Complaint meet-confer - motions

The following is a complaint filed in the United States District Court for the District of Connecticut:

1. Plaintiff Jane Smith is a citizen of Connecticut. The amount in controversy herein exceeds $75,000, exclusive of interest and costs.

2. Defendant Electronics Institute, Inc. is a Delaware Corporation with its principal place of business in New York. It operates an establishment in New Haven, Connecticut.

3. Defendant advertised a course in electronics technology at tuition of $2,500. The advertisements claimed that "completion of the course could lead to big money in electronics." Plaintiff enrolled in and completed the course and paid $2,500 in tuition therefor.

4. Plaintiff has been unable to find any employment in electronics at a wage exceeding the minimum wage. Plaintiff is informed and believes and therefore alleges that there are no jobs paying more than $8 per hour in the New Haven area for which the training provided by defendant is necessary and useful.

5. Plaintiff was induced to believe that employment at a high wage would result from taking the course provided by the defendant. As a result of thus being misled by defendant, plaintiff suffered embarrassment, humiliation, and loss of self respect, to her damage of $100,000.

6. The training provided by the defendant was substantially worthless.

Wherefore, plaintiff prays for restitution in the amount of $2,500, for additional damages in the amount of $100,000; and for interest and costs.

You represent the defendant. Analyze the motions that you might have good basis for asserting by way of attack on the complaint.