The New York City Court of Yonkers decided yes, a contract with a pyramid scheme could be voided for lack of consideration. NU-Concepts sold travel agent training plans that provided no training or education, only the right to sell the program to others. The purchaser wanted the training program, and did not want anything to do with the pyramid selling aspects of the program. The City Court held that NU-Concepts never intended to fulfill it representations that induced the plaintiff to purchase the program. Their representations of education and training amounted to unconscionably and gross misrepresentation, and rescission of the agreement was warranted.

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