Five people have been ordered to pay a total of £150,000 in costs after admitting rogue trading.
The three men and two women were directors of St Frances Marketing which offered "free" or "heavily discounted" holidays.
Fraud charges were dropped, but the judge said they had "sailed the company as close as they could to the wind".
They each received a three-year conditional discharge at Exeter Crown Court.
Carol Small, 47, and Karen Henthorne, 45, both of Ide Lane, Alphington, Exeter, were ordered to pay £47,500 each in costs.
John Girvin, 48, of Newlands Avenue, Exmouth, and his 50-year-old brother Michael Girvin, of Salterton Road, Exmouth, Devon, were ordered to each pay £12,500.
Mark Herbert, 56, of Main Road, West Huntspill, Highbridge, Somerset, was told to pay £30,000 costs.
A five-week trial involving 11 barristers was avoided when the defendants all pleaded guilty to unfair trading after seven days of legal argument.
The five were directors of the Exeter based St Frances Marketing, a company set up to market holiday products which has now gone into liquidation.
Potential customers received phone calls, letters and e-mails from different company centres in Exeter, Torquay and Taunton offering "free" or "heavily discounted" holidays which were supposedly the "opportunity of a lifetime".
The case was brought by Devon Trading Standards.
'No free lunch'
Sentencing them, Judge Phillip Wassall said: "Hard sell is one thing, unfair hard sell is quite another.
"Most people would recognise in the cold light of day that there is no such thing as a free lunch."
Charges against the St Frances Marketing Company were left on the file, but there was no order for confiscation.
Judge Wassall said the courts had to send out a clear message that immediate custodial sentences would be imposed on fraudsters who used dishonest tactics to "ensnare their victims".