H. E. Martindale

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IN THE MATTER OF H. E. MARTINDALE, TRADING AS FEDERAL INSTITUTE OF MEATS & MARKETING CO:\IPLAINT, FINDINGS, AND ORDER IN REGARD TO THEJ ALLEGED VIOLATION OF SEC. 5 OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1914 Docket 2134. Complaint, Feb. 29, 1936-Decisi!Yit, Dec. 14, 1936 Where an individual engaged in distributing and selling, from his place of business in a Michigan city, correspondence courses in butchering and meat packing, and in selling books, booklets, and pamphlets to those subscribing to and purchasing his said courses, in substantial competition with those similarly engaged and with those engaged in the business of teaching butchering and meat packing, etc., in ways other than through correspondence courses, in commerce among and between the various States and in the District of Columbia, and including among such competitors many who distribute and sell their courses without in any way misrepresenting the character, quality, size, scope, or connection with the United States Government, of their respective businesses, demand for pupils who have successfully completed their courses, or degree of proficiency that will be acquired by their pupils upon successful completion of the course- (a) Featured in his various advertising literature, including advertisements printed and circulated throughout the various States to pupils and prospec· tive pupils, and extensively used questionnaires, circular letters, enrollment blanks, etc., his trade name, including words "Federal Institute," and made use of such words as "Chief of Examiners," "Board of Examiners," "Examiners," ".Assistant Examiners," and "Divisional Director," notwithstanding fact neither said individual nor the business conducted by him under aforesaid name was in any way connected with, licensed, or approved by any branch or bureau of the United States Government; (b) Included along with his aforesaid trade name, words "Washington, D. C.," and followed his own name with term "Divisional Director," and made use of words ''Central States Office," and made such statements therein as "This survey • • • now being conducted in Wisconsin, is part of a nationwide project, Wisconsin being the first state in the middle-west section (Central States Division) to be contacted," and "Due to the limited time allotted for the completion of this survey, we are resorting to the mails," etc., and depicted in certain portions of 'his advertising a large building, together with his aforesaid trade name, facts being the business thus conducted by him was not operated on a nation-wide or wide-spread basis covering many States, or conducted on a large and substantial basis, pupils and prospective pupils had been contacted only In a very few States, so-called "Central States Office" In said Michigan city was in reality the home and sole office of the business, which rented only a comparatively small office space In building depicted as aforesaid, and said individual or business did not, as represented, have Washington office; and (c) Represented, In his aforesaid advertising literature, that ''The field of operation in this Industry Is nation-wide," and that "among many oppor· tunitles indicated are those of: buyer-shlpper-lnspectlon," etc., and that, 200 FEDERAL TRADE COi\Il\IISSION DECISIONS Complaint 24F. T. C.

as a result of the survey hereinbefore referred to, and use of the mails "to reach quickly a list of men from whom we will select a limited number for personal interviews," "We will be able to select this limited number of men who through the facilities of onr various departments will quicldy qualify for the branches of Rervice outlined herein," notwithstanding fact course in question was uot a complete one in butchering and meat packing, and successful completion thereof did not, of itself, qualify the pupil taking same to fill various positions in the meat slaughtering and pncldng industry, in which there were not many openings, and in whlrh need and dE-mand for trained men was not grcatf'r than actual supply thereof, and In which there were skilled men with long experience in the industry waiting the return of normal conditions for reemployment therein; With capacity and tendency to mislead and deceive a substantial portion of the purchasing public into the beliefs that aforesaid business, thus conducted, was a branch or bureau of the Government, or connected or af!Ulated in some way therewith, or Jirensed and approved by some branch or bureau thereof, and was operated and conducted on a nation-wide and large and substantial basis covering many States, and that there were many openings for various positions in said industry, with need for trained men in exce-ss of the actual supply, as above set forth, and that its course constituted a competent one, upon the completion of which the student would be qualified adequately to fill various positions therein, and with the result that a substantial number of the consuming public, as a direct result of such mistaken and erroneous beliefs, purchased his said courses, and trade was unfairly diverted to him from those similarly eugagecl in the distribution and sale of such or other corresvondence courses and who truthfully advertised the same; to the injury of compe· titlon In commerce among and between the various States and in the District of Columbia:

llelcl, That such acts and practices were to the prejudice of the public and competitors and constituted unfair methods of competition. Before Mr. John J. J(eenan, trial examiner. Mr. J. T. Welch for the Commission.

Mr. Wentworth T. Durant, of Milwaukee, 'Vis., for respondent. Complaint Pursuant to the provisions of an Act of Congress approved September 2G, 1014, rntitled "An Act to create a Federal Trade Commission, to define its powrrs and dutirs, and for other purposes," the Federal Trade Cowmission, having rrason to l1C'lieve that II. E. 1\Iartindalt:>, an inLlividual, trading as Federal Institute of Meats & Marketing, hereinafter referred to as respondent, has been and now is using unfair mrthotls of comp('tition in comnwrce a'l "commerce" is defined in said act, aji\l it apJ)(':tring to the Commission that a proceeding by it in re<;pect thereof woulll be in the public interest, hereby issues its complaint stating it» charges in that rcspc>ct as follows: PAUAGR.\PII 1. Respondent, II. E. ::\lartin(late, is an individual trading us Fedrral Institute of Meats & Marketing with its principal office FEDERAL INSTITUTE OF :MEATS & MARKETING 201 19!) Complaint and place of busir.ess located at 805% Sheridan Road, Menominee, in the State of Michigan. Respondent is now, and has Leen for some time past, engaged in the business of distributing and selling correspondence courses of instruction in the art of butchery and meat packing to persons hereinafter referred. to as pupils and in selling to such pupils severally, as incidental and accessory to the instructions in and to the learning, use, and practice of such science and art, certain merchandise consisting of books, booklets, pamphlets, and other articles in commerce as herein set out.

PAR. 2. Said respondent, being engaged in bnsine>'S as aforesaid, when a prospective pupil entprs into a contract with him, enrolls sn,id pupil, in consideration of the agreed charge or tuition paid or agreed to be paid by such pupil, umlertakes to sell and deliver to such pupil~ through the United States mails or otherwise, a complete course of written, mimeograpluid or printed information and instruction in the particular course or cours<>s of said instruction chosen by such pupil and causes said correspondence courses of instruction, when sold, to be transported from his office and principal place of business in the State of Michigan to purchasers thereof located at various points in other States of the UnitNl States and in tlle District of Columbia, and there is now, and has been at all times mentimwcl herein, a constant current of trade in commerce in said correspomlence courses of instruction in the art of butchery and meat packing so distributed and sold by the respondent between and among the various States of the United States and in the District of Columbia. PAR. 3. In the course and conduct of his said business, respondent is now, and has been, in substantial competition with other individuals and with firms and corporations likewise engaged in the business of distributing and selling correspondence courses of instruction in various arts, including the art of butchery and meat packing, and also with persons, firms, and corporations engaged in the business of teaching or giving instruction in the art of butchery and meat packing and other arts in ways other than through correspondence courses, in commerce among and between the various States of the United States and in the District of Columbia. PAR. 4. In the course of the operation of said business, and for the purpose of inducing individuals to purchase and pay for said correspondence course of instruction, respondent has cam:ed advertisements to Le inserted in newspapers of general circulation throughout the Unit('cl States, and has printed and circulated throughout the various States to pupils an<l prosprcti,·e pupils, through the United States mails and otherwise, circular letters, questionnaires, enrollment blanks, and other advertising literature. In all of said ques- Complaint 24 F. T.C. tionnaires, circular letters, enrollment blanks, and advertising literature, the respondent has caused his trade name to be prominently and conspicuously displayed with the following addresses and designations :

Central States Division Federal Instltute--l\1eats-1\1arketlng Washington, D. C.

II. E. 1\lartlndale, Divisional Director Central States Office Menominee, Michigan In other advertising literature, the respondent has made use of the following statements:

This survey sponsored by the F. I. M. l\1. now being conducted in Wisconsin is part of a nation-wide project, Wisconsin being the first state In the middlewest section (Central States Division) to be contacted. Due to the limited time allotted for the completion of this survey, we are resorting to the malls In order to reach quickly a list of men from whom we wlll select a limited number for personal interviews. The field of opemt!on in this industry is nation-wide-among the many opportunities Indicated are those of: buyer-shlpper-lnspectlon-managlngsupervislng; also grading-slaughter-dressing of cattle-likewise sausage mak· ing, etc. As a result of this survey, we will be able to select this limited number of men who through the facilities of our various departments will quickly qualify for the branches of senice outlined herein. In all of said literature and enrollment blanks, hereinabove referred to, the respondent also makes use of such terms as "Chief of Examiners," "Doard of Examiners," "Examiners," "Assistant Examiners," and "Divisional Director" to designate certain of his employees or associates, those terms being generally used by various branches, divisions, and bureaus of the United States Government to designate certain classes of their respective employees. In certain portions of the advertising literature, hereinabove referred to, respondent displays a picturization of a large building under which there appears the designation:

FEDEllAL INSTITUTE OF MEATS & MARKETING Menominee, Michigan All of said statements, together with many similar statements appearing in respondent's advertising literature, purport to be descriptive of the business conducted by him under the trade name Federal Institute of Meats & Marketing. In all of his advertising litemture and through representations and statements made by the respondent FEDERAL INSTITUTE OF 1\IEATS & MARKETING 203 199 Complaint acting through agents and representatives, the respondent has represented, and now represents, that (1) the business conducted by him under the trade name Federal Institute of Meats & Marketing is a branch or bureau of the United States Government, has some connection or affiliation with some branch or bureau of the United States Government or is licensed and approved by some branch or bureau of the United States Government; (2) that the business operated under the trade name Federal Institute of Meats & Marketing is operated on a nation-wide basis, or is operated on a widespread basis covering many states and is conducted on a large and substantial basis; and (3) that there are many openings for various positions in the meat slaughtering and packing industry and that the need and demand for men trained in the art of butchery and meat packing is much greater than the actual demand therefor and that the course of instruction sold by the respondent is a competent course upon the completion of which the pupil will be adequately qualified to fill various positions in the meat slaughtering and meat packing industry.

PAR. 5. The representations made by the respondent as to any connection between the business conducted by him under the trade name Federal Institute of Meats & :Marketing and any branch or bureau of the United Stares Government are, in fact, untrue. Neither the respondent nor the business conducted, as aforesaid, is in any way connected with a bureau or branch of the United States Government and neither the respondent nor the business conducted under the name of Federal Institute of :Meats & Marketing maintains an office <If any kind in 'Vashington, D. C.

The business operated by the respondent is not operated on a nation-wide basis or on a widespread basis covering many states and is not conducted on a large and substantial basis. In truth and in fact, pupils and prospective pupils have been contacted in only a very few states and the so-called "Central States Office" located at Menominee, Mich., is in reality the home and sole office of the business. 'fhe Federal Institute of Meats & Marketing does not operate or completely occupy the building depicted, as hereinabove indicated, but actually rents only a comparatively small office space in said building. In truth and in fact, there are not many openings for various positions in the meat slaughtering and packing industry and the need and demand for men trained in the art of butchery and meat packing is not greater than the actual demand therefor. In truth and in fact, the course of instruction offered by the respondent is :not a complete course in butchery and meat packing and a success- :ful completion of said course does not, of itself, qualify the pupil 204 FEDERAL TRADE COl\Il\IISSION DECISIONS Findings 24 F. T. C. taking said course to fill various positions in the meat slaughtering and packing industry.

PAn. G. There are among the competitors of the respondent many who distribute and sell either correspondence courses or other courses in butchery and meat packing, or other correspondrnce courses of instruction, who do not, in any way, misrepresent the character, quality, size, scope, or connection with the United States Government, of their respective businesses and do not, in any way, misrepresent the demand for pupils who have successfully completed their respective courses of instruction or the degree of proficiency that will be acquired by the pupil upon a successful completion of the course. PAn. 7. Each a11<l all of the false and misleading statements and representations made by the respondent, as hereinabove set out, in his advertising, in newspapers, questionnaires, circular letters, enrollment blanks, and other advertising literature, in offering for sale and selling his courses of instruction was, and is, calculated to, and had,. and now has, a tendency and capacity to mislead and deceive a substantial portion of the purchasing public into the erroneous belief that all of said representations are true. Further, as a direct consequence of the mistaken and erroneou~ beliefs, induced by the acts,. adv:et~tisements, and misrepre~entations of respondent, as hereinabove detailed, a substantial number of the consuming public has purchased a substantial volume of respondent's courses of instruction with the result that trade has been unfairly diverted to the respondent from individuals, firms and corporations likewise engaged in the business of distributing and selling correspondence courses or other courses in the art of butchery and meat packing, or other correspondence courses, and who truthfully advertise their courses of instruction. As a result therof, substantial injury has been, and is now being done, by respondent to substantial competition in commerce among and between the various States of the United States and in the District of Columbia.

PAR. 8. The above and foregoing acts, practices and repre~·enta­ tions of the respondent have been, and are, all to the prejudice of the public and respondent's competitors as aforesaid, and have been, and are, unfair methods of competition within the meaning and intent of Section 5 of an Act of Congress approved September 26, 1914, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes." REronT, FINDINGS AS TO THE FACTs, AND Onom Pursuant to the provisions of an Act of Congress approved September 26, 1914, entitled, "An Act to create a Federal Trade Com- FEDERAL INSTITUTE OF MEATS & 1\IARI(ETING 205 199 Findings mission, to define its powers aml duties, and for other purposes," the Federal Trade Commission on February 29, 1936, issued and served its complaint in this proceeding upon the respondent, H. E. Martindale, trading as Federal Institute of Meats & Marketing, charging him with the use of unfair methods of competition in violation of the provisions of said act. After the issuance of said complaint, testimony and other evidence in support of the allegations of said complaint were introduced by J. T. ·welch, attorney for the Commission, before John J. Keenan, an examiner of the Commission theretofore duly designated by it, and in opposition to the allegations of the complaint by ·wentworth T. Durant, attorney for the respondent, and said testimony and other evidence were duly recorded and filed in the office of the Commission. Thereafter, the proceeding regularly came on for final hearing before the Commission on the said complaint and testimony and other evidence; and the Commission having duly considered the same, and being now fully ad vised in the premises, finds that this proceeding is in the interest of the public and makes this its findings as to the facts and its conclusion drawn therefrom: FINDINGS AS TO THE FACTS PARAGRAPH 1. Respondent, H. E. Martindale, is an individual, trading as Federal Institute of Meats & Marketing. His place of business was formerly located at 805lf2 Sheridan Road, Menominee, Mich. He is now located at G47 State Street, Marinette, in the State of Wisconsin. Respondent is engaged in the business of distributing and selling correspondence courses of instruction in the art of butchery and meat packing. As incidental and accessory to the instruction in the art of butchery and meat packing, he also sells certain merchandise consisting of books, booklets, and pamphlets to those persons subscribing to and purchasing his correspondence courses of instruction.

'Vlwn a prospf'ctive pupil enters into a contract with the respondent, he is enrollt:>d in consideration of the agree1l tuition charge which is paid or agreed to he paid by saill pupil. The respondent delivers to such pupil, through the United States mail or otherwise, a course of written, minwogmphed, or printed instructions in the particular course or courses chosen by such pupil. Respondent causes such courses of instruction, wlwn sold, to be transported from his principal place of business in the State of l\Iichigan to purchasers thereof located at various points in other States of the United States. The respondent has maintaincd, at all times for a period of more than one year last past, a constant cmTPnt of trade and comm(>rce in said correspondence courses of instruction in the art of butchery and meat packing, between 14(Jj;;(Jon R!l \ ol. 24 l 6 FEDERAL TRADE COMI\IISSION DECISIONS 206 Findings 24F.T.C.

and among the various States of the United States and in the District of Columbia.

PAR. 2. In the course and conduct of his said business, respondent is now, and has been, in substantial competition with other individuals and with firms and corporations likewise engaged in the business of distributing and selling correspondence courses of instruction in various arts, including the art of butchery and meat packing, and also with persons, firms, and corporations engaged in the business of teaching or giving instruction in the art of butchery and meat packing and other arts in ways other than through correspondence courses, in commerce among and between the various States of the United States and in the District of Columbia.

PAR. 3. For the purpose of inducing individuals to purchase and pay for said correspondence courses of instruction, the respondent has made use of advertisements which had been printed and circulated throughout the various States of the United States to pupils and prospective pupils through the United States mail and otherwise .. The respondent has also made extensive use of questionnaires, circular letters, enrollment blanks, and advertising literature which has been circulated in the same way to prospective pupils. In all of his advertising literature, the respondent causes his trade name to be prominently aml conspicuously displayed with the following addresses and designations:

Central States Division Federal Institute--l\feats-1\Iarket!ng Washington, D. C.

II. E. 1\Iartindule, Divi,;ional Director Central Statps Office 1\Ienominee, 1\IIchlgan In other advertising literature, the respondent has made use of statements such as the following:

This survey Fponsored by the F. I. 1\I. l\I. now bdng conducted In Wisconsin Is part of a nation-wide projrct, Wisconsin bping the first state In the middlewest section (C('ntral States Division) to be contacted. Due to the limftE'd time allottrd tor the completion ot this survey, we are resorting to the malls In order to reach quickly a li"lt of men from whom we will select a limited number tor personal Interviews. The tlr•ld of operation In this industry Is nation-wide-among the many opportunities indicated are those of: buyer-shipper-inspeetlon-mnnnging-supervislng; also grading-sloughter-dressing of cattle-likewise snnsn~:e making, FEDERAL INSTITUTE OF MEATS & MARKETING 207 . 100 Findings ~tc. As a result of this survey, we will be able to select this limited number of men who through the facilities of our various departments will quickly qualify for the branches of service outlined herein. In all of said advertising literature, including questionnaires, circulars and enrollment blanks, the respondent makes extensive use of such terms as "Chief of Examiners," "Doard of Examiners," "Examiners," "Assistant Examiners," and ''Divisional Director" to designate certain of his employees or associates. In certain portions of his advertising literature, the respondent displays a picturization of a large building under which there appears the designation: FEDERAL INSTITUTE OF MEATS & :l\IARKETING l\Ienominee, Michigan In all of his advertising literature and through representations and statements made by the respondent acting through agents and representatives, the respondent has represented and now represents that {1) the business conducted by him under the trade name Federal Institute of .Meats and .Marketing is a branch or bureau of the United States Government, has some connection or affiliation with some branch or bureau of the United States Government or is licensed and approved by some branch or bureau of the United States Government; (2) the business operated under the trade name Federal Institute of Meats & Marketing is operated on a nation-wide basis, or is operated on a widespread basis covering many states and is conducted on a large and substantial basis; (3) there are many openings for various positions in the meat slaughtering and packing industry and that the need and demand for men trained in the art of butchery and meat packing is much greater than the actual demand therefor; and ( 4) the course of instruction sold by the respondent is a competent course upon the completion of which the pupil will be adequately qualified to fill various positions in the meat slaughtering and meat packing industry. PAn. 4. The terms "Chief of Examiners," "Doard of Examiners," "Examiners," "Assistant Examiners," and "Divisional Director" are terms generally used by various branches, divisions, and bureaus of the United States Government to designate certain classes of their respective employees. The representations made by the respondent as to any connection between him or the business conducted by him under the trade name Federal Institute of Meats & Marketing and any brunch or bureau of the United States Government are, in fact, untrue. Neither the respondent nor the business conducted by him under said trade name is in any way connected with, affiliated with, licensed or approved by, any branch or bureau of the United States Government. The respondent, neither individually nor under the 208 FEDERAL TRADE COl\11\IISSION DECISIONS Findings 2-!F. T. C. trade name Federal Institute of l\Ieats & Marketing, conducts or maintains an office of any kind in the city of Washington, District of Columbia. The business operated by the respondent is not operated on a nation-wide basis or on a widespread basis covering many States and is not conducted on a large and substantial basis. As a matter of fact, pupils and prospective pupils have been contacted only in a very few States. The so-called "Central States Office" located at Menominee, Mich., is in reality the home and sole office of the business. The Federal Institute of Meats & Marketing does. not completely occupy the building depicted in respondent's advertising matter but actually rents only a comparatively small office space in said building. The course of instruction sold by the respondent is not a complete course of butchery and meat packing and a successful completion of said course does not, of itself, qualify the pupil taking such course to fill various positions in the meat slaughtering and packing industry. There are not many openings. of various positions in the meat slaughtering and packing inrlustry and the need and demand for men trained in the art of bnt<-hery and meat packing is not greater than the actual supply therefor. There are skilled men with long experience in the industry who are waiting a return of normal conditions for reemployment in the meat packing industry.

PAR. 5. There are among the competitors of the respondent many who distribute and sell either correspondence courses or other courses in butchery and meat packing, or other correspondence courses of instruction, who do not, in any way, misrepresent the character, qualityt size, scope, or connection with the United States Government, of their respective businesses and do not, in any way, misrppresent. the demand for pupils who have successfully completed their respective courses of iustmction or the degree of proficiency that will be acquired by the pupil upon a successful completion of the course. PAR. 6. Each an<l all of the f1tlse an<l misleading f'tfltements nnd representations made by the respondent in hi1> advertising literature in offering for sale an<l selling his conespomlence courses of instruction were, and are, calculated to, and hal, and now haw, 11. capacity an<l tendency to mislead<l a1Hl deceive n substantial portion of the pnrcha~i11g public into the Lrliefs that the bnsinrss condnctl'd under the trade name of Federal Institute of Meats & Marketing is a branch or burl'au of the United States Government or has some connection or affiliation with some branch or bureau of the Unite<l States Government or is licem;pd and approw<l by some branch or Lureau of the United States Government; that the business is operated on a nation-wide basis covering many States and is conducted FEDERAL INSTITUTE OF :MEATS & MARKETING 209 199 Order on a large and substantial basis; that there are many openings for various positions in the meat slaughtering and packing industry and that the need for men trained in the art of butchery and meat packing is much greater than the actual supply therefor; and that the respondent's course of instruction constitutes a competent course upon the completion of which a student will be adequately qualified to fill various positions in the meat slaughtering and meat packing industry. As a direct consequence of these mistaken and erroneous beliefs, a substantial number of the consuming public has purchased respondent's courses of instruction with the result that trade has been unfairly diverted to the respondent from individuals, firms, and corporations likewise engaged in the business of distributing and selling correspondence courses or other courses in the art of butchery and meat packing, or other correspondence courses and who truthfully advertise their respective courses of instruction. As a consequence thereof, injury has been done by respondent to competition in commerce among and between the various States of the United States and in the District of Columbia.

CONCLUSION The aforesaid acts and practices of the respondent, H. E. 1\Iartindale, trading as Federal Institute of l\Ieats & Marketing, are to the prejudice of the public and of respondent's competitors, and constitute unfair methods of competition in commerce, within the intent and meaning of Section 5 of an Act of Congress, approved September 2G, 1014, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes." ORDER TO CEASE AND DESIST This proceeding having been heard by the Federal Trade Commis~ion upon the complaint of the Commission, testimony and other f•vidence taken before John J. Keenan, an examiner of the Commission theretofore duly designated by it, in support of the allegations of said complaint awl the Commission having made its findings as to the facts and c~nclusion that said respondent has violated the provisions of an Act of Congress approved September 26, 1!>14, entitled, "An Act to create a Federal Trade Conm1ission, to define its powers and duties and for other purposes."

It i8 orllered That the respondent, II. E. Martindale, individually and trading at~d doing business as Federal Institute ?f Meats and Marketi 1w or trading umler any other trade name, Ins representatives, age~~s, and employees, in connection with the offering for sale, Order 24F.T.C.

sale, and distribution of correspondence courses of instruction in interstate commerce or in the District of Columbia, do forthwith cease and desist from :

1. Representing, through the use of the words "Chief of Examiners," "Doard of Examiners," "Examiners," "Assistant Examiner," "Divisional Director," and "Federal Institute," alone or in conjunction with any other word or words, or through any other means, or in any other manner, that the respondent or the business conducted by him is a branch or bureau of the United States Government, or is in any way connected or affiliated with, or is licensed and approved by, any branch or bureau of the United States Government; 2. Representing that the business operated by the respondent is operated on a nation-wide basis or is operated on a widespread basis covering many states, or is conducted on a large and substantial basis, when such is not the fact;

3. Representing that there are many openings for various positions in the meat slaughtering and packing industry, or that the need and demand for men trained in the art of butchery and meat packing is much greater than th~ actual demand therefor; 4. Representing that the respondent's course of instruction is a competent course, upon the completion of which the pupil will be adequately qualified to fill various positions in the meat slaughtering and packing industry;

5. Representing that the respondent or the business conducted by him maintains offices in the city of Washington, District of Columbia; 6. Using the term "Federal Institute" in the name under which respondent's business is conducted, or using any other word or expression which implies or suggests any connection with any branch or bureau of the United States Government.

It isfttrther ordered, That the respondent shall, within 30 days after service upon him of this order, file with the Commission a report in writing setting forth in detail the manner and form in which he has complied with this order.

A. KE\IBALL COMPANY ET AL. 211 Complaint