ALAN HEISE, Individually and as Representative for all others similarly situated and the General Public. This is a national class action against:

MOTOROLA, INC., SUREWEST COMMUNICATIONS, and SUREWEST WIRELESS

on behalf of all those who allege to have purchased a Motorola V710 cellular phone, which was extensively advertised as Bluetooth® enabled. SUREWEST is one of the numerous service carriers that purchased V710 phones from MOTOROLA. SUREWEST is alleged to have wrongfully and unfairly deceived its cellular telephone customers by advertising and selling the high-priced V710 phone with express and implied promises that it had all Bluetooth® capabilities and then disabling most of its Bluetooth® capabilities, which adversely affects the usability of the phone, resulting in a significantly degraded phone and phone services, forcing the customer to pay for additional services that would not otherwise be required if the Bluetooth® capabilities were not disabled by SUREWEST. The suit asks for an equitable relief, injunctive relief , declaratory relief, punitive damages, exemplary damages, compensatory damages, cy pres recovery, restitution and disgorgement of money received by Defendants as a result of their wrongful conduct, attorneys' fees, pre-judgment interest and costs of suit.