MEMORANDUM OPINION AND ORDER
SIDNEY A. FITZWATER, Chief Judge.
The court revisits this enforcement action under the Credit Repair Organizations Act ("CROA"), 15 U.S.C. §§ 1679-1679J, to determine whether defendants should be enjoined from engaging in the business of a credit repair organization and should be subjected to civil penalties under § 5(m)(1)(A) of the Federal Trade Commission Act ("FTCA"), 15 U.S.C. § 45(m)(1)(A).
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