the Delaware Consumer Protection Act.  Moreover, since the May, 2010 settlement agreement, additional consumers have complained that Serenity has failed to change its marketing practices, as required, by continuing to:

  • advertise "gifts" and free travel incentives that were never provided and in fact carried fees
  • engage in high pressure sales techniques such as substantial "one day only" price drops
  • misrepresent their accreditation with the Better Business Bureau
  • opened credit cards without the consumers' full knowledge and consent, and
  • fail to fulfill the type and price of travel available to Serenity members

Ongoing attempts to secure the unpaid refunds have failed and the Department will be moving forward with this lawsuit as well as a new lawsuit alleging continued deceptive trade practices, including purporting to buy consumers' timeshares in exchange for the consumer joining Serenity's club, requiring additional fees to transfer the timeshare, and using major travel brands on advertising and marketing when Serenity was not in fact affiliated with those brands.