Plaintiff Millennium Laboratories ("Millennium"), a national, researched-based medication monitoring company specifically focused on clinicians who treat chronic pain, brings this Verified Complaint against Defendant Ameritox, Ltd. ("Ameritox"), the provider of RxGuardian pain medication monitoring system (the "RxGuardian system"), for repeatedly engaging in false, misleading and unsubstantiated advertising designed to incorrectly lead consumers into believing that the RxGuardian system can determine whether a patient is complying with the prescribed dosages of pain medication. Ameritox has refused to halt its false and misleading advertisments despite Millennium's demand that it do so. Plaintiff Millennium therefore brings this action seeking preliminary and permanent injunctive relief and damages for unfair and deceptive trade practices under federal law, 15 U.S.C. § 1125.