Send this puppy certified to Mr. Gershfield’s attention:

(Today’s date)

(Your name)
(Your address)
(Your phone number)
(Your email address)

Cash Today Limited
Northway House
1379 High Road
London, N20 9LP
Attn: Aaron Gershfield

Dear Mr. Gershfield,

As of today, (today’s date), I do not authorize Cash Today Limited, nor any representative, parent company, affiliate, or subsidiary of Cash Today Limited, to withdraw any funds from the checking account under the name of (your name), account number (your account number), located at (your bank name).

Your company is in violation of (Your state’s code title or statute)

(insert your state’s text here)

Your claim that the contract that I signed is only governed by the law of the state in which your company resides is unsubstantiated. There is specific Federal case law that refutes your claim. Your company solicited, accepted and transacted business with a citizen of The State of New Jersey, thus you are subject to the laws of this state including the usury and licensing laws.

“Dot Com repeatedly and consciously chose to process Pennsylvania residents’ applications and to assign them passwords. Dot Com knew that the result of these contracts would be the transmission of electronic messages into Pennsylvania. The transmission of these files was entirely within its control. Dot Com cannot maintain that these contracts are “fortuitous” or “coincidental” within the meaning of World-Wide Volkswagen. When a defendant makes a conscious choice to conduct business with the residents of a forum state, “it has clear notice that it is subject to suit there.” World-Wide Volkswagen, 444 U.S. at 297, 100 S. Ct. at 567 Dot Com was under no obligation to sell its services to Pennsylvania residents. It freely chose to do so, presumably in order to profit from those transactions. If a corporation determines that the risk of being subject to personal jurisdiction in a particular forum is too great, it can choose to sever its connection to the state. Id. If Dot Com had not wanted to be amenable to jurisdiction in Pennsylvania, the solution would have been simple–it could have chosen not to sell its services to Pennsylvania residents.” (W. D. Pa. 1997)

After reviewing the laws of the State of Delaware, where Cash Today Ltd. is incorporated as Lotus Leads, Inc. it is apparent that your company is operating in violation of the laws in the State of Delaware as well.

Title 5 Banking
2207 Exemption of Licensed Lenders
Formerly Regulation No.: 5.2202(b).0007
Effective Date: June 11, 2001
1.0 Purpose
1.1 This regulation governs the procedures and requirements for exemptions pursuant to 5 Del. C. §2202(b).
2.0 Definitions
For the purpose of this regulation, the following definitions apply:
“Person” means an individual, corporation, partnership, or any other business entity or group or combination of individuals however organized.
“Statute” means 5 Del.C. Ch. 22.
“Commissioner” means the State Bank Commissioner.
“Existing exemption” means an exemption from the Statute granted before the effective date of this regulation.
“Exempt person” means a person that has been granted an exemption from the Statute pursuant to 5 Del.C. §2202(b) and this regulation.
3.0 Applicability
3.1 This regulation and the Statute apply only to persons engaged in consumer credit transactions, including but not limited to mortgage lending secured by one to four family residential, owner occupied property located in Delaware and intended for personal, family or household purposes.
3.2 This regulation and the Statute’s licensing requirements do not apply to:
3.2.1 Any person who makes 5 or less loans within any 12 month period;
3.2.2 Any banking organization, as defined by 5 Del.C. §101;
3.2.3 Any federal credit union;
3.2.4 Any insurance company;
3.2.5 Any person if and to the extent that such person is lending money in accordance with, and as authorized by, any other applicable law of the State of Delaware; and
3.2.6 Any person if and to the extent that such person is lending money in accordance with, and as authorized by, any applicable law of the United States of America.
3.3 A person shall not be deemed to be transacting the business of lending money within the meaning of 5 Del.C. §2202 and shall not be subject to this regulation or the licensing requirements of the Statute solely because the person is a participating merchant as the term is used in the Statute.
4.0 Qualifications
4.1 An exempt person shall at all times maintain such financial responsibility, experience, character, and general fitness as to command the confidence of the community and to warrant belief that its business will be operated honestly, fairly, and efficiently within the purposes of the Statute.
5.0 Grant of Exemptions
5.1 Upon finding the qualifications of Section 4.0 of this regulation have been met, theCommissioner may grant an exemption to:
5.1.1 Any person whose lending operations are regularly examined, either separately or as part of an examination of an affiliated company, by an agency of the State of Delaware or the United States of America, if that agency regulates banks.
5.1.2 Any person exempt from federal taxation under 26 USC §501(c)(3), as amended.
5.1.3 Any other person whom the Commissioner determines to be inappropriate to include within the coverage of the Statute, including any person whose operations and financial condition are regularly examined by any other agency of the State of Delaware, the United States of America, or another state.
6.0 Nature of Exemption
6.1 An exemption granted pursuant to Section 5.1.1 and 5.1.2 of this regulation shall include at minimum an exemption from the licensing and surety bond requirements of the Statute. The Commissioner may also grant an exemption from any other provision of the Statute that the Commissioner deems appropriate.
6.2 The Commissioner shall determine the nature and extent of any exemption granted pursuant to Section 5.1.3 of this regulation.
7.0 Application of the Statute to Exempt Persons
7.1 Unless the Commissioner specifies otherwise, Subchapter II and Subchapter III of the Statute shall apply to all exempt persons as if they were licensees.
8.0 Expiration
8.1 Except as otherwise provided in this regulation, exemptions shall expire one year from the date granted.
9.0 Application and Renewals
9.1 Any person who desires an exemption from the Statute shall apply to the Commissioner on such forms as the Commissioner may designate.
9.2 An exempt person shall apply for a renewal of the exemption at least 30 days before the expiration of the exemption on such forms as the Commissioner may designate.
10.0 Changed Information
10.1 Exempt persons shall notify the Commissioner within 30 days of any changes in the information contained in the application for its exemption or the renewal thereof.
11.0 Extensions on License Applications
11.1 An exempt person who applies for a license under the Statute before the expiration or revocation of its exemption shall have the exemption automatically extended until a final decision is made on the license application.
12.0 Existing Exemptions
12.1 Existing exemptions shall expire on July 1, 2002.
12.2 Persons with existing exemptions may apply for a renewal of their exemption pursuantto this regulation at any time before June 30, 2002.
12.3 The provisions of all existing exemptions shall remain in effect until the exemption expires pursuant to subsection 12.1 of this regulation.
13.0 Suspension or Revocation
13.1 The Commissioner may suspend or revoke any exemption upon a finding that:
13.1.1 The exempt person has violated any statute, judicial order, administrative order, rule, regulation or other law of the State of Delaware, any other state or the United States of America;
13.1.2 Any fact or condition exists which if it had existed at the time of the application or renewal for the exemption, would have warranted the Commissioner in refusing to issue the exemption or its renewal;
13.1.3 The exempt person has engaged in unfair or deceptive business activities or practices in connection with extensions of credit to consumers. Unfair or deceptive activities and practices include, but are not limited to, the use of tactics which mislead the consumer, misrepresent the consumer transaction or any part thereof, or otherwise create false expectations on the part of the consumer; or
13.1.4 The exempt person does not meet the qualifications specified in Section 4 of this regulation.
13.2 No exemption shall be suspended or revoked except in accordance with the procedures for suspending or revoking a license that are specified in the Statute and in the Delaware Administrative Procedures Act, 29 Del.C. Ch. 101.
13.3 No suspension or revocation of an exemption shall impair or affect the obligation of any preexisting lawful contract between the exempt person and any other person.
14.0 Exemption Denials
14.1 If the Commissioner denies an exemption or the renewal of an exemption, the Commissioner shall promptly send the applicant or exempt person a written order to that effect which states the grounds for the denial. The applicant or exempt person may request that the Commissioner hold a hearing to reconsider that denial, in accordance with the procedures for requesting a hearing on the denial of a license application that are specified in the Statute and in the Delaware Administrative Procedures Act, 29 Del.C. Ch. 101. The Commissioner may extend the term of any exemption whose renewal has been denied until the final resolution of that hearing.
15.0 Fees
15.1 The investigation fee for an application for an exemption shall be $250.00.
15.2 The investigation fee for renewal of an exemption shall be $100.00. A renewal application must be submitted more than 30 days in advance of the exemption’s expiration.
15.3 A renewal application submitted less than 30 days in advance of the exemption’s expiration shall be treated as a new application for an exemption and shall be subject to the investigation fee of $250.
See 4 DE Reg 1993 (6/1/01)

I have reviewed the laws of the State of Nevada where Cash Today Ltd. is incorporated as Leads Global Inc. and low and behold your company is in violation of these laws as well.
2. Subject to the affirmative defense set forth in subsection 3,
in addition to any other remedy or penalty, the customer may
bring a civil action against a person pursuant to subsection 1 to
recover an additional amount, as statutory damages, which is
equal to $1,000 for each violation if the person knowingly:
(a) Operates a check-cashing service, deferred deposit loan
service, short-term loan service or title loan service without a
license, in violation of section 29 of this act;
(b) Fails to include in a loan agreement a disclosure of the
right of the customer to rescind the loan, in violation of section 31
of this act;

Sec. 73.5. In addition to any other remedy or penalty, the
Commissioner may impose an administrative fine of not more
than $10,000 upon a person who, without a license, conducts any
business or activity for which a license is required pursuant to the
provisions of this chapter.

Sec. 74. 1. Subject to the affirmative defense set forth in
subsection 3, in addition to any other remedy or penalty, if a
person violates any provision of section 29, 31 to 47, inclusive, 49,
50, 57 or 58 of this act or any regulation adopted pursuant thereto,
the customer may bring a civil action against the person for any or
all of the following relief:
(a) Actual and consequential damages;
(b) Punitive damages, which are subject to the provisions of
NRS 42.005;
(c) Reasonable attorney’s fees and costs; and
(d) Any other legal or equitable relief that the court deems
appropriate.

Sec. 29. 1. A person, including, without limitation, a
person licensed pursuant to chapter 675 of NRS, shall not operate
a check-cashing service, deferred deposit loan service, short-term
loan service or title loan service unless the person is licensed with
the Commissioner pursuant to the provisions of this chapter.
2. A person must have a license regardless of the location or
method that the person uses to operate such a service, including,
without limitation, at a kiosk, through the Internet, through any
telephone, facsimile machine or other telecommunication device
or through any other machine, network, system, device or means,
except that the person shall not operate such a service through
any automated loan machine in violation of the provisions of
subsection 3.
3. A person shall not operate a deferred deposit loan service
or short-term loan service through any automated loan machine,
and the Commissioner shall not issue a license that authorizes the
licensee to conduct business through any automated loan
machine

Sec. 31. 1. Before making any loan to a customer, a
licensee shall provide to the customer a written loan agreement
which may be kept by the customer and which must be written in:
(a) English, if the transaction is conducted in English; or
(b) Spanish, if the transaction is conducted in Spanish.
2. The loan agreement must include, without limitation, the
following information:
(a) The name and address of the licensee and the customer;
(b) The nature of the security for the loan, if any;
(c) The date and amount of the loan, amount financed, annual
percentage rate, finance charge, total of payments, payment
schedule and a description and the amount of every fee charged,
regardless of the name given to the fee and regardless of whether
the fee is required to be included in the finance charge under the
Truth in Lending Act and Regulation Z;
(d) A disclosure of the right of the customer to rescind a loan
pursuant to the provisions of this chapter;
(e) A disclosure of the right of the customer to pay his loan in
full or in part with no additional charge pursuant to the provisions
of this chapter;
(f) A disclosure stating that, if the customer defaults on the
loan, the customer has the opportunity within 30 days of the date
of default to enter into a repayment plan with a term of at least 90
days, and that the licensee must offer the repayment plan to the
customer before the licensee commences any civil action or
process of alternative dispute resolution or, if appropriate for the
loan, before the licensee repossesses a vehicle; and
(g) Any other disclosures required under the Truth in Lending
Act and Regulation Z or under any other applicable federal or
state statute or regulation.

Sec. 43. 1. Except as otherwise provided in subsection 2, if
a customer agrees to establish or extend the period for the
repayment, renewal, refinancing or consolidation of an
outstanding loan by using the proceeds of a new deferred deposit
loan or short-term loan to pay the balance of the outstanding loan,
the licensee shall not establish or extend such a period beyond 60
days after the expiration of the initial loan period.
2. This section does not apply to a deferred deposit loan or
short-term loan if the licensee:
(a) Makes the deferred deposit loan or short-term loan to a
customer pursuant to a loan agreement which, under its original
terms:
(1) Charges an annual percentage rate of less than 200
percent;
(2) Requires the customer to make a payment on the loan at
least once every 30 days;
(3) Requires the loan to be paid in full in not less than 150
days; and
(4) Provides that interest does not accrue on the loan at the
annual percentage rate set forth in the loan agreement after the
date of maturity of the loan;
(b) Performs a credit check of the customer with a major
consumer reporting agency before making the loan;
(c) Reports information relating to the loan experience of the
customer to a major consumer reporting agency;
(d) Gives the customer the right to rescind the deferred deposit
loan or short-term loan within 5 days after the loan is made
without charging the customer any fee for rescinding the loan;
(e) Participates in good faith with a counseling agency that is:
(1) Accredited by the Council on Accreditation for Services
for Families and Children, Inc., or its successor organization; and
(2) A member of the National Foundation for Credit
Counseling, or its successor organization; and
(f) Does not commence any civil action or process of
alternative dispute resolution on a defaulted loan or any extension
or repayment plan thereof.

Sec. 46. In addition to any other provision in this chapter,
each time a customer makes a payment to a licensee, the licensee
shall give to the customer a receipt with the following information:
1. The name and address of the licensee;
2. The identification number assigned to the loan agreement
or other information that identifies the loan;
3. The date of the payment;
4. The amount paid;
5. The balance due on the loan or, when the customer makes
a final payment, a statement that the loan is paid in full; and
6. If more than one loan made by the licensee to the customer
was outstanding at the time the payment was made, a statement
indicating to which loan the payment was applied.

Sec. 49. 1. Except as otherwise provided in section 50 of
this act, each application for a license pursuant to the provisions
of this chapter must be accompanied by a surety bond payable to
the State of Nevada in the amount of $50,000 plus an additional
$5,000 for each branch location at which the applicant proposes to
do business under the license. Thereafter, each licensee shall
maintain the surety bond so that the amount of the surety bond is
$50,000 plus an additional $5,000 for each branch location at
which the licensee does business under the license. The surety
bond required by this section is for the use and benefit of any
customer receiving the services of the licensee at any location at
which the licensee does business under the license.
2. The bond must be in a form satisfactory to the
Commissioner, issued by a bonding company authorized to do
business in this State and must secure the faithful performance of
the obligations of the licensee respecting the provision of the
services.
3. A licensee shall, within 10 days after the commencement of
any action or notice of entry of any judgment against him by any
creditor or claimant arising out of business regulated by this
chapter give notice thereof to the Commissioner by certified mail
with details sufficient to identify the action or judgment. The
surety shall, within 10 days after it pays any claim or judgment to
a creditor or claimant, give notice thereof to the Commissioner by
certified mail with details sufficient to identify the creditor or
claimant and the claim or judgment so paid.
4. Whenever the principal sum of the bond is reduced by
recoveries or payments thereon, the licensee shall furnish:
(a) A new or additional bond so that the total or aggregate
principal sum of the bonds equals the sum required pursuant to
subsection 1; or
(b) An endorsement, duly executed by the surety, reinstating
the bond to the required principal sum.
5. The liability of the surety on the bond to a creditor or
claimant is not affected by any misrepresentation, breach of
warranty, failure to pay a premium or other act or omission of the
licensee, or by any insolvency or bankruptcy of the licensee.
6. The liability of the surety continues as to all transactions
entered into in good faith by the creditors and claimants with the
agents of the licensee within 30 days after:
(a) The death of the licensee or the dissolution or liquidation
of his business; or
(b) The termination of the bond,
whichever event occurs first.
7. A licensee or his surety shall not cancel or alter a bond
except after notice to the Commissioner by certified mail. The
cancellation or alteration is not effective until 10 days after
receipt of the notice by the Commissioner. A cancellation or
alteration does not affect any liability incurred or accrued on the
bond before the expiration of the 30-day period designated in
subsection 6.
Sec. 50. 1. In lieu of any surety bond, or any portion of the
principal sum thereof as required pursuant to the provisions of
this chapter, a licensee may deposit with the State Treasurer or
with any bank, credit union or trust company authorized to do
business in this State as the licensee may select, with the approval
of the Commissioner:
(a) Interest-bearing stocks;
(b) Bills, bonds, notes, debentures or other obligations of the
United States or any agency or instrumentality thereof, or
guaranteed by the United States; or
(c) Any obligation of this State or any city, county, town,
township, school district or other instrumentality of this State or
guaranteed by this State,
in an aggregate amount of, based upon principal amount or
market value, whichever is lower, of not less than the amount of
the required surety bond or portion thereof.
2. The securities must be held to secure the same obligation
as would the surety bond, but the depositor may receive any
interest or dividends and, with the approval of the Commissioner,
substitute other suitable securities for those deposited.

Sec. 57. 1. A licensee shall not conduct the business of
making loans under any name, at any place or by any method,
including, without limitation, at a kiosk, through the Internet,
through any telephone, facsimile machine or other
telecommunication device or through any other machine, network,
system, device or means, except as permitted in the license or
branch license issued to the licensee.
2. A licensee must obtain the approval of the Commissioner
before using or changing a business name.
3. A licensee shall not:
(a) Use any business name which is identical or similar to a
business name used by another licensee under this chapter or
which may mislead or confuse the public.
(b) Use any printed forms which may mislead or confuse the
public.

2. Subject to the affirmative defense set forth in subsection 3,
in addition to any other remedy or penalty, the customer may
bring a civil action against a person pursuant to subsection 1 to
recover an additional amount, as statutory damages, which is
equal to $1,000 for each violation if the person knowingly:
(a) Operates a check-cashing service, deferred deposit loan
service, short-term loan service or title loan service without a
license, in violation of section 29 of this act;
(b) Fails to include in a loan agreement a disclosure of the
right of the customer to rescind the loan, in violation of section 31
of this act;
(c) Violates any provision of section 33 of this act;
(d) Accepts collateral or security for a deferred deposit loan, in
violation of section 35 of this act, except that a check or written
authorization for an electronic transfer of money shall not be
deemed to be collateral or security for a deferred deposit loan;
(e) Uses or threatens to use the criminal process in this State
or any other state to collect on a loan made to the customer, in
violation of section 36 of this act;
(f) Includes in any written agreement a promise by the
customer to hold the person harmless, a confession of judgment by
the customer or an assignment or order for the payment of wages
or other compensation due the customer, in violation of section 36
of this act;
(g) Violates any provision of section 44 of this act; or
(h) Violates any provision of section 45 of this act.
3. A person may not be held liable in any civil action brought
pursuant to this section if the person proves, by a preponderance
of evidence, that the violation:
(a) Was not intentional;
(b) Was technical in nature; and
(c) Resulted from a bona fide error, notwithstanding the
maintenance of procedures reasonably adapted to avoid any such
error.
4. For the purposes of subsection 3, a bona fide error
includes, without limitation, clerical errors, calculation errors,
computer malfunction and programming errors and printing
errors, except that an error of legal judgment with respect to the
person’s obligations under this chapter is not a bona fide error.

NRS 42.005 Exemplary and punitive damages: In general; limitations on amount of award; determination in subsequent proceeding.

1. Except as otherwise provided in NRS 42.007, in an action for the breach of an obligation not arising from contract, where it is proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud or malice, express or implied, the plaintiff, in addition to the compensatory damages, may recover damages for the sake of example and by way of punishing the defendant. Except as otherwise provided in this section or by specific statute, an award of exemplary or punitive damages made pursuant to this section may not exceed:

(a) Three times the amount of compensatory damages awarded to the plaintiff if the amount of compensatory damages is $100,000 or more; or

(b) Three hundred thousand dollars if the amount of compensatory damages awarded to the plaintiff is less than $100,000.

2. The limitations on the amount of an award of exemplary or punitive damages prescribed in subsection 1 do not apply to an action brought against:

(a) A manufacturer, distributor or seller of a defective product;

(b) An insurer who acts in bad faith regarding its obligations to provide insurance coverage;

(c) A person for violating a state or federal law prohibiting discriminatory housing practices, if the law provides for a remedy of exemplary or punitive damages in excess of the limitations prescribed in subsection 1;

(d) A person for damages or an injury caused by the emission, disposal or spilling of a toxic, radioactive or hazardous material or waste; or

(e) A person for defamation.

3. If punitive damages are claimed pursuant to this section, the trier of fact shall make a finding of whether such damages will be assessed. If such damages are to be assessed, a subsequent proceeding must be conducted before the same trier of fact to determine the amount of such damages to be assessed. The trier of fact shall make a finding of the amount to be assessed according to the provisions of this section. The findings required by this section, if made by a jury, must be made by special verdict along with any other required findings. The jury must not be instructed, or otherwise advised, of the limitations on the amount of an award of punitive damages prescribed in subsection 1.

4. Evidence of the financial condition of the defendant is not admissible for the purpose of determining the amount of punitive damages to be assessed until the commencement of the subsequent proceeding to determine the amount of exemplary or punitive damages to be assessed.

5. For the purposes of an action brought against an insurer who acts in bad faith regarding its obligations to provide insurance coverage, the definitions set forth in NRS 42.001 are not applicable and the corresponding provisions of the common law apply.

(Added to NRS by 1989, 486; A 1995, 2669)

As far as your assertion that I am bound by the laws of the United Kingdom, that would be acceptable if Cash Today Ltd. was following the laws of the United Kingdom themselves

The United Kingdom Consumer Credit Act of 1974 states:

“53 Duty to display information
Regulations may require a person who carries on a consumer credit business or consumer hire business, or a business in the course of which he provides credit to individuals secured on land (other than credit provided under an agreement which is an exempt agreement as a result of section 16(6C)), to display in the prescribed manner, at any premises where the business is carried on to which the public have access, prescribed information about the business.”

“20 Total charge for credit
(1) The Secretary of State shall make regulations containing such provisions as appear to him appropriate for determining the true cost to the debtor of the credit provided or to be provided under an actual or prospective consumer credit agreement (the “total charge for credit”), and regulations so made shall prescribe—
(a) what items are to be treated as entering into the total charge for credit, and how their amount is to be ascertained;
(b) the method of calculating the rate of the total charge for credit.
(2) Regulations under subsection (1) may provide for the whole or part of the amount payable by the debtor or his relative under any linked transaction to be included in the total charge for credit, whether or not the creditor is a party to the transaction or derives benefit from it.
60 Form and content of agreements
(1) The Secretary of State shall make regulations as to the form and content of documents embodying regulated agreements, and the regulations shall contain such provisions as appear to him appropriate with a view to ensuring that the debtor or hirer is made aware of—
(a) the rights and duties conferred or imposed on him by the agreement,
(b) the amount and rate of the total charge for credit (in the case of a consumer credit agreement),
(c) the protection and remedies available to him under this Act, and
(d) any other matters which, in the opinion of the Secretary of State, it is desirable for him to know about in connection with the agreement.
(2) Regulations under subsection (1) may in particular—
(a) require specified information to be included in the prescribed manner in documents, and other specified material to be excluded;
(b) contain requirements to ensure that specified information is clearly brought to the attention of the debtor or hirer, and that one part of a document is not given insufficient or excessive prominence compared with another.
63 Duty to supply copy of executed agreement
(1) If the unexecuted agreement is presented personally to the debtor or hirer for his signature, and on the occasion when he signs it the document becomes an executed agreement, a copy of the executed agreement, and of any other document referred to in it, must be there and then delivered to him.
(2) A copy of the executed agreement, and of any other document referred to in it, must be given to the debtor or hirer within the seven days following the making of the agreement unless—
(a) subsection (1) applies, or
(b) the unexecuted agreement was sent to the debtor or hirer for his signature and, on the occasion of his signing it, the document became an executed agreement.
(3) In the case of a cancellable agreement, a copy under subsection (2) must be sent by post.
(4) In the case of a credit-token agreement, a copy under subsection (2) need not be given within the seven days following the making of the agreement if it is given before or at the time when the credit-token is given to the debtor.
(5) A regulated agreement is not properly executed if the requirements of this section are not observed.
Amendments to the Act
2.—(1) The Act shall be amended as follows:
(2) In section 61 (signing of the agreement), in paragraph (b) of subsection (2) (unexecuted agreement to be sent to debtor or hirer by post for signature), for “by post” substitute “by an appropriate method”.
(3) In section 63(3) (duty to supply copy of executed agreement), for “by post” substitute “by an appropriate method”.
(4) In section 64 (duty to give notice of cancellation rights), for “by post”, in each place where it occurs, substitute “by an appropriate method”.
(5) For section 69(7) substitute—
Citation, commencement and interpretation
1.—(1) This Order may be cited as the Consumer Credit Act 1974 (Electronic Communications) Order 2004 and shall come into force on 31st December 2004.
(2) In this Order, the “Act” means the Consumer Credit Act 1974(b).
“(7) Whether or not it is actually received by him, a notice of cancellation sent to a person shall be deemed to be served on him—
(a) in the case of a notice sent by post, at the time of posting, and
(b) in the case of a notice transmitted in the form of an electronic communication in accordance with section 176A(1), at the time of the transmission.”.
(6) In section 176 (service of documents), in subsection (2) (permitted methods of service), for “by post” substitute “by an appropriate method”.
(7) After section 176 insert—
“176A Electronic transmission of documents
(1) A document is transmitted in accordance with this subsection if–
(a) the person to whom it is transmitted agrees that it may be delivered to him by being transmitted to a particular electronic address in a particular electronic form,
(b) it is transmitted to that address in that form, and
(c) the form in which the document is transmitted is such that any information in the document which is addressed to the person to whom the document is transmitted is capable of being stored for future reference for an appropriate period in a way which allows the information to be reproduced without change.
(2) A document transmitted in accordance with subsection (1) shall, unless the contrary is proved, be treated for the purposes of this Act, except section 69, as having been delivered on the working day immediately following the day on which it is transmitted.
(3) In this section, “electronic address” includes any number or address used for the purposes of receiving electronic communications.”.
(8) In section 189 (definitions), in subsection (1), insert the following at the appropriate places—
““appropriate method” means–
(a) post, or
(b) transmission in the form of an electronic communication in accordance with section 176A(1);””.
““electronic communication” means an electronic communication within the meaning of the Electronic Communications Act 2000 (c.7)””.
(9) In that subsection, in the definitions of the expressions “give” and “serve on” for “by post” substitute “by an appropriate method”.
Amendments to the Consumer Credit (Termination of Licences) Regulations 1976
3.—(1) The Consumer Credit (Termination of Licences) Regulations 1976(a) shall be amended as follows:
(2) In regulation 7, for “by post”, in each place where it occurs, substitute “by an appropriate method”

The OECD has issued guidelines for European businesses who conduct business across borders. Cash Today Ltd. has violated these guidelines.
RECOMMENDATION OF THE OECD COUNCIL CONCERNING
GUIDELINES FOR CONSUMER PROTECTION
IN THE CONTEXT OF ELECTRONIC COMMERCE

ANNEX
GUIDELINES
PART ONE
SCOPE
These Guidelines apply only to business-to-consumer electronic commerce and not to business to- business transactions.
PART TWO
GENERAL PRINCIPLES
I. TRANSPARENT AND EFFECTIVE PROTECTION
Consumers who participate in electronic commerce should be afforded transparent and effective
consumer protection that is not less than the level of protection afforded in other forms of commerce.
Governments, businesses, consumers, and their representatives should work together to achieve
such protection and determine what changes may be necessary to address the special
circumstances of electronic commerce.
II. FAIR BUSINESS, ADVERTISING AND MARKETING PRACTICES
Businesses engaged in electronic commerce should pay due regard to the interests of consumers
and act in accordance with fair business, advertising and marketing practices.
Businesses should not make any representation, or omission, or engage in any practice that is
likely to be deceptive, misleading, fraudulent or unfair.
Businesses selling, promoting or marketing goods or services to consumers should not engage in
practices that are likely to cause unreasonable risk of harm to consumers.
Whenever businesses make information available about themselves or the goods or services they
provide, they should present such information in a clear, conspicuous, accurate and easily
accessible manner.
Businesses should comply with any representations they make regarding policies or practices
relating to their transactions with consumers.
Businesses should take into account the global nature of electronic commerce and, wherever
possible, should consider the various regulatory characteristics of the markets they target.
Businesses should not exploit the special characteristics of electronic commerce to hide their true
identity or location, or to avoid compliance with consumer protection standards and/or
enforcement mechanisms.
Businesses should not use unfair contract terms.
Advertising and marketing should be clearly identifiable as such.
Advertising and marketing should identify the business on whose behalf the marketing or
advertising is being conducted where failure to do so would be deceptive.
Businesses should be able to substantiate any express or implied representations as long as the
representations are maintained, and for a reasonable time thereafter.
Businesses should develop and implement effective and easy-to-use procedures that allow
consumers to choose whether or not they wish to receive unsolicited commercial e-mail
messages.
Where consumers have indicated that they do not want to receive unsolicited commercial e-mail
messages, such choice should be respected.
In a number of countries, unsolicited commercial e-mail is subject to specific legal or selfregulatory
requirements.
Businesses should take special care in advertising or marketing that is targeted to children, the
elderly, the seriously ill, and others who may not have the capacity to fully understand the
information with which they are presented.
III. ONLINE DISCLOSURES
A. INFORMATION ABOUT THE BUSINESS
Businesses engaged in electronic commerce with consumers should provide accurate, clear and
easily accessible information about themselves sufficient to allow, at a minimum:
i) Identification of the business - including the legal name of the business and the name
under which the business trades; the principal geographic address for the business; email
address or other electronic means of contact, or telephone number; and, where
applicable, an address for registration purposes and any relevant government
registration or license numbers;
ii) Prompt, easy and effective consumer communication with the business;
iii) Appropriate and effective resolution of disputes;
iv) Service of legal process; and
v) Location of the business and its principals by law enforcement and regulatory officials
6
Where a business publicises its membership in any relevant self-regulatory scheme, business
association, dispute resolution organisation or other certification body, the business should
provide consumers with appropriate contact details and an easy method of verifying that
membership and of accessing the relevant codes and practices of the certification body.
B. INFORMATION ABOUT THE GOODS OR SERVICES
Businesses engaged in electronic commerce with consumers should provide accurate and easily
accessible information describing the goods or services offered; sufficient to enable consumers to make an
informed decision about whether to enter into the transaction and in a manner that makes it possible for
consumers to maintain an adequate record of such information.
C. INFORMATION ABOUT THE TRANSACTION
Businesses engaged in electronic commerce should provide sufficient information about the
terms, conditions and costs associated with a transaction to enable consumers to make an informed
decision about whether to enter into the transaction.
Such information should be clear, accurate, easily accessible, and provided in manner that gives
consumers an adequate opportunity for review before entering into the transaction.
Where more than one language is available to conduct a transaction, businesses should make
available in those same languages all information necessary for consumers to make an informed
decision about the transaction.
Businesses should provide consumers with a clear and full text of the relevant terms and
conditions of the transaction in a manner that makes it possible for consumers to access and
maintain an adequate record of such information.
Where applicable and appropriate given the transaction, such information should include the
following:
i) an itemisation of total costs collected and/or imposed by the business;
ii) notice of the existence of other routinely applicable costs to the consumer that are
not collected and/or imposed by the business;
iii) terms of delivery or performance;
iv) terms, conditions, and methods of payment;
v) restrictions, limitations or conditions of purchase, such as parental/guardian
approval requirements, geographic or time restrictions;
vi) instructions for proper use including safety and health care warnings;
vii) information relating to available after-sales service
viii) details of and conditions related to withdrawal, termination, return, exchange,
cancellation and/or refund policy information; and
ix) available warranties and guarantees.
All information that refers to costs should indicate the applicable currency.
IV. CONFIRMATION PROCESS
To avoid ambiguity concerning the consumer’s intent to make a purchase, the consumer should
be able, before concluding the purchase, to identify precisely the goods or services he or she wishes to
purchase; identify and correct any errors or modify the order; express an informed and deliberate consent
to the purchase; and retain a complete and accurate record of the transaction.
The consumer should be able to cancel the transaction before concluding the purchase.
V. PAYMENT
Consumers should be provided with easy-to-use, secure payment mechanisms and information on
the level of security such mechanisms afford.
Limitations of liability for unauthorised or fraudulent use of payment systems, and chargeback
mechanisms offer powerful tools to enhance consumer confidence and their development and use
should be encouraged in the context of electronic commerce.
VI. DISPUTE RESOLUTION AND REDRESS
A. APPLICABLE LAW AND JURISDICTION
Business-to-consumer cross-border transactions, whether carried out electronically or otherwise,
are subject to the existing framework on applicable law and jurisdiction.
Electronic commerce poses challenges to this existing framework. Therefore, consideration
should be given to whether the existing framework for applicable law and jurisdiction should be modified,
or applied differently, to ensure effective and transparent consumer protection in the context of the
continued growth of electronic commerce.
In considering whether to modify the existing framework, governments should seek to ensure that
the framework provides fairness to consumers and business, facilitates electronic commerce, results in
consumers having a level of protection not less than that afforded in other forms of commerce, and
provides consumers with meaningful access to fair and timely dispute resolution and redress without undue
cost or burden.
B. ALTERNATIVE DISPUTE RESOLUTION AND REDRESS
Consumers should be provided meaningful access to fair and timely alternative dispute
resolution and redress without undue cost or burden.
Businesses, consumer representatives and governments should work together to continue to use
and develop fair, effective and transparent self-regulatory and other policies and procedures,
including alternative dispute resolution mechanisms, to address consumer complaints and to
resolve consumer disputes arising from business-to-consumer electronic commerce, with special
attention to cross-border transactions.
8
i) Businesses and consumer representatives should continue to establish fair, effective and
transparent internal mechanisms to address and respond to consumer complaints and
difficulties in a fair and timely manner and without undue cost or burden to the
consumer. Consumers should be encouraged to take advantage of such mechanisms.
ii) Businesses and consumer representatives should continue to establish co-operative selfregulatory
programs to address consumer complaints and to assist consumers in
resolving disputes arising from business-to-consumer electronic commerce.
iii) Businesses, consumer representatives and governments should work together to
continue to provide consumers with the option of alternative dispute resolution
mechanisms that provide effective resolution of the dispute in a fair and timely manner
and without undue cost or burden to the consumer.
iv) In implementing the above, businesses, consumer representatives and governments
should employ information technologies innovatively and use them to enhance
consumer awareness and freedom of choice.
In addition, further study is required to meet the objectives of Section VI at an international level.
VII. PRIVACY
Business-to-consumer electronic commerce should be conducted in accordance with the
recognised privacy principles set out in the OECD Guidelines Governing the Protection of Privacy and
Transborder Flow of Personal Data (1980), and taking into account the OECD Ministerial Declaration on
the Protection of Privacy on Global Networks (1998), to provide appropriate and effective protection for
consumers.
VIII. EDUCATION AND AWARENESS
Governments, business and consumer representatives should work together to educate consumers
about electronic commerce, to foster informed decision-making by consumers participating in electronic
commerce, and to increase business and consumer awareness of the consumer protection framework that
applies to their online activities.
Governments, business, the media, educational institutions and consumer representatives should
make use of all effective means to educate consumers and businesses, including innovative
techniques made possible by global networks.
Governments, consumer representatives and businesses should work together to provide
information to consumers and businesses globally about relevant consumer protection laws and
remedies in an easily accessible and understandable form.
9
PART THREE
IMPLEMENTATION
To achieve the purpose of this Recommendation, Member countries should at the national and
international level, and in co-operation with businesses, consumers and their representatives:
a) review and, if necessary, promote self-regulatory practices and/or adopt and adapt laws
and practices to make such laws and practices applicable to electronic commerce,
having in mind the principles of technology and media neutrality;
b) encourage continued private sector leadership that includes the participation of
consumer representatives in the development of effective self-regulatory mechanisms
that contain specific, substantive rules for dispute resolution and compliance
mechanisms;
c) encourage continued private sector leadership in the development of technology as a
tool to protect and empower consumers;
d) promote the existence, purpose and contents of the Guidelines as widely as possible and
encourage their use; and
e) facilitate consumers’ ability to both access consumer education information and advice
and to file complaints related to electronic commerce.
PART FOUR
GLOBAL CO-OPERATION
In order to provide effective consumer protection in the context of global electronic commerce
Member countries should:
Facilitate communication, co-operation, and, where appropriate the development and
enforcement of joint initiatives at the international level among businesses, consumer
representatives and governments.
Through their judicial, regulatory, and law enforcement authorities co-operate at the international
level, as appropriate, through information exchange, co-ordination, communication, and joint
action to combat cross-border fraudulent, misleading and unfair commercial conduct.
Make use of existing international networks and enter into bilateral and/or multilateral
agreements or other arrangements as necessary and appropriate, to accomplish such co-operation.
Work toward building consensus, both at the national and international levels, on core consumer
protections to further the goals of enhancing consumer confidence, ensuring predictability for
businesses, and protecting consumers.
Co-operate and work toward developing agreements or other arrangements for the mutual
recognition and enforcement of judgments resulting from disputes between consumers and
businesses, and judgments resulting from law enforcement actions taken to combat fraudulent,
misleading or unfair commercial conduct.

So I ask you Mr. Gershfield, is there any law on the planet Earth that Cash Today Ltd. does follow? Cash Today Ltd. is accountable to follow the laws in the United Kingdom being that that is where the corporate office is located, as well as the guidelines set forth by the OECD, being that Cash Today Ltd. is located in a European Member country. Cash Today Ltd. has incorporated in the states of Delaware and Nevada, thus Lotus Leads Inc. and Leads Global Inc. are subject to follow the their respective states. Every state in the United States of America requires that a license be obtained in order to distribute consumer credit. Does your company have a valid license in any of the 50 states? I think not.
In lieu of your blatant disregard for any law on a global scale, I am demanding a full refund of all principal and all interest that I have paid to your company to date. This refund should total ($ amount). I will expect a cashier’s check wrote out to (your name), to arrive at (your address) within 30 calendar days from today’s date, (date). If I due not receive this refund I will proceed with civil suit against you, Aaron Gershfield, Ivor Gershfield, Keith and Carole Harris, Harris Holding Ltd., Cash Today Ltd., The Royal Bank of Canada (Channel Islands), Lotus Leads, Inc., and Leads Global Inc.
Below is a list of agencies that I have filed formal complaints with regarding your company’s illegal business practices globally.

Sincerely,
(sign your name)

(your name)

Office of the Attorney General
Nevada Department of Justice
Carson City Office
100 North Carson Street
Carson City, Nevada 89701-4717
(775) 684-1100
Fax - (775) 684-1108

Financial Institutions Division
Attn: Supervisory Examiner
901 S. Stewart St., Suite 1003
Carson City, NV 89701
(775) 684-1830
Fax - (775) 684-1845

Office of the Attorney General
Delaware Department of Justice
Wilmington Office
Carvel State Office Building
820 N. French Street
Wilmington, DE 19801
(302) 577-8500
Fax – (302) 577-2496

Office of the State Bank Commissioner
555 E. Loockerman Street
Suite 210
Dover, DE 19901
(302) 739-4235
Fax – (302) 739-3609

(add your state’s division of financial institutions)
(add your state’s Attorney General)