Advisory opinion letter: or not, under existing laws and decisions, the dissemination of such a chart to its…

Gentlemen:

We represent Beauty and Barber Supply Institute, a national trade association with its office at 551 Fifth Avenue, New York City. Its membership consists of 800 wholesalers of “beauty” products. The members of the association are concerned with the distribution of all “beauty” products. The members of the association have performed the typical “wholesaler” functions: stocking, warehousing, delivering, extending credit, travel salesmen and maintaining the inventory of their customers.

The association is desirous of providing its membership with a benefit that would insure their having knowledge and therefore the ability to take advantage of freight allowances that are due to them. It feels that a comprehensive chart showing how the wholesaler must order to accrue the benefits offered by manufacturers would be of substantial benefit. It is proposed that a chart such as that submitted herewith would be a material aid to its members. Therefore, I request an advisory opinion as to whether or not, under existing laws and decisions, the dissemination of such a chart to its members would in any way be a violation of the law.

The proposed course of action is not currently followed by the association and is not the subject of any pending investigation or other proceedings by the Federal Trade Commission or any other governmental

agency.
Very truly yours,
James F., Flanagan