The Plaintiff alleges, and Direct denies, that Direct in its telemarketing, in-person, and other marketing, selling, and promoting activities relating to the sale of electricity (a) solicited residential Illinois Consumers by telephone without stating the purpose of the call at the outset, or inquiring whether the person called consented to the solicitation, in violation of Illinois law; (b) misrepresented to residential Consumers that Direct was affiliated with the Consumer’s public utility; (c) misrepresented that there exists a state-sponsored or state-sanctioned “program” that offers residential Consumers savings, refunds, or similar benefits upon enrollment; (d) misrepresented during solicitations that the residential consumer’s public utility account information had to be “verified” or “confirmed,” and thereby deceptively obtained access to confidential utility account information; (e) misrepresented that Direct’s rates are “low” and that residential Consumers will save money by enrolling with Direct, when the opposite is true; (f) misrepresented that Direct’s fixed rates provided “price protection” that would protect residential Consumers from allegedly high default utility rates when in fact it locked residential Consumers into fixed rates considerably higher than the default utilities had ever charged; and (g) routinely failed to disclose the new rate that residential customers would be paying or their new fixed rate term.