In August 2003, named plaintiff Trevor Rieger ordered an AEGON membership services program called Bargain Network, also known as Bargain.com. He made the purchase with a credit card over the telephone. He was informed at that time that he would have an introductory 30 day period, after which he would be charged $9.95 per month for the service. He allegedly received no information on any other membership at that time. Later that month, Mr. Rieger received his credit card statement and found that he had not only been charged for Bargain Network, but also three other programs, QuestSavers, LeisurePlus, and Experts on Call, at the rate of $9.95 per program. When he called the toll-free number listed on the bill beside the Experts on Call charge, he was told that the programs were all marketed by the same company, Aegon.

Through similar means, the action alleges that AEGON double-, triple-, and even quadruple-bills clients who innocently order its programs. The memberships include discount shopping, travel, leisure and entertainment, insurance, home and garden products and services, automotive services, health services, and pet care programs. Customers’ information is allegedly transferred from the named service company to AEGON, which charges the consumer for additional unrequested services. At the time the consumer contacts the retailer, no information regarding AEGON is given—it is only when the consumer has received a credit card or bank statement that the up-selling becomes apparent. The consumer never has a chance to thwart AEGON’s sale of a membership because he knows nothing of it. The consumer allegedly never receives any other type of invoice or receipt showing the purchase. By these means, AEGON allegedly hopes to sneak its charges in on the bills of unwary consumers.