A complaint was filed against D for a lot of very shady assurances as part of their programs offered to students. After an extensive hearing covering 16 days, 1810 pages of transcripts, 52 witnesses, and 240 exhibits, the hearing examiner ruled in a 93-page initial decision that the charges in the complaint should be dismissed. That decision was appealed to the full Commission. The full Commission reversed the findings of the examiner on six of the charges and entered a cease and desist order against Ds. D appealed.