1 2 3 4 5 6 7 8 9 KAMALA D. HARRIS Attorney General of California FRANCES T. GRUNDER Senior Assistant Attorney General NICKLAS A. AKERS Supervising Deputy Attorney General NICHOLAS G. CAMPTNS (SBN 238022) ANGELA M. MuNOZ (SBN 263971) CAROLINE N. DESSERT (SBN 287783) Deputy Attorneys General 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 Telephone: (415) 703 -5500 Fax: (415) 703-5480 E-mail: Nicholas.Campins@doj .ca.gov Attorneys for THE PEOPLE OF THE STATE OF CALIFORNIA ENDORSED F I LED San Fronc:lsco County Superior Coutt OCT 1 0 Z013 CLERK OF THE COURT . BY. DEBORAH STEPPE DepUty CIM< 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN FRANCISCO 12 13 14 15 Case No. THE PEOPLE OF THE STATE OF CALIFORNIA, COMPLAINT FOR CIVIL PENALTIES, Plaintiff, PERMANENT INJUNCTION, AND OTHER EQUITABLE RELIEF 16 17 v. 18 19 20 21 22 23 Verified Answer Required Pursuant to Code of Civil Procedure Section 446 HEALD COLLEGE, LLC; CORiNTHIAN COLLEGES, INC.; CORiNTHIAN SCHOOLS, INC.; SEQUOIA EDUCATION, INC.; CAREER CHOICES, INC.; MJB ACQUISITION CORPORATION; TITAN SCHOOLS, INC.; RHODES COLLEGES, INC.; FLORIDA METROPOLITAN UNIVERSITY, INC.; EVEREST COLLEGE PHOENIX, INC.; and DOES 1 through 100, INCLUSIVE, 24 Defendants. 25 26 27 28 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 2 3 The People of the State of California ("the People"), by and through Kamala D. Harris, Attorney General, allege as follows: 1. The People bring this action to hold Corinthian Colleges, Inc. and its subsidiaries 4 that operate Heald, Everest and Wyotech schools (collectively "CCI") accountable for violating 5 California law by misrepresenting job placement rates to students, misrepresenting job placement 6 rates to investors, advertising for programs that it does not offer, unlawfully using military seals 7 in advertising, and inserting unlawful clauses into enrollment agreements that purport to bar any 8 and all claims by students. 9 2. CCI is engaging in thes,e unlawful, unfair, and fraudulent practices in connection 10 with the sale of programs that are very expensive. For example, Heald College in San Francisco 11 charges $3 9,510 in tuition and fees and $3,500 in books and supplies for an Associate of Applied 12 Science degree in Medical Assisting; Everest College in City of Industry charges $38,341 in 13 tuition and fees and $4,339 in books and supplies for its Criminal Justice Associate's degree; 14 Wyotech in Long Beach charges $35,000 in tuition and fees and $2,000 in books and supplies for 15 an Automotive Technology with Applied Service Management Associate's degree; and Everest 16 University Online's Brandon Campus charges $68,800 in tuition for an online Bachelor's degree 17 in "Paralegal." 18 3. CCI is selling these expensive programs to students throughout California, many 19 of whom head single parent families and have annual incomes that are near the federal poverty 20 line ($19,530 for a three-person household). CCI targets this demographic, which it describes in 21 internal company documents as composed of "isolated," "impatient," individuals with ''low self- 22 esteem," who have "few people in their lives who care about them" and who are "stuck" and 23 "unable to see and plan well for future," through aggressive and persistent internet and 24 telemarketing campaigns and through television ads on daytime shows like Jerry Springer and 25 Maury Povich. 26 4. CCI's unlawful, unfair, and fraudulent practices are all the more egregious in light 27 of the fact that its Everest campuses are subject to a permanent injunction secured by the People 28 in 2007 that bars many of the practices at issue. 2 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 5. 2 to permanently end CCI's unlawful, unfair, and fraudulent practices. PLAINTIFF 3 4 The People respectfully request that this Court use its equitable and legal authority 6. Plaintiff is the People of the State of California. The People bring this action by 5 and through Kamala D. Harris, Attorney General. The Attorney General is authorized by 6 Business and Professions Code sections 17204, 17206, and 17207 to bring actions to enforce the 7 Unfair Competition Law ("UCL"); by Business and Professions Code sections 17535, 17535.5, 8 and 17536 to bring actions to enforce the Fair Advertising Law ("FAL"); and by Government 9 Code sections 12658 and 12660 to bring actions to enforce the Corporate Securities Law of 1968 10 ("CSL"). DEFENDANTS 11 12 7. Defendant Heald College, LLC, is, and at all times mentioned herein was, an LLC 13 organized and existing under the laws of the State of California. Heald College, LLC' s principal 14 place of business is in the City and County of San Francisco. At all times relevant herein, 15 Defendant Heald College, LLC has transacted and continues to transact business throughout 16 California, including at campuses in Concord, Fresno, Hayward, Modesto, Rancho Cordova, 17 Roseville, Salinas, San Francisco, San Jose, Stockton and online. Heald College, LLC is a 18 wholly owned subsidiary of Corinthian Colleges, Inc. 19 8. Defendant Heald College, LLC, its agents, employees, officers, and others acting 20 on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant Heald 21 College, LLC, are referred to collectively herein as "Heald." 22 9. Defendant Corinthian Colleges, Inc., is, and at all times mentioned herein was, a 23 corporation organized and existing under the laws of the State of Delaware. Corinthian Colleges, 24 Inc.'s principal place of business is in Santa Ana, California in Orange County. At all times 25 relevant herein, Defendant Corinthian Colleges, Inc. has transacted and continues to transact 26 business throughout California, including at its headquarters in Santa Ana. Corinthian Colleges, 27 Inc.'s direct and indirect subsidiaries operate schools and/or enroll students throughout California 28 and include Corinthian Schools, Inc.; Rhodes Colleges, Inc.; Florida Metropolitan University, Inc.; 3 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 Titan Schools, Inc.; Career Choices, Inc.; Sequoia Education, Inc.; MJB Acquisition Corporation; 2 Everest College Phoenix, Inc.; and Heald College, LLC. 3 10. Corinthian Colleges, Inc.'s common stock has been listed on the Nasdaq National 4 Market System since February 1999 under the symbol "COCO." Corinthian Colleges, Inc.'s 5 common stock qualifies as a security as defined in Corporations Code section 25019. Corinthian 6 Colleges, Inc. qualifies as an issuer under Corporations Code sections 25010 and as a person 7 under Corporations Code section 25013. 8 9 10 11 11. Defendant Corinthian Colleges, Inc., its agents, employees, officers, and others acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant Corinthian Colleges, Inc., are referred to collectively herein as "Corinthian Colleges, Inc." 12. Defendant Corinthian Schools, Inc., is, and at all times mentioned herein was, a 12 corporation organized and existing under the laws of the State of Delaware. Corinthian Schools, 13 Inc.'s principal place of business is in Santa Ana, California in Orange County. At all times 14 relevant herein, Defendant Corinthian Schools, Inc. has transacted and continues to transact 15 business throughout California, including its Everest College campuses in Alhambra, Anaheim, 16 City oflndustry, Gardena, Hayward, Los Angeles - Wilshire, Ontario, Ontario Metro, Reseda, 17 San Bernardino, San Francisco, San Jose, Torrance, and West Los Angeles and its Wyotech 18 campus in Long Beach. Corinthian Schools, Inc. is a wholly owned subsidiary of Corinthian 19 Colleges, Inc. 20 13. Defendant Corinthian Schools, Inc., its agents, employees, officers, and others 21 acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant 22 Corinthian Schools, Inc., are referred to collectively herein as "Corinthian Schools, Inc." 23 14. Defendant Sequoia Education, Inc., is, and at all times mentioned herein was, a 24 corporation organized and existing under the laws of the State of California. Sequoia Education, 25 Inc.'s principal place of business is in Santa Ana, California, in Orange County. At all times 26 relevant herein, Defendant Sequoia Education, Inc. has transacted and continues to transact 27 business throughout California, including at its Wyotech campus in Fremont. Sequoia Education 28 Inc. is owned by Career Choices Inc. 4 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 15. Defendant Sequoia Education, Inc., its agents, employees, officers, and others 2 acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant 3 Sequoia Education, Inc., are referred to collectively herein as "Sequoia Education, Inc." 4 16. Defendant Career Choices, Inc., is, and at all times mentioned herein was, a 5 Corporation organized and existing under the laws of the State of California. Career Choices, 6 Inc.'s principal place of business is in Santa Ana, California, in Orange County. At all times 7 relevant herein, Defendant Career Choices, Inc. has transacted and continues to transact business 8 throughout California, including through Sequoia Education, Inc., which it owns. Career Choices 9 Inc. is a wholly owned subsidiary of Corinthian Colleges, Inc. 10 17. Defendant Career Choices, Inc., its agents, employees, officers, and others acting 11 on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant Career 12 Choices, Inc., are referred to collectively herein as "Career Choices, Inc." 13 18. Defendant MJB Acquisition Corporation, is, and at all times mentioned herein was, 14 a corporation organized and existing under the laws of Wyoming. MJB Acquisition 15 Corporation's principal place of business is in Santa Ana, California, in Orange County. At all 16 times relevant herein, Defendant MJB Acquisition Corporation has transacted and continues to 17 transact business throughout California, including at its Wyotech campus in West Sacramento. 18 MJB Acquisition Corporation is owned by Titan Schools, Inc. 19 19. Defendant MJB Acquisition Corporation, its agents, employees, officers, and 20 others acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by 21 Defendant MJB Acquisition Corporation, are referred to collectively herein as " MJB Acquisition 22 Corporation." 23 20. Defendant Titan Schools, Inc., is, and at all times mentioned herein was, a 24 corporation organized and existing under the laws of Delaware. Titan Schools, Inc.'s principal 25 place of business is in Santa Ana, California, in Orange County. At all times relevant herein, 26 Defendant Titan Schools, Inc. has transacted and continues to transact business throughout 27 California, including through MJB Acquisition Corporation, which it owns. Titan Schools, Inc. is 28 a wholly owned subsidiary of Corinthian Colleges, Inc. 5 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 21. Defendant Titan Schools, Inc., its agents, employees, officers, and others acting on 2 its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant Titan 3 Schools, Inc., are referred to collectively herein as "Titan Schools, Inc." 22. 4 Defendant Rhodes Colleges, Inc., is, and at all times mentioned herein was, a 5 corporation organized and existing under the laws of Delaware. Rhodes Colleges, Inc.'s principal 6 place of business is in Santa Ana, California in Orange County. At all times relevant herein, 7 Defendant Rhodes Colleges, Inc. has transacted and continues to transact business throughout 8 California, including through its subsidiaries Florida Metropolitan University, Inc. and Everest 9 College Phoenix, Inc. Rhodes Colleges, Inc. is a wholly owned subsidiary of Corinthian Colleges, 10 11 Inc. 23. Defendant Rhodes Colleges, Inc., its agents, employees, officers, and others acting 12 on its behalf, as well as subsidiaries, affiliates, and other entities controlled by Defendant Rhodes 13 Colleges, Inc., are referred to collectively herein as "Rhodes Colleges, Inc." 14 24. Defendant Florida Metropolitan University, Inc., is, and at all times mentioned 15 herein was, a corporation organized and existing under the laws of the State of Florida. Florida 16 Metropolitan University, Inc.'s principal place of business is in Santa Ana, California, in Orange 17 County. At all times relevant herein, Defendant Florida Metropolitan University, Inc. has 18 transacted and continues to transact business throughout California, including through Everest 19 University Online, which it operates as part of institutions it owns with physical locations in 20 Brandon, Pompano Beach and Orlando, Florida. Florida Metropolitan University, Inc., is a 21 wholly owned subsidiary of Rhodes Colleges, Inc. 22 25. Defendant Florida Metropolitan University, Inc., its agents, employees, officers, 23 and others acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by 24 Defendant Florida Metropolitan University, Inc., are referred to collectively herein as "Florida 25 Metropolitan University, Inc." 26 26. Defendant Everest College Phoenix, Inc., is, and at all times mentioned herein was, 27 a corporation organized and existing under the laws of the State of Arizona. Everest College 28 Phoenix, Inc.'s principal place of business is in Santa Ana, California, in Orange County. At all 6 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 times relevant herein, Defendant Everest College Phoenix, Inc. has transacted and continues to 2 transact business throughout California, including through its online school, Everest College 3 Phoenix Online, which it operates as part of an institution it owns with physical locations in 4 Phoenix and Mesa, Arizona. Everest College Phoenix, Inc. is owned by Rhodes Colleges, Inc. 5 27. Defendant Everest College Phoenix, Inc., its agents, employees, officers, and 6 others acting on its behalf, as well as subsidiaries, affiliates, and other entities controlled by 7 Defendant Everest College Phoenix, Inc., are referred to collectively herein as "Everest College 8 Phoenix, Inc." 9 28. The true names and capacities, whether individual, corporate, associate or 10 otherwise, of defendants sued herein as Does 1 through 100, inclusive, presently are unknown to II the People, who therefore sue these defendants by their fictitious names. The People will seek 12 leave to amend this Complaint to allege the true names of Does I through 100 once they have 13 been ascertained. Does 1 through 100 participated in some or all of the acts alleged herein. 14 29. Does 1 through 50, their agents, employees, officers, and others acting on their 15 behalf, as well as subsidiaries, affiliates, and other entities controlled by Does 1 through 50, are 16 referred to collectively herein as "DOE Defendants 1 to 50." 17 30. Does 51 through 100, their agents, employees, officers, and others acting on their 18 behalf, as well as subsidiaries, affiliates, and other entities controlled by Does 51 through 100, are 19 referred to collectively herein as "DOE Defendants 51 to 100." 20 31. Heald, Corinthian Colleges, Inc., Corinthian Schools, Inc.; Sequoia Education, Inc.; 21 Career Choices, Inc.; MJB Acquisition Corporation; Titan Schools, Inc.; Rhodes Colleges, Inc.; 22 Florida Metropolitan University, Inc.; Everest College Phoenix, Inc.; DOE Defendants 1 to 50; 23 and DOE Defendants 51 to 100 are referred to collectively in this Complaint as "CCI," and/or 24 "Defendants." 25 32. Whenever reference is made in this Complaint to any act of"CCI," and/or 26 "Defendants," that allegation shall mean that each Defendant acted individually and jointly with 27 the other Defendants named in that cause of action. 28 7 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 33. At all times mentioned herein, each of the Defendants acted as the principal, agent, 2 or representative of each of the other Defendants, and in doing the acts herein alleged, each 3 Defendant was acting within the course and scope of the agency relationship with each of the 4 other Defendants, and with the permission and ratification of each of the other Defendants. 34. 5 6 At all relevant times, Defendants have controlled, directed, formulated, known and/or approved of, and/or agreed to the various acts and practices of each of the Defendants. 7 35. Whenever reference is made in this Complaint to any act of any Defendant or 8 Defendants, the allegation shall mean that the Defendant or Defendants did the acts alleged in this 9 Complaint either personally or through the Defendant's or Defendants' officers, directors, 10 employees, agents and/or representatives acting within the actual or ostensible scope of their 11 authority. 36. 12 At all times mentioned herein, each Defendant knew that the other Defendants 13 were engaging in or planned to engage in the violations of law alleged in this Complaint. 14 Knowing that other Defendants were engaging in such unlawful conduct, each Defendant 15 nevertheless facilitated the commission of those unlawful acts. Each Defendant intended to and 16 did encourage, facilitate, or assist in the commission ofthe unlawful acts alleged in this 17 Complaint, and thereby aided and abetted the other Defendants in the unlawful conduct. 18 37. Each Defendant committed the acts, caused or directed others to commit the acts, 19 or permitted others to commit the acts alleged in this Complaint. Additionally, some or all of the 20 defendants acted as the agents of the other defendants, and all of the Defendants acted within the 21 scope of their agency if acting as an agent of another. 38. 23 24 25 Each Defendant is a "person" as defined in Business and Professions Code section 39. 22 All of the conduct that forms the basis for this Complaint has been undertaken by 17201 . Defendants by and through their agents, employees, officers, or others acting on their behalf. 26 27 28 JURISDICTION AND VENUE 40. This Court has original jurisdiction over this action pursuant to California Constitution article 6, section 10. 8 COMPLATNT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 41. This Court has jurisdiction over Defendants because each Defendant's principal 2 place of business is in California or each Defendant otherwise intentionally avails itself of the 3 California market so as to render the exercise ofjurisdiction over it by the California courts 4 consistent with traditional notions of fair play and substantial justice. 5 6 7 42. The violations of law alleged in this Complaint occurred in the City and County of San Francisco and elsewhere throughout California. 43. Venue is proper in this Court pursuant to Code of Civil Procedure section 395.5 8 because Heald College, LLC's principal place of business is in the City and County of San 9 Francisco. 10 44. Venue is also proper in this Court pursuant to Code of Civil Procedure section 393, 11 subdivision (a) because violations of law that occurred in the City and County of San Francisco 12 are a "part of the cause" upon which the People seek the recovery of penalties imposed by statute. 13 45. Venue for the People's cause of action against Corinthian Schools, Inc. is proper in 14 San Francisco pursuant to Business and Professions Code sections 17207, subdivision (b) and 15 17535.5, subdivision (b) because, as more particularly alleged herein, violations ofthe final 16 judgment ofthe Los Angeles Superior Court in People v. Corinthian Schools, Inc., et al. (Super. 17 Ct. L.A. County, 2007, No. BC374999) occurred in the City and County of San Francisco. 18 19 DEFENDANTS' REPRESENTATIONS AND BUSINESS PRACTICES 46. CCI operates nationally and regionally accredited schools throughout California 20 and online. The schools include Everest Colleges, Everest University, Everest College Phoenix, 21 Heald Colleges, and Wyotech. 22 Misrepresenting Job Placement Rates to Students 23 47. From a date unknown to the People and continuing to the present, CCI's 24 representations and advertisements related to job placement were untrue, misleading, or both. For 25 example, the data in the disclosures published on or about July 1, 2012 for all campuses in 26 California and online campuses does not match or agree with the data in CCI's own database 27 systems and/or in student files. In numerous cases, the placement rate data in CCI's files shows 28 that the placement rate is lower than the advertised rate. 9 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 48. CCI's marketing studies show that student "[e]nrollment largely hinges on selling 2 affordability & [job] placement." As Bob Bosic, Corinthian Colleges, Inc.'s Executive Vice 3 President of Operations, stated: "Our students come to us primarily to gain skills and find a 4 position that will help them launch a successful career." 5 49. To help sell its programs to prospective students, CCI issues standardized 6 disclosures for each campus related to job placement. The disclosures contain placement rates for 7 each program. The consumer disclosur?es are published online and provided to students in hard 8 copy as part of the enrollment process. 9 50. The placement rates published by CCI are at times as high as 100 percent, leading 10 prospective students to believe that if they graduate they will get a job. These placement rates are 11 false and not supported by the data. In some cases there is no evidence that a single student in a 12 program obtained a job during the time frame specified in the disclosures. 13 51. These violations are all the more egregious given senior CCI executives' firsthand 14 knowledge of the misconduct. More specifically, CCI management knew that CCI had a 15 placement compliance problem: 16 (a) 17 presentation that was to be read by the ELT [Executive Leadership Team] in 18 advance of an offsite me?eting. One of the slides stated: "We have a placement 19 compliance problem now. " 20 (b) 21 Schools and Colleges (ACCSC) sent a letter to the Campus President of Everest 22 College Hayward noting that "39 of the 167 [medical assistant] students reported 23 as employed in field were employed by the same agency, Select Staffing" and that 24 the documentation provided by Everest "did not clearly demonstrate that the 25 employment at Select Staffing constitutes sustainable employment in a related 26 field." In response, Everest College Hayward admitted that the positions were 27 health screening fair positions but stated that the positions were valid placements. On or about September 23,201 I, CCI's CEO, Jack Massimino, e-mailed a On or about December 7, 2011, the Accrediting Commission of Career 28 10 COMPLAINT FOR CIVIL PENAL TIES, PERMANENT INJUNCTION AND OTHER RELIEF On or about June 6, 2012, ACCSC sent a follow-up letter to the Campus President, 2 noting that "the majority of placements with Select Staffing resulted in two days of 3 employment and did not clearly demonstrate that the employment at Select 4 Staffing constitutes 'sustainable' employment for a reasonable period of time in a 5 field related to the graduate' s educational program." 6 (c) 7 Nicole Camagey, e-mailed the Executive Vice President of Operations, Bob Bosic, 8 to tell him that in 2011 Everest College Hayward and Everest College San 9 Francisco paid a temporary agency, Remedy Temp, "to place students to meet the 10 accreditation deadline and minimum placement%." Bosic responded, asking her 11 to find the answers to numerous questions regarding the placements and noted 12 "This is the [expletive omitted] that got [Everest College] Decatur in trouble and 13 the types of questions that need answering." 14 (d) 15 audit showing that 53 percent of student placement files reviewed were missing 16 employment verification forms was emailed to the CEO, Jack Massimino, and 17 other senior executives. 18 (e) 19 emailed to David Poldoian, Executive Vice President of Corinthian Colleges, 20 Inc.'s Online Learning Division, showed a placement file error rate of 53.6 percent 21 to 70.6 percent. 22 (f) 23 Operations, Bob Bosic e-mailed all division presidents and stated "the placement 24 verification issues we discussed Monday were shared over the last two days and 25 were not well received. We will discuss Monday, but together we'll need to 26 demonstrate improvement. I will be interested in your thoughts on how we can 27 tighten this up so future audits reflect greater accuracy and completion of 28 documents." On or about February 10, 2012, CCI's Western Division President, On or about March 20, 2012, An Everest College San Francisco internal On or about April 13, 2012, an Everest Online internal audit presentation On or about April 27, 2012, CCI's Executive Vice President of II COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF (g) On or about May 12, 2012, CCI' s Executive Vice President of Operations, 2 Bob Bosic, e-mailed the Chief Administrative Officer Ken Ord and Carrnella 3 Cassetta, Senior Vice President and President, Online Learning a copy of a 4 presentation regarding placements which stated "No current guidelines and 5 training to define a placement - mistakes are repeated constantly because no clear 6 definition of a placement exists;" and "inconsistent processes on what passes as in- 7 field or related [placement]." 8 (h) 9 Carnagey and Executive Vice President of Operations, Bob Bosic exchanged e- 10 mails regarding the Renton, Washington Everest campus's failure of an internal 11 audit due to backdating of signatures on placement files. The e-mails discussed 12 how Everest College Gardena (in California) "almost got hit" as well and saying 13 that " If the current RVPO [Regional Vice President of Operations] was there she 14 would have been in a world of [expletive omitted]." The Executive Vice President, 15 Bob Bosic also told the Western Division President, Nicole Carnagey that "you 16 are correct that all the other campuses in yours and other divisions that made it 17 through [verit1cation audits] this time are lucky." 18 (i) 19 Bob Bosic, e-mailed the CEO, Jack Massimino, regarding the findings of an 20 internal review of placement procedures and stated that the review found that there 21 was a "Lack of workable definitions for a Placement" and that the lack of specific 22 definitions resulted "in subjective decisions at all levels;" that there "is no 23 consistent process for Placement (or other areas of Career Services) and lack of 24 SOP's [Standard Operating Procedures];" that there "is generally no training at the 25 process level for Placement (since there is no standard process);" and that 26 "Campus Vue [CCI's data management system] is not fully utilized [which] 27 [l]eads to poor data or lack of data availability as well as duplication of data across 28 forms and the Placement Verification system." On or about May 18, 2012, CCI's Western Division President, Nicole On or about June 14, 2012, CCI' s Executive Vice President of Operations, 12 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF On or about July 13, 2012, CCI's Vice President of Compliance, Michelle 1 2 Reed e-mailed Beth Wilson, Executive Vice President, regarding results of a 3 review of Wyotech Long Beach self-employment placements. The review showed 4 that the files for 28 of74 such placements had missing documents, or included 5 Craigslist ads that purported to be from the students in question, but that had in 6 fact been created by CCI. An additional 15 files were suspicious. Despite these 7 known irregularities, as of 8112/2013, the Long Beach disclosures (published on 8 7/1/2012) had not been amended to take into account the audit's findings. 9 (k) On or about July 16, 2012, CCI' s Assistant Vice President of Student 10 Outcomes e-mailed Division Presidents regarding Career Services Operating 11 Procedures, with a copy ito the Executive Vice President of Operations. The 12 emails stated that, "[o)ver the past year, several campuses have had challenges 13 providing adequate documentation for placements and waivers [emphasis in 14 original]. Issues that have surfaced during audits and Employment Verification 15 reviews are missing key fields such as signatures, inconsistencies with 16 CampusVue I other backup and in some cases, documentation that was never 17 procured or cannot be found." 18 (I) 19 by Hyper Core solutions on behalf of an accreditor, ACCSC, were e-mailed to 20 CCI's Executive Vice President and Chief Academic Officer. The review, which 21 examined a random sample of330 student records showed substantial issues at 22 each CCI campus examined (Everest campuses including West Los Angeles, City 23 oflndustry and Reseda). In particular, the review found that 30 percent of the 24 placements could not be verified and that there were no records to substantiate a 25 further 9 percent of the placements. At Everest College West Los Angeles, only 26 30 percent of criminal justice program placements could be verified and 20 percent 27 were identified as no record found. At the same campus, only 36 percent of dental On or about August 28, 2012, the results of a third-party audit conducted 28 13 COMPLAINT FOR CIVIL PENAL TIES, PERMANENT INJUNCTION AND OTHER RELIEF assistant program placements could be verified and 55 percent were identified as no record found. 2 3 52. The consumer disclosures provided to students by CCI and published online are 4 misleading and/or false for the reasons articulated above, including but not limited to the fact that 5 (a) the data in the system used to generate them do not support them; (b) the paper files do not 6 meet accreditor standards; and (c) CCI managers knew that the placement numbers were 7 unreliable and unsubstantiated and failed to publicly amend or qualify them. 8 Misrepresenting Job Placement Rates to Investors 9 53. From a date unknown to the People and continuing to the present, Corinthian 10 Colleges, Inc. made representations to investors related to job placement that were false and/or 11 materially misleading when made. Such representations include but are not limited to the 12 following: 13 (a) 14 Annual Report (Form 10-K) that: "Our colleges endeavor to obtain information 15 regarding their students' employment following graduation. The reliability of that 16 information depends, to a large extent, on the completeness and accuracy of the 17 data provided to our colleges by graduates and their employers. Additionally, a 18 dedicated team at the campus support center conducts a verification process to 19 check the accuracy of the placement information gathered by our campuses. 20 Based on information received from these groups of people, we believe that 21 approximately 68.1% of our graduates in calendar year 2011 who were available 22 for placement have been placed in a job for which they were trained by June 30, 23 2012, using accrediting agency standards." 24 (b) 25 Inc. 's CEO used a version of a presentation with investors that stated "CY 26 [Calendar Year] 11 placement 68.1% vs. 67.6% in CY 10." On or about August 24, 2012, Corinthian Colleges, Inc. stated in its On or about August 20, 20 12 and October 31, 2012, Corinthian Colleges, 27 28 14 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF (c) On or about January 24, 20I3, Corinthian Colleges, Inc. incorporated its 2 Annual Report (and the 68.1 percent job placement number) into a Registration 3 Statement (Form S-8) for its Employee Stock Purchase Plan. 4 (d) 5 Corinthian Colleges, Inc.'s CEO made a presentation to investors that 33,316 of 6 48,930 eligible graduates in the 20II graduation cohort were "placed in field." 7 (e) 8 call with investors that: "In the area of placement, we continue to achieve solid 9 results for the 20 I2 cohort graduates. We currently expect our calendar 20 I2 IO placement rate to meet or slightly exceed our placement rate in calendar 2011, II which was 68.1 %. " I2 (f) 13 "This is just a quick slide on information we've given you over the years around I4 graduation and placement. And one of the things we're pretty proud of is in a 15 pretty difficult time, we have done a pretty remarkable job in terms of placement. 16 We have over 800 placement people in our organization today helping our students 17 get jobs in the areas we trained them for. We're very tight on our definitions. And 18 so if you're a medical assistant, for example, with us and you get a job at a doctor's 19 or the hospital, those count. If you get a job as an aide in a nursing home, that 20 does not count even though you're making $IO to $I2 an hour. So we're very tight 2I on our definitions around what is and what isn't included in our placements. We've 22 been averaging over the course of this very difficult time up to around 68%, 69%, 23 and we're about there again this year." 24 54. On or about January 3I, 2013, March 11,2013 and April30, 2013, On or about January 3I, 20I3, Corinthian Colleges, Inc.'s CEO stated in a On or about March I1 , 2013, Corinthian Colleges, Inc.'s CEO stated: The statements concerning the 20 II graduation cohort were false when made and 25 CCI senior executives knew they were false. In fact, CCI's own data and files suggest that the 26 actual rate is much lower and has been subject to manipulations and assumptions not disclosed to 27 investors, included but not limited to: 28 15 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 (a) On or about July 31, 2012, Beth Wilson Executive Vice President of CCI 2 instructed her team to exdude 2011 graduates from what she deemed "Closed 3 Schools" including Fife, Washington, Chicago, Illinois, Ft. Lauderdale, Florida, 4 Decatur, Georgia and Arlington, Texas from the calculation to bring the placement 5 rate higher. This adjustment was not disclosed to investors. 6 (b) 7 number of placements that occurred outside the time frame specified by the 8 disclosures. 9 (c) The data used by CCI to generate the placement rate included a substantial The data used by CCI to generate the placement rate included a substantial 10 number of double-counted placements. 11 (d) 12 of the 68.1 percent placement rate in the annual report), Michelle Reed, Vice 13 President of Compliance, emailed a spreadsheet showing that a substantial number 14 of placements and waivers for the 2011 graduation cohort had still not been 15 verified. 16 55. On or about November 16, 2012 (nearly three months after the disclosure Corinthian Colleges, Inc.'s CEO and/or senior management were, at all relevant 17 times, aware of the falsity, inaccuracy, and unreliability ofjob placement data and the statements 18 they made concerning the data, yet they did not disclose that fact to consumers or investors, or 19 take any action to make consumer disclosures and statements to investors accurate. 20 56. Written illustrations of this knowledge include, but are not limited to, the 21 allegations set forth in Paragraph 51 above. They demonstrate that Corinthian Colleges, Inc.'s 22 CEO and/or senior management knew all of the following at the time the placement 23 representations concerning the 2011 graduates were made to investors: (1) CCI had a placement 24 compliance problem; (2) two CCI schools paid temporary agencies to employ graduates; (3) 25 audits at CCI programs showed that over half of the placement files were missing; (4) there were 26 company-wide placement verification issues, including a lack of any definitions or standard 27 procedures; (5) placement files at one CCI campus were backdated; (6) self-employment files 28 were being fabricated at one CCI campus; (7) campuses were not providing adequate or accurate 16 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF documentation; and (8) a third-party review ordered by ACCSC of 330 randomly selected files 2 3 found that 39 percent of placements could not be verified. 57. Despite senior management's knowledge that the statements they made in 4 securities filings and to investors were false and/or materially misleading, none of the false 5 representations were amended and/or restated by Corinthian Colleges, Inc. Instead, as alleged 6 herein, senior management continued to repeat and reinforce the false representations and make 7 new ones. For example, CCI's CEO's knowingly false statement that CCI was "tight" on its 8 definitions of what constitutes a placement. 9 58. The misstatements concerning the placement rate are material to investors because 10 a reasonable investor would consider the rate important in reaching an investment decision. For 11 example, CCI's CEO considers the job placement rate to be "the most important metric in the 12 company." It is material to investors for several reasons related directly to Corinthian Colleges, 13 Inc.'s ability to access government funds and enroll students; 14 (a) 15 wide graduate placement rate is an important measure of its ability to attract and 16 enroll new students. A poor or unmarketable placement rate therefore leads to 17 fewer enrollments and Jess revenue. 18 (b) 19 Commission of Career Schools and Colleges (ACCSC) and/or the Accrediting 20 Council for Independent Colleges and Schools (ACICS). Both accreditors require 21 schools to meet minirmun placement rates by school and by program. The ACCSC 22 "Established Benchmark Employment Rate" is 70 percent and the ACICS standard 23 is 65 percent. Where CCI's job placement rate as a company falls relative to the 24 65 and 70 percent requirements set by ACCSC and ACICS is therefore indicative 25 of CCI's ability to keep its campuses accredited and, relatedly, its ability to access 26 federal funds. 27 (c) 28 loans, including subprime loans for which CCI bears the risk of default. The job First, as discussed above, placement drives enrollment. The company- Second, the majority ofCCI's campuses are accredited by the Accrediting Third, if graduates cannot find work, they are likely to default on their 17 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 placement rate is also important to the cohort default rate (CDR), a measure used 2 by the Federal Department of Education and the California Student Aid 3 Commission. For example, in California schools must keep their CDR rate below 4 15.5 percent to draw Cal Grant funds. 5 (d) 6 account for almost all of its revenue, will be tied to how well its graduates perform 7 in the job market. Specifically, the Federal Department of Education recently 8 announced the establishment of a negotiated rulemaking committee to establish 9 gainful employment regulations which will govern CCI's access to federal funds. 10 59. Fourth, CCI faces a substantial risk that its access to federal funds, which Moreover, CCI's strategy is to close or sell campuses that are not meeting 11 placement outcomes. This strategy is reflected in a May 5, 2012 e-mail exchange between the 12 Executive Vice President of Operations, Bob Bosic, and the Division President of Wyotech 13 Michael Stiglich, referring to job placement metrics. Securities analyst reports concerning CCI 14 demonstrate that the market is aware of and concerned about CCI's strategy of closing 15 underperforming schools. 16 Advertising for Programs that CCI Does Not Offer 17 60. Heald, Corinthian Schools, Inc., and Corinthian Colleges, Inc. do not offer 18 ultrasound technician programs, x-ray technician programs, radiology technician programs or 19 dialysis technician programs in California. 20 61. Despite this fact, from a date unknown to the People and continuing to the present, 21 Heald, Corinthian Schools, Inc., and Corinthian Colleges, Inc. have nevertheless run millions of 22 online and mobile ads stating that they do offer ultrasound technician, x-ray technician, radiology 23 technician or dialysis technician programs, certificates, diplomas, or degrees at their California 24 campuses. Illustrative examples are attached as Exhibit A hereto. 25 62. Consumers are routinely tricked by these ads into entering their information to be 26 contacted by Heald, Corinthian Schools, Inc., and Corinthian Colleges, Inc. on the internet or 27 into contacting Heald, Corinthian Schools, Inc., and Corinthian Colleges, Inc. directly. 28 18 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 63. In some cases, a Heald, Corinthian Schools, Inc., or Corinthian Colleges, Inc. 2 representative convinces the consumer to visit the campus without ever disclosing that the 3 program is not offered, while in other cases the Heald, Corinthian Schools, Inc., and Corinthian 4 Colleges, Inc. representative pressures the prospective student into considering a different 5 program that is offered by Corinthian Colleges, Inc. 6 64. The fact that these false ads mislead students is known by Heald, Corinthian 7 Schools, Inc., and Corinthian Colleges, Inc. Call center employees who try to tell prospective 8 students the truth are disciplined by CCI managers. 9 Unlawfully Using Military Seals In Advertising 10 65. From a date unknown to the People and continuing to the present, Heald and 11 Corinthian Colleges, Inc. included the official seals of the United States Department of the Army, 12 the United States Department of the Navy, the United States Department of the Air Force, the 13 United States Marine Corps, and the United States Coast Guard in mailings, electronic messages, 14 and Internet Web sites to solicit information, or to solicit the purchase of or payment for a product 15 or service. 16 66. 17 18 The seals and related content were used in a manner that reasonably could be interpreted or construed as implying federal government connection, approval, or endorsement. 67. For example, the seals were prominently displayed on Healdmilitary.com until 19 recently and they continue to be prominently displayed in online ads run by Heald, an example of 20 which is attached hereto as Exhibit B. 21 68. Heald and Corinthian Colleges, Inc. have no expressed connection with or 22 approval by the United States Department of the Army, the United States Department of the Navy, 23 the United States Department of the Air Force, the United States Marine Corps and the United 24 States Coast Guard. 25 69. Heald and Corinthian Colleges, Inc. have never included the statutory disclaimers 26 indicated by Business & Professions Code section 17533.6 on any mailings, electronic messages, 27 and internet websites containing the seals of the United States Department of the Army, the 28 19 COMPLAINT FOR CIVIL PENAL TIES, PERMANENT INJUNCTION AND OTHER RELIEF United States Department ofthe Navy, the United States Department of the Air Force, the United 2 States Marine Corps, or the United States Coast Guard. 3 Inserting Unlawful Clauses into Enrollment Agreements 4 70. CCI enrollment agreements contain language that violates Civil Code section 1770, 5 subdivision a, paragraph 14, because they purports to confer rights and remedies on CCI that are 6 expressly prohibited by law. The agreements contain clauses that are substantially identical to the 7 following language: 8 GENERAL RELEASE OF CLAIMS. I hereby release and hold 9 this School harmless from and against any and all claims of any I0 kind whatsoever, including allegations related to needle sticks, 11 allied health and automotive practice and techniques, slips and falls 12 and quality of equipment and instruction, (collectively, "Claims"), 13 against the School (including its present and former parent 14 companies, insurers, representatives and all persons acting by or 15 through them), which I may have for any reason arising out of or 16 relating to my education. I am aware of the risks involved with my 17 education and knowingly assume those risks following my 18 investigation into possible injuries and the nature and quality of my 19 education. I further agree that if I bring any Claim against the 20 School, I shall reimburse the School for its attorney's fees and costs 21 incurred as a result thereof. I may opt out of this general release of 22 Claims provision by delivering a written statement to that effect 23 received by the School within 30 days of my first execution of an 24 Enrollment Agreement with the School. 25 71. Because the clause claims that CCI is exempt from responsibility from "any and 26 all claims of any kind whatsoever" and therefore from its "own fraud, or willful injury to the 27 person or property of another, or violation of law, whether willful or negligent," it is per se 28 invalid under Civil Code section 1668. 20 COMPLAINT FOR ClVfL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 72. Nevertheless, in violation of Civil Code section 1770, subdivision (a), CCI 2 continues to use the invalid clause to unlawfully represent that it has rights that it does not have 3 (e.g., the right to fees if sued), and/or that students have obligations they do not have (e.g., the 4 obligation to refrain from suing CCI under all circumstances). 5 FIRST CAUSE OF ACTION AGAINST ALL DEFENDANTS 6 VIOLATIONS OF BUSINESS AND PROFESSIONS CODE SECTION 17500 7 (UNTRUE OR MISLEADING REPRESENTATIONS) 8 9 10 73. The People reallege all paragraphs set forth above and incorporate them by reference as though they were fully set forth in this cause of action. 74. From a date unknown to the People and continuing to the present, Defendants, and 11 each of them, have engaged in and continue to engage in, aided and abetted and continue to aid 12 and abet, and conspired to and continue to conspire to engage in acts or practices that constitute 13 violations of Business and Professions Code section 17500 et seq., by making or causing to be 14 made untrue or misleading statements with the intent to induce members of the public to purchase 15 Defendants' services, as described in Paragraphs 47 to 52 and 60 to 69. Defendants' untrue or 16 misleading representations include, but are not limited to, the following: (a) 17 Defendants' statements regarding job placement rates, including but not 18 limited to their published job placement disclosures that were posted online and provided to 19 students during the enrollment process; 20 21 (b) advertisements for programs, certificates, diplomas, or degrees they do not offer in California; (c) 22 23 24 Heald's, Corinthian Schools, Inc.'s, and Corinthian Colleges, Inc.'s Heald's and Corinthian Colleges, Inc.'s unlawful use of United States government seals in advertisements. 75. At the time the representations set forth in Paragraph 74 were made, Defendants 25 knew or by the exercise of reasonable care should have known that the representations were 26 untrue or misleading. 27 28 21 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF 1 SECOND CAUSE OF ACTION AGAINST ALL DEFENDANTS 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTION 17200 3 (UNFAIR COMPETITION) 4 5 6 76. The People reallege all paragraphs set forth above and incorporate them by reference as though they were fully set forth in this cause of action. 77. Defendants, and each of them, have engaged in and continue to engage in, have 7 aided and abetted and continue to aid and abet, and have conspired to and continue to conspire to 8 engage in business acts or practices that constitute unfair competition as defined in the Unfair 9 Competition Law, Business and Professions Code section 17200 et seq., in that such business acts 10 11 12 and practices are unlawful, unfair, and fraudulent within the meaning of that statute. 78. The business acts and practices engaged in by Defendants that violate the Unfair Competition Law include: 13 (a) 14 misleading, unreliable, and/or inaccurate job placement rate information. 15 (b) 16 running ads for programs, certificates, diplomas, or degrees they do not offer in 17 California. 18 (c) 19 failing to disclose to students on the phone that Defendants do not offer certain 20 programs, certificates, diplomas, or degrees in California. 21 (d) 22 United States governrnent seals to imply a connection to, approval by, or 23 endorsement by the United States Department of the Army, the United States 24 Department of the Navy, the United States Department of the Air Force, the 25 United States Marine Corps, and the United States Coast Guard, when Heald and 26 Corinthian Colleges, Inc. have no such endorsement. 27 (e) 28 related to job placement rates and related information to investors. As to all Defendants, publishing and/or providing students with untrue, As to Heald, Corinthian Schools, Inc. and Corinthian Colleges, Inc., As to Heald, Corinthian Schools, Inc. and Corinthian Colleges, Inc., As to Heald and Corinthian Colleges, Inc., unlawfully using official As to Corinthian Colleges, Inc., making untrue statements of material fact 22 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF (t) As to Corinthian Colleges, Inc., omitting material facts from statements to 2 investors related to job placement rates. 3 (g) 4 falsely state that Defendants are immune from liability from any and all claims of 5 any kind whatsoever. 6 79. As to all Defendants, including clauses in enrollment agreements that These business acts and practices are unlawful because they violate laws including. 7 (a) 8 alleged in Paragraphs 47 to 52, 60 to 69, and 73 to 75. 9 (b) Business and Professions Code section 17500, as more particularly Corporations Code section 25400, subdivision (d), as more particularly 10 alleged in Paragraphs 53 to 59 and 91 to 100. 11 (c) 12 Paragraphs 53 to 59 and 82 to 90. 13 (d) 14 alleged in Paragraphs 65 to 69. 15 (e) 16 alleged in Paragraphs 60 to 69. 17 (f) 18 alleged in Paragraphs 65 to 69. 19 (g) 20 alleged in Paragraphs 60 to 64. 21 (h) 22 particularly alleged in Paragraphs 70 to 72. 23 80. Corporations Code section 25401, as more particularly alleged in Business and Professions Code section 17533.6, as more particularly Civil Code section 1770, subdivision (a), paragraph 2, as more particularly Civil Code section 1770, subdivision (a), paragraph 3, as more particularly Civil Code section 1770, subdivision (a), paragraph 9, as more particularly Civil Code section 1770, subdivision (a), paragraph 14, as more These business acts and practices are unfair in that Defendants have: 24 (a) 25 obligations, and/or spend years of their lives in educational programs because they 26 hoped to get a job and believed they would get a job based on Defendants' untrue 27 and misleading representations; caused students to pay tens of thousands of dollars, undertake huge credit 28 23 COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION AND OTHER RELIEF in the case of Heald, Corinthian Schools, Inc. and Corinthian Colleges, 1 (b) 2 Inc., caused consumers to call them, visit their campuses, and/or enroll at one of 3 their schools by misleading them into believing they offer programs, certificates, 4 diplomas, or degrees they do not offer; 5 (c) 6 including service members and veterans, to call them, visit their campuses, enroll 7 at one of their schools, and/or use federal benefits they accrued through service to 8 their country under the false pretense that they have a connection with, approval of, 9 or endorsement of the United States Department of the Army, the United States in the case of Heald and Corinthian Colleges, Inc., caused consumers, 10 Department of the Navy, the United States Department of the Air Force, the 11 United States Marine Corps, and/or the United States Coast Guard; 12 (d) 13 immune from liability from any and all claims of any kind whatsoever, and 14 thereby dissuading students with valid legal claims from taking legal action; 15 (e) 16 and/or substantially injurious to consumers. 17 81. included clauses in enrollment agreements that falsely stated that they are engaged in conduct that is irnrnoral, unethical, oppressive, unscrupulous, These business acts and practices are fraudulent in that Defendants' untrue and 18 misleading representations regarding their: job placement rates; ads for programs, certificates, 19 diplomas, or degrees they do not offer; unauthorized use of official United States government 20 seals; and use of enrollment agreements that falsely state that Defendants are irnrnune from 21 liability, and are likely to deceive the public. 22 THIRD CAUSE OF ACTION AGAINST 23 CORINTHIAN COLLEGES, INC. 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