The complaint alleges a practice in which the shopping network advertises and sells items that are not in stock, and possibly will never be in stock. Allegedly, attempts to inquire about the status of paid-for orders are brushed off and requests for refunds are denied. The action seeks compensatory damages, declaratory and injunctive relief, punitive damages, and attorney's fees.

The Latin Shopping Television Network is composed of both a television sales channel that is carried nationally and an Internet website that is available to customers the world over. Appealing primarily to customers who are Hispanic or Latino, the network advertises merchandise, such as computers, satellite television systems, etc. for sale. According to the customers' allegations, the network targets people who have a limited ability to speak English and who have almost no knowledge of the American legal system.

It is claimed that the merchandise sold to the class members is rarely, if ever, in stock. Additionally, bait-and-switch tactics are allegedly utilized to encourage consumers to buy more expensive items than the ones advertised for sale. Once the item or items are paid for, they are allegedly rarely delivered. Calls and other attempts to obtain information about the status of purchases are deflected with the promise that the items are on order and will be delivered soon. Attempts by class members to obtain refunds for items never delivered are apparently fruitless, with the shopping network stating that it is "not their policy" to issue refunds.

The action contends that the shopping network's conduct is fraudulent and deceptive, a violation of the class members' civil rights under federal and state law, a violation of consumer protection laws and a violation of federal anti-racketeering laws.