Advisory opinion letter to Mr. Pons

Dear Mr. Pons:

I have your letter of July 11, 1974 to Mr. Greenman. We appreciate the consideration you have given to our submission and request that it be submitted to the Commission for an advisory opinion. As we told you, as soon as we learned on June 3 of the denial of certiorari by the Supreme Court, we informed the management of La Salle. La Salle on the same day ceased to respond to all “leads” (ze., inquiries resulting from advertising) with respect to their law courses. Ordinarily, a course catalog and other promotional material is sent to each “lead,” and the name and address of the prospective student is given to a La Salle representative; since June 8, neither of these steps has been taken with respect to any law course inquiries or “leads.” We are awaiting the Commission’s opinion with respect to the mate 1695 Opinion rials already submitted before making detailed revisions of all La Salle promotional materials with respect to law courses. In the interim, as we have said, the courses have not been sold except to “leads” received before June 3, 1974, and will not be; La Salle is therefore in compliance by the rather brutal temporary expedient of having gone out of the business in question. We request that the due date for La Salle’s compliance report be extended until 30 days after the Commission renders its advisory opinion with respect to the materials already submitted, so as to give time to make whatever revisions in promotional materials are necessary in light of the Commission’s opinion. The materials submitted to you represent an extreme effort to comply with the Commission’s order. For the reasons stated in Mr. Greenman’s letter of June 17, we believe that the general approach embodied in the materials fully meets the purposes of the Commission’s order, to prevent the slightest misunderstanding as to the function of La Salle’s law courses.

We are particularly concerned with the general form of the course catalog, Exhibit 1, and the size of the disclosure to be required in ads such as Exhibits 2 and 3. If the Commission for technical reasons should reject these aspects of these exhibits, we see no alternative at this point to the entire destruction of this part of La Salle’s business. We do not

believe this is the Commission’s purpose.
Sincerely,
/s/ Bella L. Linden