Plaintiff U-Can-II, Inc. sues Defendants Richard Setzer; Setzer International, Inc.; Harold Gooch, Jr.; Gooch Support Systems, Inc.; Gooch Enterprises, Inc.; William Childers; TNT, Inc.; Thomas D. "Tim" Foley; T&C Foley, Inc.; Steven S. Woods; G.F.I. International, Inc.; ProNet Global Association, Inc.; Don Brindley; Global Support Services, Inc.; ProNet Global I, Inc.; John Doe; Richard Roe and other unknown conspirators, and alleges:

1. This cause arises out of business relationships between Plaintiff U-Can-II and Defendants complementary to what may be commonly referred to as the Amway business. Amway is an international multi-level marketing firm based in Michigan. This dispute does not directly involve the purchase or sale of Amway products. Instead, it pertains to what may be referred to as the Amway-related "tool and function business" more particularly described below. (Note: Terms in bold type are defined below in the accompanying Glossary of Terms on page XX74.) The tool and function business is not a part of Amway itself, but pertains to the promotion of Amway through the independent efforts of Amway distributors. The parties hereto are engaged in the Amway-related tool and function business.
   
   
2. Brig and Lita Hart (the "Harts") are the principals of a heretofore tremendously successful Amway distributorship, a non-party hereto. Plaintiff corporation, U-CAN-II, Inc., is owned by the Harts and facilitated the Harts' tool and function business. Over a period of 23 years, the Harts built a domestic and international network of over 200,000 independent downline distributors (the "Hart Network), achieving the coveted "Double Diamond" status in Amway. The Hart Network represents one of the very largest networks or "legs" within the Amway multi-level marketing network. The Hart Network is extremely valuable to the Harts as a means of selling Amway's products. And, equally important, it serves as a huge ready market for the Plaintiff's participation within the tool and function business. This, too, was recognized by the Defendants.
   
   
3. The causes of action hereinafter set forth, arising out of a common series of transactions and occurrences, are based upon the Defendants and their co-conspirators conducting a wrongful and elicit scheme to misappropriate the Plaintiff's tool and function business. Of particular concern is the Defendants' ongoing efforts to illegally boycott the Harts. The Defendants' activities give rise to liability under various common law causes of action. In substance, the Defendants' ruthless pursuit of the Plaintiff's tool and function business, and the interference with the Plaintiff's relationships with its network of distributors, have deprived the Plaintiff of millions of dollars in revenue. This case is intended to remedy and stop these wrongful actions.
   

   Jurisdiction and Venue
4. Personal jurisdiction is proper in this Court, pursuant to F.S.A. § 48.193(1)(a), (b), (f), (g), in that each of the Defendants has (a) operated, conducted, engaged in or carried on a business or business venture in this State; (b) an office or agency in this State; (c) committed a tortious act within this State; (d) breached a contract in this State by failing to perform acts required by the contract to be performed in this State; and/or jurisdiction is proper in this Court, pursuant to F.S.A. § 48.193(2) in that each Defendant is engaged in substantial and not isolated activity within this State. Further, on knowledge and belief, the Defendants acted in concert with one another in furtherance of a joint enterprise or conspiracy, such that the acts of one Defendant constitute the acts of all other Defendants.
   

   Parties
5. Non-parties Brig and Lita Hart are a married couple and citizens of the State of Florida. Plaintiff U-CAN-II, Inc. ("U-CAN-II") is a Florida corporation with principal offices located in Lakeland, Florida. The Harts are the owners and principals of U-CAN-II, which is the operating entity for the tool and function business for the Harts and B&L Hart Enterprises, Inc. ("Hart Enterprises"), a Florida corporation owned by the Harts and an Amway distributorship located in Lakeland, Florida. Hart Enterprises is an Amway distributorship or independent business ("IB"), a non-party, and brings no claims herein. The Plaintiff, the Harts and Hart Enterprises are collectively referred to herein at times as the "Hart Organization."
   
   
6. Defendant Richard Setzer ("Setzer") is a citizen of the State of South Carolina, residing at Route 5, Rock Road, Greer, South Carolina. Upon knowledge and belief, Setzer operates an Amway distributorship through a non-party corporation, but he is not himself an Amway distributorship/independent business. Setzer also conducts business through Defendant Setzer International, Inc. ("Setzer International"). Setzer International's principal is Defendant Setzer. On knowledge and belief, Setzer International is organized and existing under the laws of the State of South Carolina, with its principal place of business at 3089 S. Highway 14, Greer, South Carolina. Setzer International is engaged in the business of purchasing and reselling business support materials for use by Amway distributors, and of organizing seminars, rallies and major functions attended by Amway distributors. Setzer International is not an Amway distributorship/independent business. On knowledge and belief, the acts and/or omissions of the co-conspirators and Defendant Setzer are/were the acts and/or omissions of Setzer International. Setzer and Setzer International conduct business in the State of Florida and are subject to suit in Florida. Unless otherwise noted, reference to "Defendant Setzer" herein shall refer to all Setzer Defendants, including Setzer International, who are/were co-conspirators in the conspiracy hereinafter described.
   
   
7. Defendant Harold [Hal] Gooch, Jr. ("Gooch"), is a citizen of the State of North Carolina, residing at Six Curtis Court, Thomasville, North Carolina. Upon knowledge and belief, Gooch operates an Amway distributorship through a nonparty corporation, but he is not an Amway distributorship/independent business. Gooch also conducts business through Defendants Gooch Support Systems, Inc. ("Gooch Systems") and Gooch Enterprises, Inc. ("Gooch Enterprises"), and is president and co-owner of each; he is the principal of each company. Gooch Systems is organized and existing under the laws of the State of North Carolina, with their principal place of business at Six Curtis Court, Thomasville, North Carolina. Gooch Enterprises is a Florida profit corporation with its principal place of business at 2182 NW 91st Street, Miami, Miami-Dade County, Florida. On knowledge and belief, Gooch Systems is in the business of purchasing and reselling business support materials for use by Amway distributors, and Gooch Enterprises is in the business of organizing seminars, rallies and major functions attended by Amway distributors. Neither Gooch Systems nor Gooch Enterprises are Amway distributorships/independent businesses. Hal Gooch, Gooch Systems and Gooch Enterprises conduct, and have conducted, business in the State of Florida, and are subject to suit in Florida. The acts and/or omissions of Harold Gooch, Jr., as herein described, are those of Gooch Systems and Gooch Enterprises. Unless otherwise noted, reference to "Defendant Gooch" herein shall refer to all Gooch Defendants who are/were co-conspirators in the conspiracy hereinafter described.
   
   
8. Defendant William [Bill] Childers ("Childers"), is a citizen of the State of Florida. Upon knowledge and belief, Childers operates an Amway distributorship through a nonparty corporation, but he is not himself an Amway distributorship/independent business. Childers also conducts business through Defendant TNT, Inc. of Charlotte, North Carolina ("TNT"). TNT's principal is Defendant Childers. On knowledge and belief, TNT is organized and existing under the laws of the State of North Carolina, with its principal place of business at 1518 Providence Road, Charlotte, North Carolina. TNT is registered with the State of Florida as a foreign profit corporation. TNT maintains agents or other representatives in Monroe County and Palm Beach County. TNT is in the business of purchasing and reselling business support materials for use by Amway distributors, and of organizing seminars, rallies and major functions attended by Amway distributors. TNT is not an Amway distributorship/independent business. Childers and TNT conduct business in the State of Florida, and are subject to suit in Florida. The acts and/or omissions of William Childers, as herein described, are those of TNT. Unless otherwise noted, reference to "Defendant Childers" herein shall refer to all Childers Defendants, including TNT, who are/were co-conspirators in the conspiracy hereinafter described.
   
   
9. Defendant Thomas D. [Tim] Foley ("Foley"), is a citizen of the State of Florida, residing at 11541 Lane Park Road, Tavares, Florida. Upon knowledge and belief, Foley operates an Amway distributorship through a nonparty corporation, but he is not himself an Amway distributorship/independent business. Foley also conducts business through Defendant T&C Foley, Inc. of Tavares, Florida ("T&C"). T&C's principal is Defendant Foley. On knowledge and belief, T&C is organized and existing under the laws of the State of Florida, with its principal place of business at 11541 Lane Park Road, Tavares, Lake County, Florida. T&C is in the business of purchasing and reselling business support materials for use by Amway distributors, and of organizing seminars, rallies and major functions attended by Amway distributors. T&C is not an Amway distributorship/independent business. On knowledge and belief, the acts and/or omissions of the co-conspirators and Defendant Foley are/were the acts and/or omissions of T&C. Foley and T&C conduct business in the State of Florida, and are subject to suit in Florida. Unless otherwise noted, reference to "Defendant Foley" herein shall refer to all Foley Defendants, including T&C, who are/were co-conspirators in the conspiracy hereinafter described.
   
   
10. Defendant Steven S. Woods ("Woods"), is a citizen of the State of Florida, residing at 3316 NE Sugarhill Avenue, Jensen Beach, Florida. Upon knowledge and belief, Woods operates an Amway distributorship through a nonparty corporation, but he is not himself an Amway distributorship/independent business. Woods also conducts business through Defendant G.F.I. International, Inc. of Jensen Beach, Florida ("GFI"). GFI's principal is Defendant Woods. On knowledge and belief, GFI is organized and existing under the laws of the State of Florida, with its principal place of business at 3316 NE Sugarhill Avenue, Jensen Beach, Martin County, Florida. GFI is in the business of purchasing and reselling business support materials for use by Amway distributors, and of organizing seminars, rallies and major functions attended by Amway distributors. GFI is not an Amway distributorship/independent business. On knowledge and belief, the acts and/or omissions of the co-conspirators and Defendant Woods are/were the acts and/or omissions of GFI. Woods and GFI conduct business in the State of Florida, and are subject to suit in Florida. Unless otherwise noted, reference to "Defendant Woods" herein shall refer to all Woods Defendants, including GFI, who are/were co-conspirators in the conspiracy hereinafter described.
    
    
11. Defendant ProNet Global Association, Inc. ("ProNet"), is a purported not-for-profit, non-stock Delaware corporation engaged generally in the business of facilitating the sale of business support materials or "tools" for use by Amway distributors, and of organizing seminars, rallies and major functions attended by Amway distributors nationwide. ProNet's main offices are now located at Suite K, 5075 Cascade Road S.E., Grand Rapids, Michigan, but were previously located at 6851 Distribution Avenue South, Jacksonville, Florida. ProNet is registered in the State of Florida as a foreign profit corporation with its principal address at 6851 Distribution Avenue South, Jacksonville, Duval County, Florida. On knowledge and belief, Robert Blanchard, an executive and manager of ProNet, has conspired with the Defendants, and the acts and omissions of Blanchard are those of ProNet. ProNet does business throughout the United States. Defendants Gooch, Childers, Foley and Woods were/are "Founding Members" of ProNet, and serve on the ProNet Board of Directors and/or "Steering Committee." ProNet is not an Amway distributorship/independent business. ProNet is/was a co-conspirator in the conspiracy hereinafter described. The conspiracy controls ProNet; it is the conspiracy's instrumentality.
    
    
12. Defendant Don Brindley ("Brindley"), is a citizen of Florida, residing at 24700 Deer Trace, Ponte Vedra, Florida. Brindley is the principal of an Amway distributorship downline to the Harts, but Brindley is not an Amway distributor/independent business. Brindley is, and has been for several years now, active in respect to the Amway-related tool and function business, and serves as the principal of Defendant Global Support Services, Inc. On knowledge and belief, Brindley is or at least has been a member of the conspiracy hereinafter described.
    
    
13. Defendant Global Support Services, Inc. ("Global"), is a purported Delaware corporation engaged generally in the business of buying, manufacturing, supplying and/or selling business support materials or "tools" to Defendant ProNet's members for use by other Amway distributors. Global's main offices are located at 6851 Distribution Avenue South, Jacksonville, Florida. Global is registered with the State of Florida as a foreign profit corporation with its principal place of business at 6811 Phillips Industrial Blvd., Jacksonville, Florida, and it maintains an officer in Jacksonville, Duval County, Florida. Global works in tandem with ProNet. Global is/was a co-conspirator in the conspiracy hereinafter described. Global's principal is Defendant Brindley. Brindley's acts and/or omissions are/were Global's. Global is not an Amway distributorship/independent business.
    
    
14. Defendant ProNet Global I, Inc. ("ProNet Profit"), is a for-profit Delaware corporation. On knowledge and belief, ProNet Profit works in tandem with Defendants ProNet and Global, sells goods and/or services to ProNet members, does business in many states including Florida, and is a co-conspirator in the conspiracy hereinafter described. ProNet Profit's main offices are located at 6851 Distribution Avenue South, Jacksonville, Florida. ProNet Profit is not an Amway distributorship/independent business. On information and belief, ProNet Profit is controlled by Defendants Gooch, Childers, Foley and Woods, and owned by one or more of them and perhaps others, and is/was a co-conspirator.
    
    
15. On knowledge and belief, Defendants conspired among themselves and with other non-party co-conspirators, as more particularly described below, to undermine and damage the Hart Organization, as well as other successful Amway-related organizations. Accordingly, in the furtherance of this conspiracy or enterprise, the primary purpose being to evade and circumvent the essential "line of sponsorship," to boycott the Plaintiff, to impair the Hart Network, and to convert the Hart Organization's tool and function business to their own pecuniary benefit and advantage, the act or omission of one Defendant co-conspirator while active in the concerted activity constitutes the act or omission of all other co-conspirators, and vice versa. Not all participants in the conspiracy are known to the Plaintiff. For that reason, Plaintiff has designated John Doe and Richard Roe as representatives of other persons, unknown to Plaintiff at this time, who conspired with the other Defendants and non-party co-conspirators to accomplish the unlawful purposes of the conspiracy enterprise, as herein alleged.