Advisory opinion letter

Dear Sirs: me We reqtiest an advisory opinion on the legality, as.it pertains to your agency’s scope, of the following new venture that we are considering. We propose to purchase products from manufacturers for resale to consumers. Sales of these products, by us, would be generated through dissemination to prospective customers of a publication consisting solely of catalog pages featuring the products that we stock. Manufacturers of the products we stock and sell would be offered advertising space within this catalog at the rate of $3000 for one-half page, $6000 for a full page. They could use this space for any purpose. ‘These manufacturers could purchase as much advertising space in this catalog as they wished, regardless of the volume of their sales to us. Manufacturers wh

o do not sell to us would not be eligible to advertise in this publication. We ask for your opinion as to whether this type of marketing firm would violate any laws or regulations enforced by the FTC.

Cordially,
ELECTRONIC DISTRIBUTING & MARKETING
Edward J. Walter
Publisher
AQT ONT 79 41a
1726 FEDERAL TRADE COMMISSION DECISIONS

‘Tripartite advertising promotional plan using grocery shopping

carts. (File No. 703 7096)
Opinion Letter
June 10, 1970
Dear Mr. Graham:

This is in further response to your letters of March 26 and April 10, 1970 requesting an advisory opinion regarding a tripartite advertising promotional plan whereby National In Store Advertising Company would lease advertising space on bascarts (grocery shopping carts) or similar equipment from supermarkets and other stores and establishments. The Commission has carefully considered the plan as outlined in your letters and concluded that implementation of the proposed plan would probably violate Section 2(d) of the amended Clayton Act. By direction of the Commission, with Commissioner Elman not concurring. ) Supplemental Letter of Request April 10, 1970