So on taking a further look at the court filing I think what we have here is your basic "real world spam" business model. Unfortunately these things are all over the place as they are a proven way to generate money by sending out a firehose of solicitations for an essentially useless "service".
Looking at the solicitation it clearly covers it's ass with all sorts of disclaimers, despite looking deceptively like a bill at first glance. I don't think the solicitation itself will hold up in court as being fraudulent alone. What they are alleging is that they did not even bother to put all the names in the book, and they did not send out as many books as they said they would.
You might ask yourself how such a mailing could be successful. Well, it is a sad truth that there are many aging business owners in many small towns across this country who are not quite on the ball enough to read the fine print anymore. Who falls for all those Nigerian emails? Obviously someone. Basically what these guys are doing is vacuuming up small checks from old man Higgins who is still running the ole' TV repair shop in downtown Podunk, even if nobody much bothers to fix their VCR anymore and the new Wal-Mart has got em for $49 anyways.
At some level this is along the lines of those "Who's Who" books that select you to be in a book of awesome people, and wouldn't you like to buy a copy? That kind of thing is pointless and deceptive, but not illegal. There seems to be more going on here.
A few questions:
Why get mail at a PO Box in Atlanta if this business is in Florida and it is so legitimate?
Illegal or not, do you really think this is the kind of ethics you want in your CFO? Or was it a deal with the dark side that had to be made?