This case involves a company that was allegedly misled by an online marketing consulting firm. The plaintiff in Hawaii searched for, and later located, a company who had extensive experience in enterprise search engine optimization. The SEO company was hired to assist in regaining the number one rank for a particular keyword on multiple search engines. The plaintiff company which hired the SEO consultant relied solely on internet marketing as a primary means of business development and marketing. Search algorithms are routinely changed by the major search services providers, and the company’s rank dropped significantly on organic search following one of these updates. The defendant in this suit promised his company would be able to get the company back on page 1 within several weeks. As time passed, their search rank did not change, and it was apparent that nothing had improved since they’d hired his firm. It was alleged that the vendor overstated his qualifications and has done nothing in terms of page ranks for their new site or prior sites.