NYC Department of Consumer and Worker Protection Against National Floors Direct, Inc.

THE CITY OF NEW YORK

OFFICE OF ADMINISTRATIVE TRIALS & HEARINGS, TRIALS DIVISION

NYC DEPARTMENT OF CONSUMER AND

WORKER PROTECTION,

Petitioner,

-against-

NATIONAL FLOORS DIRECT, INC.,

Respondent.

PETITION

OATH Index No. _______

The New York City Department of Consumer and Worker Protection (“DCWP” or the

“Department”) brings this action against Respondent, National Floors Direct, Inc. (“NFD” or

“Respondent”), and alleges as follows:

INTRODUCTION

1. NFD, a home improvement contractor (“HIC”), is a largescale provider of

flooring products and related services that operates across the northeastern United States. NFD

does substantial business in New York City, and frequently advertises its products and services

across television stations, the internet, and other media.

2. Over the past several years, the Department became aware of NFD’s prevalence

in the five boroughs because NFD’s treatment of New York City consumers prompted a litany of

complaints to DCWP and other entities. Indeed, NFD appears in the top five HICs consumers

complained about to DCWP in 2019, 2020, 2022, 2023, and thus far in 2024. In response to

these complaints, DCWP initiated an investigation into NFD’s business practices, and found that

NFD consistently violates the laws and rules of the City of New York governing HICs, including

the Consumer Protection Law (“CPL”).

3. To attract customers, NFD regularly misleads consumers about the speed and

quality of its available products and services. And when consumers attempt to assert their legal

right to cancel a recently signed contract, NFD frustrates their efforts to do so. Consumers are

left with shoddy work and floors that took longer to install than originally promised, and that

often require replacement shortly after installation. Throughout this stressful and exploitative

process, NFD insists that its work meets industry standards and refuses to assist consumers.

These practices have led to a high degree of consumer dissatisfaction, as evidenced by the

number of complaints received by DCWP, as well as NFD’s approximate rating of 1.6 stars on

the consumer review website Yelp.

4. In addition to misleading consumers and performing substandard work, NFD

routinely violates legal requirements governing the content of advertisements in New York City.

NFD’s advertisements promise consumers enticing terms that are later qualified by fine print in a

manner inconsistent with New York City’s laws and rules. NFD aired commercials for its

services on New York City television stations and on social media which also failed to meet

basic requirements—such as displaying its HIC license number issued by DCWP.

5. The Department finds that NFD’s deceptive practices violate New York City

Administrative Code (“NYC Code”) §§ 20-393(2), 20-393(11) and Title 6 of the Rules of the

City of New York (the “Rules” or “RCNY”) §§ 5-06(b), 5-09(a), 2-221(h), 2-222(a), and 2-

222(k). By this proceeding, DCWP seeks civil penalties, restitution to harmed consumers, the

https://www.yelp.com/brands/national-floors-direct.

revocation or suspension of NFD’s license, and such other relief as authorized by section 2203(h)

of Chapter 64 of the New York City Charter (“Charter”), the NYC Code, and the Rules.

PARTIES

6. DCWP is a mayoral agency of the City of New York responsible for protecting

and enhancing the daily economic lives of New Yorkers to create thriving communities. DCWP

is charged with the protection and relief of the public from deceptive, unfair, and unconscionable

practices, and for the maintenance of standards of integrity, honesty, and fair dealing among

persons engaging in business activities requiring a license issued by the Department. Charter

section 2203(h) and Chapter 20 of the NYC Code authorize DCWP to enforce the laws and rules

governing HICs.

7. NFD is a corporation licensed to conduct business as an HIC in New York City

with addresses of 100 Messina Drive, Unit H, Braintree, MA 02184 and P.O. Box 5776, Queens,

NY 11105. NFD is currently licensed by DCWP under license number 1461664-DCA.

STATEMENT OF FACTS

I. NFD Makes Substantial Misrepresentations and False Promises to Secure

Consumer Business in New York City

8. NFD routinely misrepresents its services to entice consumers to contract with it.

Specifically, NFD overpromises how quickly it can begin work, and understates the extent of the

work needed to complete the contract. In fact, NFD has previously been accused of using

deceptive and unfair business practices to consumers’ detriment. In 2019, the Federal Trade

Commission (“FTC”) issued a Consent Order

based on its investigative finding that NFD

violated the Consumer Review Fairness Act of 2016 by including unlawful non-disparagement

clauses in its form contracts. The Consent Order resolved the violations because NFD agreed to

See https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3085-national-floors-direct-inc-matter.

cease its practice of using contractual language that barred its customers from posting negative

reviews online. Unfortunately, it seems the company may have simply swapped this deceptive

business practice for others, continuing to take advantage of, and harm, consumers.

a. NFD Overpromises How Quickly It Can Begin Work

9. In its advertisements and across its websites, NFD promises rapid installation to

secure consumer business, only to then unreasonably delay its performance—sometimes

rescheduling installation appointments as many as 10 times. NFD’s website prominently

features a “Free Next Day Flooring Installation” page which, along with other advertising,

promises next day installation of its products.

When a contract is executed, NFD promises

similarly near-immediate installation dates to secure consumer business. Subsequently, NFD

often fails to arrive for these scheduled appointments, and then provides consumers with a series

of implausible excuses for its consistent pattern of delays. To worsen matters, NFD even urges

consumers to select “emergency installation” to guarantee rapid service, only to delay

installation regardless of the “emergency” status—while waiving the cancellation rights of these

consumers, so when they are faced with the inevitable delay, they have no recourse.

10. Consumers are regularly frustrated, suffer financial harm, and ultimately end up

without the service they sought or are forced to spend more money than anticipated. The fact that

NFD refuses to refund deposits further harms consumers when NFD fails to perform its

contractual duties. Some specific examples of how this conduct and NFD’s false promises as to

timing has impacted consumers include:

a. After consumer Pauline Stewart contracted with NFD in 2020, it delayed

performance several times, once claiming an accident caused its inability to

arrive, and, on a later occasion, arriving with damaged equipment. Because of

the delays, the consumer ultimately used another company to perform the

work, and NFD refused to return the consumer’s deposit of $1,600.

https://www.nationalfloorsdirect.com/free-next-day-installation

b. NFD delayed installation appointments five times with consumer Forrest

Williams in 2020, providing the excuse that there were stock issues. When

Williams attempted to cancel the contract and requested a refund due to the

extreme delay, NFD refused.

c. In 2021, NFD rescheduled several installation appointments with consumer

Sheila Whitaker, providing excuses ranging from an emergency to a truck

breaking down, and then did not return to finish its work on a staircase and

carpet area for the consumer.

d. NFD missed two appointments with consumer Alyssa Picchini Schaffer

before performing a rushed and incomplete installation in 2023.

e. NFD not only missed several installation appointments with consumer Rosalie

Macaluso, but cancelled several as well, once claiming difficulty parking,

before performing an incomplete and flawed installation that damaged the

consumer’s home.

f. After consumer Rhonda Pitts contracted with NFD just this past year, in 2024,

NFD did not perform the agreed-upon installation, and has refused to refund

the $2,000 it collected from the consumer.

11. As evidenced by these unhappy consumers’ complaints, after enticing consumers

to accept its bids by promising rapid installation, NFD regularly fails to provide services on

agreed-upon dates. The regularity and frequency of this conduct suggests that NFD intentionally

deceives consumers to generate more business by misrepresenting the speed at which its services

will be provided. NFD causes further harm to consumers by refusing to return their deposits

after it fails to timely perform its contractual duties.

b. NFD Understates the Work Needed to Perform Its Contracts

12. In addition to delaying installation, NFD often misrepresents the full extent of

work that is required to complete the consumer’s desired project. NFD salespersons

misrepresent the necessity of preliminary steps, such as subfloor removal, required to complete

an installation. When soliciting contracts with consumers, NFD’s salespersons frequently assure

consumers that no additional work will be required to install the new floors. However, once the

contract is signed and NFD’s contractors arrive for installation, they state that additional work is

required for them to be able to install the floors—both delaying the process and adding

additional costs for the consumer.

13. After informing the consumers of the required add-ons, NFD then mandates that

consumers pay an additional sum of money beyond what was previously agreed upon to receive

what they already purchased. Sometimes, the consumers object to this bait-and-switch and

demand a refund of their deposit. But NFD increases the pressure on those consumers by

refusing to refund the deposit or to do the agreed-upon work unless the consumers agree to the

additional charges, leaving the consumers in the terrible position of losing the money they

already paid NFD. Some of the consumers whom NFD has placed in these unenviable situations

include:

a. Consumer Danny Vega, to whom an NFD salesperson promised that NFD

could lay a new floor over the existing floor to induce Vega to contract with it,

but when the installer arrived, he said he could not install the new floor

without first ripping out the old floor at an additional cost;

b. Consumer Nora De Rosa, who was required by NFD to pay an additional

$900 for “leveling” when she had her floor installed;

c. Consumer Jalil Torres, to whom an NFD salesperson represented that an

uneven subfloor would not prevent a successful floor installation, only to sign

the contract, and then have the installer inform him it was his responsibility to

fix the subfloor prior to the installation. When Torres refused to take on this

new undisclosed obligation, NFD refused to refund Torres’s initial cash

deposit;

d. Consumer Trina Caver, with whom NFD contracted for a floor installation

without providing any flags at the time of contract but was then told by the

NFD installers that she must pay an additional $900 for the floor to be leveled.

14. As with NFD’s other misleading business practices, a consistent pattern of

deception emerges in its regular failure to disclose additional costs to consumers at the time of

contract; NFD systemically makes unrealistic promises to consumers with respect to the ease

with which its products can be installed, and the extent of preliminary work necessary for the job

to be done. In each case, NFD’s misrepresentations help it to secure the consumer’s business

before the consumer is left disappointed by delays or is forced to pay more than agreed.

II. NFD Fails to Perform Work in a Skillful and Competent Manner

15. Even when consumers are not deceived into utilizing NFD’s services, NFD’s

conduct still violates the law because it often fails to perform its work in a skillful and competent

manner, leaving behind damage and improperly installed products that consumers must fix at

their own expense. In many instances, after performing substandard work, NFD exacerbates the

harm to consumers by refusing to remedy the situation and forcing consumers to spend large

sums of money to repair the damage done to their homes. Below are some concerning examples

of NFD’s failure to perform HIC work in a skillful and competent manner:

a. NFD installed a carpet for consumer Alyssa Picchini Schaffer that needed to

be replaced again shortly after installation because the binding almost

immediately began to unravel. Unable to afford another company, the

consumer attempted to sew the carpet by hand as a temporary solution.

b. NFD installed floors for consumer Cheryldine Rodriguez that lacked a

protective layer, which NFD had agreed to install. The installers instead

placed the new floor directly over the old floor, leading to air bubbles and

gaps appearing in the floor over the following months.

c. Consumer Linda Parrish had NFD install vinyl floor planks that began to

separate shortly after installation. NFD has refused to correct the problem.

d. Consumer Rachel Shore’s floor, which was installed by NFD, needed to be

replaced after just six months because portions were peeling off, missing

covering, and were of uneven height. NFD has refused to provide a refund.

16. In each case, NFD did not perform its work in a skillful and competent manner.

In many cases, consumers had to engage outside companies to fix the damage caused by NFD or

choose to be left with damaged floors that they lack the means to repair. Even when the

unskilled work was not immediately apparent, the subsequent short lifespan of the floors

installed by NFD suggests consistently questionable level of skill and competency at the time of

installation.

III. NFD Fails to Adequately Disclose Conditions or Limitations on its Offers for Free

Services

17. A review of NFD’s website (https://www.nationalfloorsdirect.com) revealed that

NFD advertised several offers of “free” services without disclosing the conditions it places on

those offers, as is required by law. Specifically,

a. The website page offering “The Guaranteed Lowest Price or It’s Free”

did

not display limitations in sufficient proximity to that offer. Furthermore, these

promises were made on the website without any indication of whether labor,

material, repair, or replacement is included by this statement, and the only

limitations disclosed at all could only be found in a small font at the very

bottom of the page.

b. The website page offering “Free Next Day Flooring Installation”

likewise did

not contain sufficient limitations in proximity to the offer. Furthermore, this

free next-day installation promise is then directly contradicted by the “Order

Terms & Conditions” agreement NFD provides to the consumer at the time of

purchase (but not easily accessible from the webpage), which outlines

limitations on the free next-day installation offer, including conditions under

which NFD may delay installation, nullifying the “next day” claim.

c. NFD’s main home page, and the page offering “Free Flooring Services,”

both offered free furniture moving without disclosing any conditions or

limitations in proximity to that offer. This free furniture moving language

was then directly contradicted by a “Furniture & Appliance & Plumbing

Terms & Conditions” agreement NFD provides to the consumer at the time of

purchase—but again, not accessible from the webpages. This document—

which, again, is only provided to the consumer at the time they transact with

NFD—outlines multiple limitations on the free furniture moving offer,

including circumstances under which furniture will not be moved by NFD at

all, and imposes several conditions under which the consumer would in fact

be required to pay additional fees for furniture moving.

https://www.nationalfloorsdirect.com/low-price-guarantee-save-15-or-its-free (from July 7, 2023 to July 2, 2024).

See Ex. A (captured on July 1, 2024).

https://www.nationalfloorsdirect.com/free-next-day-installation (from July 7, 2023 to July 2, 2024). See Ex. B

(captured on July 1, 2024).

https://www.nationalfloorsdirect.com/free-services (from August 17, 2023 to July 5, 2024). See Ex. C (captured on

July 3, 2024).

d. NFD’s main home page

also offered “free standard stair work,” which is

again offered on the “Free Flooring Services” webpage. This offer of free

work on stairs appeared to apply to all carpet installation on stairs, without

any limitations or conditions on the offer on either page. Notably, NFD does

not define what constitutes “free standard stair work” anywhere, and

eventually presents consumers with contracts specifying additional and less

favorable terms, such as its Carpet Runner & Binding Customization Terms &

Conditions document.

18. As with its other problematic conduct, NFD entices consumers with appealing

promises of free services while failing to disclose the limitations, terms and conditions that often

substantially modify the otherwise tempting offer. In doing so, NFD misleads consumers about

the actual cost of its products and services. Consumers are directly harmed by these misleading

advertisements by believing they are contracting for a specific free service, only to be charged

for it after the fact.

19. NFD consistently obscures conditions and limitations on its offers for free

services, if it discloses such conditions and limitations at all. This conduct is in direct violation of

the Rules and misleads consumers about the true value of the deals being offered to them. As a

result, consumers are misled into purchasing products and services that are less likely to meet

their needs and which end up costing more, resulting in consumers being charged additional

amounts when they believed that they were receiving a service for free.

IV. NFD Fails to Adequately Disclose Additional Installation Charges in its

Advertisements

20. Continuing in its pattern of enticing consumers to contract with it only to pull a

bait and switch on the service requirements and costs, on its “Current Offers” website page

NFD advertised “60% OFF ON THE SPOT INCLUDING FULL INSTALLATION” without

https://www.nationalfloorsdirect.com/ (from July 7, 2023 to July 5, 2024). See Ex. D (captured on July 3, 2024).

https://www.nationalfloorsdirect.com/current-offers (from July 7, 2023 to July 12, 2024). See Ex. E (captured on

July 11, 2024).

disclosing any limitations in proximity to the offer. The same web page then listed several

limitations in a small font at the very bottom of the page.

21. NFD failed to clearly and conspicuously state that removal and disposal of

existing flooring and floor preparation often carry an additional cost. This practice misled

consumers into believing that installation was included in the original contract price or quote,

before NFD then informed them that they require more than “basic installation” and, therefore,

additional fees must be paid.

V. NFD Prevents Consumers from Cancelling Their Contracts Within the Permitted

Three-Day Cancellation Period

22. NFD’s unlawful conduct extends beyond its myriad ways of enticing customers in

with too-good-to-be-true promises only to then change the terms; NFD also interferes with

consumers’ right to cancel contracts within the lawful three-day period: Consumers who attempt

to cancel their contracts with NFD within the legally mandated three-day cancellation period

often find themselves being provided with endless excuses and unable to cancel their contract, or

NFD provides those consumers with incorrect information as to their cancellation rights under

the law.

23. At least two consumers who complained to the Department reported having been

prevented from cancelling their contracts with NFD during the permitted three-day window.

NFD improperly prevented one consumer from communicating her notice of cancellation and

simply refused to honor another’s notice. Specifically,

a) NFD ignored consumer Pauline Stewart’s efforts to contact the business via

phone to express Stewart’s desire to cancel the contract; instead, NFD failed

to answer or return the calls during the three-day cancellation period. Stewart

made $1,600 in payments under her NFD contract and was unable to get a

refund.

b) NFD falsely informed consumer Ruth Charles that Charles had only 24 hours

within which to cancel when she attempted to cancel the contract via phone

during the second day of the three-day period. Charles had made a $5000

deposit and was unable to obtain a refund.

24. By engaging in these practices, NFD deprived these consumers of their lawful

right to cancel their contracts within a three-day period. In doing so, NFD unjustly pocketed

money that the consumers had every right to get refunded. This conduct again demonstrates that

NFD regularly flouts the law to make a profit.

VI. NFD Has Failed to Include Its License Number in Its Advertisements

25. NFD advertises on New York City television stations so frequently that

consumers may see a commercial for NFD’s services multiple times during one program or

sporting event. In addition to airing in the five boroughs, most of these television advertisements

also appear on NFD’s website and are posted to social media sites such as YouTube that are

readily accessible by the New York City public.

26. Troublingly, NFD has not consistently included its New York City HIC license

number in the advertisements it broadcasts in New York City, as is required by the Rules.

Indeed, NFD’s HIC license number issued by DCWP did not appear anywhere on its website.

27. By failing to include its license number in its advertisements, NFD frustrates the

intent of the licensing scheme—which is to ensure that consumers know who the appropriate

regulatory agency is for reporting concerns or problems with a business or service.

VIOLATIONS

COUNT ONE

Engaging in substantial misrepresentations or false promises in the solicitation or procurement

of a home improvement contract in violation of NYC Code § 20-393(2)

At least 10 counts

28. NYC Code § 20-393(2) prohibits “[m]aking any substantial misrepresentation in

the solicitation or procurement of a home improvement contract, or making any false promise of

character likely to influence, persuade or induce” when dealing with consumers.

29. Respondent violated NYC Code § 20-393(2) by (i) promising rapid installation to

entice consumers to contract with it, and then excessively delaying its performance beyond

agreed-upon dates, (ii) encouraging consumers to request emergency installation in order to

receive immediate installation, which requires the consumer waive their right to cancel, before

then delaying installation anyway, and (iii) frequently misrepresenting to consumers the full

extent of the work required to complete the desired services in order to entice a consumer to sign

a contract, only to then require consumers to pay an additional sum of money, beyond what was

agreed, to receive what the consumer had already purchased.

30. Respondent violated NYC Code § 20-393(2) at least ten times. On this count,

Petitioner seeks civil penalties of $750 per violation. See 6 RCNY § 6-29.

COUNT TWO

Failing to perform work in a skillful and competent manner in violation of NYC Code § 20-

393(11)

At least four counts

31. NYC Code § 20-393(11) prohibits “[f]ailing to perform work under a home

improvement contract in a skillful and competent manner.”

32. Respondent violated NYC Code § 20-393(11) at least four times by failing to

perform its work in a skillful and competent manner and, in so doing, leaving behind damage and

improperly installed products for consumers to have to fix and/or pay an additional amount to

have fixed.

33. On this count, Petitioner seeks civil penalties of $750 per violation. See 6 RCNY

§ 6-29.

COUNT THREE

Failing to disclose conditions on offers for free services and consumer goods in violation of 6

RCNY § 5-06(b)

At least 2,096 counts

34. 6 RCNY § 5-06(b) requires that a “seller who imposes a condition on a free offer

must describe the condition clearly and conspicuously. The description of every condition on a

free offer must be placed near the word ‘free.’ An asterisk or other symbol near the word ‘free,’

which refers the customer to a footnote containing conditions, does not satisfy this section. This

condition must be in print at least half as large as the print used for the word ‘free.’”

35. DCWP promulgated 6 RCNY § 5-06(b) under its CPL rulemaking powers to

“defin[e] specific deceptive and unconscionable trade practices.” NYC Code § 20-702.

36. The CPL’s penalty provisions apply to violations of rules DCWP promulgates

under the CPL. NYC Code § 20-703(a).

37. “Each individual statement, description or other representation or omission that

constitutes a deceptive trade practice shall give rise to a distinct and independent violation.”

NYC Code § 20-703(b).

38. “Each day on which an individual statement, description or other representation or

omission that constitutes a deceptive trade practice is distributed, broadcast, posted, published, or

otherwise exposed to the public shall give rise to a single separate violation.” NYC Code § 20-

703(c).

39. Respondent violated 6 RCNY § 5-06(b) at least 2,096 times by including several

offers of “free” services and consumer goods in its advertisements without disclosing the

conditions it places on those offers. By failing to list any limitations or conditions on the offers

for free services or goods, NFD misled and deceived consumers into believing goods and

services are free when they were not. NFD violated this rule on its:

a. Guaranteed Lowest Price or Free page – from at least July 7, 2023 to July 2,

2024 (361 days);

b. Free Next-Day page – from at least July 7, 2023 to July 2, 2024 (361 days);

c. Home website – from at least July 7, 2023 to July 5, 2024 (364 days and 728

violations); and

d. Free Flooring Services page – from at least August 17, 2023 to July 5, 2024

(323 days and 646 violations).

40. On this count, Petitioner seeks civil penalties of $525 per violation.

COUNT FOUR

Failing to disclose limitations on installation offers in violation of 6 RCNY § 5-09(a)

At least 371 counts

41. 6 RCNY § 5-09(a) specifies that “[s]ellers offering consumer goods or services in

print advertising and promotional literature must disclose clearly and conspicuously all material

exclusions, reservations, limitations, modifications or conditions. A disclosure made in print at

least one-third as large as the largest print used in the advertisement or promotional literature

satisfies this section.”

42. DCWP promulgated 6 RCNY § 5-09(a) under its CPL rulemaking powers to

“defin[e] specific deceptive and unconscionable trade practices.” NYC Code § 20-702.

43. “Each individual statement, description or other representation or omission that

constitutes a deceptive trade practice shall give rise to a distinct and independent violation.”

NYC Code § 20-703(b).

44. “Each day on which an individual statement, description or other representation or

omission that constitutes a deceptive trade practice is distributed, broadcast, posted, published, or

otherwise exposed to the public shall give rise to a single separate violation.” NYC Code § 20-

703(c).

45. Respondent violated 6 RCNY § 5-09(a) at least 371 times by failing to include

applicable limitations on its advertisements promising full installation. NFD violated this rule by

making statements on its Current Offers page without including any disclosures – from at least

July 7, 2023 to July 12, 2024 (371 days).

46. On this count, Petitioner seeks civil penalties of $525 per violation. See 6 RCNY

§ 6-47.

COUNT FIVE

Failing to honor cancellation of contracts in violation of 6 RCNY § 2-221(h)

At least two counts

47. 6 RCNY § 2-221(h) states that a “contractor shall not fail or refuse to honor any

valid notice of cancellation by the buyer and within ten business days after the receipt of such

notice, the contractor shall (1) refund all payments made under the contract; (2) cancel and return

any negotiable instrument executed by the buyer in connection with the contract; (3) take any

action necessary or appropriate to terminate promptly any security interest created in the

transaction; and (4) within ten business days of receipt of the buyer's notice of cancellation the

contractor shall notify the buyer whether the contractor intends to repossess or to abandon any

shipped or delivered materials.”

48. Respondent violated 6 RCNY § 2-221(h) at least two times by preventing

consumers from exercising their right to cancel their contracts.

49. On this count, Petitioner seeks civil penalties of $500 per violation. See 6 RCNY

§ 6-29.

COUNT SIX

Failing to include license number on advertisements in violation of 6 RCNY § 2-222(a)

At least seven counts

50. 6 RCNY § 2-222(a) mandates that “[a]ll advertising and sales literature must

contain the license number of the contractor.”

51. Respondent violated 6 RCNY § 2-222(a) by leaving its New York City HIC

license number out of its advertisements, including those on television, YouTube, and its

website. NFD violated this rule on:

a. The NFD Website – from at least July 7, 2023 to May 14, 2024; and

b. Six television advertisements that were available as YouTube videos on

National Floor Direct’s channel.

52. On this count, Petitioner seeks civil penalties of $500 per violation. See 6 RCNY

§ 6-29.

RELIEF SOUGHT

WHEREFORE, the Department respectfully requests that OATH issue a Report and

Recommendation pursuant to NYC Charter § 2203(h)(1) recommending the following:

I. Revoking or suspending NFD’s license to do business as an HIC, pursuant to

NYC Code §§ 20-101, 20-104(a), 20-393(2), 20-393(11);

II. Ordering that NFD pay civil penalties for all HIC violations, including: (a) $750

for each misrepresentation or false promise in violation of NYC Code § 20-

393(2); (b) $750 for each failure to perform work in a skillful and competent

manner in violation of NYC Code § 20-393(11); (c) $525 for each failure to

describe conditions on free services offers in violation of 6 RCNY § 5-06(b); (d)

$525 for each failure to describe conditions on installation offers in violation of 6

RCNY § 5-09(a); (e) $500 for each failure to allow cancellation of a contract

within three days of its creation in violation of 6 RCNY § 2-221(h); and (f) $500

https://www.youtube.com/@nationalfloorsdirect9057/videos

for each failure to include NFD’s license number in advertisements in violation of

6 RCNY § 2-222(a);

III. Ordering Respondent to pay restitution to known consumers in the amount of at

least $9,500.00, and to pay restitution to all other affected consumers via a fund

for restitution for additional aggrieved consumers, whether named or unnamed, in

an amount to be determined at trial, pursuant to NYC Code § 20-703(i)(2); and

IV. Granting such other and further relief as may be deemed just and proper.

Dated: August 12, 2024

New York, New York

For: Vilda Vera Mayuga

Commissioner

New York City Department of Consumer and

Worker Protection

By: ____________________________

Aram Boghosian, Esq.

Staff Counsel

42 Broadway

New York, NY 10004

[email protected]

(212) 968-6738

To: National Floors Direct, Inc.

100 Messina Drive, Unit H

Braintree, MA 02184

02184

P.O. Box 5776

Queens, NY 11105