(CN) - A dozen irate dog lovers claim Florida-based Purebred Breeders and its owner Jason M. Halberg are "the largest volume seller of puppies over the Internet in the country," and make "a tremendous profit" from "the marketing and sale of sick puppies from substandard breeders to consumers in Florida and across the nation."
The 12 plaintiffs in Miami-Dade County Court say they all "were victimized by the defendants' unscrupulous conduct."
They claim Halberg and Purebred Breeders, based in Cooper City, a suburb of Fort Lauderdale, "sell approximately 1,200 to 1,400 puppies every month to customers throughout the United States, including Florida, and Canada, at a mark-up of approximately 100 to 200 percent per puppy. On information and belief, PBB is the largest volume seller of puppies over the Internet in the country."
Halberg and his company act as middlemen between purchasers and the breeders, with whom customers never communicate directly, according to the complaint.
Halberg's website states: "Purebred Breeders is a network of responsible and professional dog breeders. ... We have established a thorough screening process that each breeder must go through before we accept them into our network. Once accepted, our Breeder Department stays in consistent contact with the breeders to guarantee they continue to follow our stringent policies. We do this to assure our families that no matter when they choose their new addition, they can be confident they will receive a happy and healthy puppy," according to the complaint.
But the plaintiffs say that's all eyewash: "These representations grossly misstate the facts. ...
"Defendants regularly sell dogs from breeders who are known to have a history of violating federal and state animal welfare laws, and, on information and belief, continue to do business with breeders who have sold numerous sick puppies to PBB customers. Defendants broker puppies from whatever breeders they can find, without proper screening and without ensuring the puppies are healthy or responsibly bred and raised. In short, despite their assurances to the contrary, defendants do indeed sell puppies from puppy mills across the country, and cannot ensure that a customer's puppy will arrive 'happy and healthy. ...
"The conditions at these breeding facilities are often unsanitary and overcrowded, and the dogs are frequently not provided with adequate veterinary care, food, water, exercise or mental stimulation and socialization, as these all involve money and staff time. As a result of these conditions and a disregard for proper canine husbandry practices, puppies whelped at these sub-standard facilities are highly prone to debilitating and life threatening conditions, such as parvovirus, distemper, congenital and hereditary conditions, giardia, kennel cough, pneumonia, heart disease, and intestinal parasites - many of the conditions suffered by the dogs purchased by the plaintiffs. ...
"Further, on information and belief, some of the breeders that PBB continues to do business with have shipped numerous unhealthy dogs to PBB customers, and yet defendants do not remove them from their list of 'intensely screened' breeders."
After defining "puppy mill" in four depressing paragraphs (paragraphs 20 b-e in the complaint), the plaintiffs say, "Defendants regularly do business with breeders who exhibit all of the hallmarks of puppy mills."
They claim that Halberg and his business operate "a website for every major breed of dog in every state," including buypuppiesdirect.com, to lure customers seeking local breeders.
"Each of the plaintiffs purchased a puppy from defendants over the Internet after reviewing the representations defendants make on their websites regarding the puppies they sell and the breeders they work with. Plaintiffs would not have purchased their puppies from defendants but for defendants' false assurances that the puppies they sell are healthy, and are from reputable, responsible breeders," the complaint states.
The plaintiffs say Halberg refused to reimburse them for ill or genetically defective puppies they bought and the medical expenses they incurred taking care of them.
Lead plaintiff Jennifer Papa and her co-plaintiffs, from 11 states, seek damages for fraudulent inducement, negligent misrepresentation, breach of contract, breach of warranty, and deceptive and unfair trade, plus legal costs and the costs of medical care for the puppies.
They are represented by Theodore Leopold with Leopold-Kuvin of Palm Beach Gardens.
Subscribe to Closing Arguments
Sign up for new weekly newsletter Closing Arguments to get the latest about ongoing trials, major litigation and hot cases and rulings in courthouses around the U.S. and the world.