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Advertising, offering for sale, or selling campground memberships, membership contract addendums, or membership upgrades to consumers in or from the State of Illinois;

Owning, operating, directing, managing, controlling, or being an officer, director, board member, or having any ownership interest in any campground in the State of Illinois;

Violating Section 2 of the Illinois Consumer Fraud and Deceptive Business Practices Act by engaging in the following acts or practices:

1. representing that they will improve and maintain facilities at a campground or campground resort, and then failing to do so;

2. utilizing language in campground membership contracts or campground bylaws which obligate campground members and/or such member's heirs to pay membership dues until the year of their death regardless of whether or not they utilize campground facilities;

3. representing that it is not possible to abandon membership in Defendants' campground when in fact Defendants routinely allow consumers to buy out of their membership dues obligations;

4. failing to maintain accurate financial records for Defendants' campground;

5. attempting to collect campground membership dues for which Defendants have inadequate substantiation;

6. representing to consumers that Defendants could resell campground memberships for consumers who purchased membership upgrades and

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