Perfect Manufacturing Co

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IN THE MATTER OF PERFECT MANUFACTURING COMPANY COl\JPLAIN'f, FINDINGS, AND ORDER IN REGARD TO THE. ALLEGED VIOLATION OF SEC. 5 OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1914 Doclcet 13899. Complaint, Aug. 14, 1936-Decision, Apr. 30, 193"/ Where a corporation engaged in manufacture, and sale to purchasing and consuming public in various parts of the United States, through use of trade name "Sav-An-Upper Company," of preparation, among others, known and designated as "Sav-An-Upper," and thus branded, labeled, and packed for sale and distribution by it, trading under name ''Sav-An-Upper Company," nnd by its agent-salesmen to purchasing and consuming public; In advertising its said product, In the course and conduct of Its said business and as a means of obtaining services of such agent-salesmen to handle and sell the same, in sales magazines and periodicals of general circulation and in circulars and other mail matter distributed to prospective agents and containing sales talks and instructions, and through representations in said advertisements, distributed as aforesaid, and ~·which were eventually communicated to customers and consumers, actual and prospective- (a) Represented that its said product had unusual sales appeal, or that selling qualities or possibilities thereof were most exceptional, and that large sums of money might commonly or easily be made by agents in handling and selling the same, through such stu tements as that men and women every- Where were making tremendous prolits, up to 202%, in the sale thereof •. that an investment of $1.50 could build itself into tens, hundreds, and thousands of dollars in just a short while, and that earnings up to $5,000 a year should be reached by quite a few, and others of like import and effect; (b) Represented that its said product, when applied to objects, possessed and imparted the quality, condition, and effect of permanency and would renew "articles to which it was applied, such as trunks, luggage, school and shopping bags, or make scuffed shoe tops loolc as neat and good as the day they left the factory, and similar statements; and (c) Represented that it owned or operated the million dollar company which Was, or would be, back of salesmen selling its said product, and that such company had a world-wide business and prospering agents everywhere; Facts being such statements and representations were false, deceptive, misleading and exaggerated in various particulars, its said product did not possess the sales appeal or possibilities claimed for it, agents and salesmen could not and did not realize, through sale thereof, large earnings and profits held out to them, product did not produce or impart a coating which was permanent in character or which would renew or restore objects, no matter how old, \\·orn or scuffed they might be, to a new or like new condition, and it did not own, control, or operate any million dollar company or business with World-wide trade or connections, or any company or business even approxi- ' lllating such financial size, status, or importance; V'ith tendency and eapaclty to cause agents and salesm<m to form mistaken and erroneous beliefs that such a company, and with world-wide business and prosperous agents everywhere, was back of them, and that product in question had a selling power or appeal which it did not possess, and that large and Complaint 24F. T. C.

substantial profits could be earned from sale thereof, and with effect of causing members of purchasing public to form mistaken and erroneous beliefs concerning character and qualities of said product and mmge to which it properly and successfully might be put, and with further result that salesmen and agents were thereby induced to handle and sell the same, and members of the public to purchase said product under erroneous belief that misleading and extravagant claims made for 1t were true, to the detriment and injury of manufatturers and sellers of similar products, and with capacity and tendency unfairly to divert to it trade of competitors engaged in selling such products and who fairly and accurately advertise and represent the same:

Held, That such acts and practices were to the prejudice of the public and competitors and constituted unfair methods of competition. Mr. 111 arshall 111 organ for the Commission. Pamton & Seasongood, of Cincinnati, Ohio, for respondent. Complaint Pursuant to the provisions 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," the Federal Trade Commission, having reason to believe that Perfect Manufacturing Company, a corporation, hereinafter referred to as "respondent," has been, and is now, using unfair methods of competition in commerce as "commerce" is defined in said act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, hereby issues its complaint, stating its charges in that respect as follows:

PARAGRAPH 1. Respondent, Perfect Manufacturing Company, is a corporation organized, existing, and doing business under ana" by virtue of the laws of the State of Ohio, with its principal office and place of business located at 3325 Madison Road, in the city of Cincinnati, Ohio. Respondent is now and for more than two years last past has been engaged, as hereinafter described, in the business of manufacturing and selling to retail dealers, agents, and salesmen iil various parts of the United StpJes, through the use of trade name companies, various appliances, products, and preparations. Among the appliances, products, and preparations so manufactured and sold by respondent, is a liquid shoe polish, enamel, dressing, or finish, for shoes, made in different colors, known and designated as "Sa-v- An-Upper,'' and sold to retail dealers, salesmen, and agents in various parts of the United States. The said preparation, Sav-An-Upper, is manufactured, as stated in Cincinnati, Ohio, where it is branded, labelled, and packed by respondent for sale and distribution by itself through the use of a trade name company, known and designated PERFECT MANUFACTURING CO. 1165 1163 Complaint as "Sav-An-Upper Company," and by its agent-salesmen, or dealercustomers, to the purchasing and consuming public of the United States. In consummating such sales and in distributing such product, respondent causes the said shoe polish, enamel, dressing, or finish to be transported and delivered from its place of business in Cincinnati, State of Ohio, through and into various other States of the United States to the respective purchasers thereof at their respective points of location. In the course and conduct of its business the respondent has been and is now engaged in direct and substantial competition With various corporations, partnerships, and individuals likewise engaged in the sale and distribution of shoe polishes, enamels, finishes, or dressings for shoes and offering such products for sale in commerce ?etween and among the various States of the United States and with- In the District of Columbia.

PAR. 2. In the course and conduct of its said business respondent has offered its products for sale and has sold and transported or caused the same to be transported in commerce among the several States of the United States to the consuming public through the llledium of salesmen, agents, and dealers. Said products are and Were shipped in response to orders received from said salesmen, agents, or dealers transported or caused to be transported in comlllerce among the several States of the United States. As a means of obtaining the services of such salesmen, agents, or dealers, said l·espomlent causes and has catLsed advertisements to appear in sales lllagazines and periodicals having general circulation, and, in addition, distributes and has distributed circulars and other mail mutter containing sales talks and instructions.

In the course and conduct of its said business, as hereinabove related, respondent has caused various false, deceptive, and misleading statelllents to be inserted and to appear in said advertisements and in circulars and other mail matter distributed by it. The statements contained in said advertisements, circulars, and mail matter are addressed to and are and have been distributed among salesmen, agents, and dealers throughout the United States and are intended to be and constitute instructions to them in connection with sales talks to be lnacle to retail stores, boot-black stands, customers and consumers, actual and prospective. In this manner the said Yarious false and lllisleading statements and representations inserted in said trtule lnagazines, circulars, bulletins and other communications by respondent, including claims set forth in describing respondent's products, are and have been passed on to the ultimate consumer by respondent's salesmen, dealers, and agents, and the consuming public have been induced to purchase the products thus offered for sale and sold by 1467:iGm-3!l vol. 24-76 Complaint 24F.T.C.

respondent in the erroneous belief that said false and misleading statements and representations concerning such products were and are true.

PAR. 3. In the course an~ conduct of its business, respondent, in advertisements, circulars, bulletins, and sales communications having a general circulation, as stated, represents in advertising: Picture appearing in a display ad,·ertisement of an old, creased and wrinkled look:ng shoe coupled with the words:

Defore Using Sav-An-Upper.

Picture of same shoe in glistening black surface, and, new In appearance, coupled with the words :

After Using Sav-An-Upper.

Shoes like new as low as 2¢ a pair. It's easy. Shoes like new 6¢ a pair. Earn up to $2 in an hour.

Sensational new discovpry-completely covers scuffed, discolored and faded uppers of any shade with wear proof highly polished coating. Makes theiil look new. Quick, easy economical. Takes only a minute. Just brush it on. Gives glossy, good-looking, long wearing, crack proof finish. Sav-An-Upper has found a hearty welcome In every city, town, village, and on millions of farms.

Free Sample-1\Ien and women representatives making tremendous profits. Unlimited demand. Write today for free sample that proves all claims and territory offer. Send no money.

Not a polish. Not a dye.

Saves buying shoes.

• • • makes the scuffed, discolored and faded uppers glossy, neat and good· looking as the day they left the factory.

Sav-An-Upper completely covers the scufl'ed, unsightly leather, canvas, suede, reptile skin, satin or linen with a tough, water-proof, long-wearing, flexible coat· ing that won't rub off. Sav-An-Upper preserves the uppers and adds months and months of extra wear.

Men and women everywhere making tremendous profits-up to 202%. Desir· able territories are being "snapped up" by hustlers. Get your share of the Dig Money • • • • • • Not only makes old shoes like new but it is also excellent for renewing trunks, luggage, school bags, shopping bags, brief cases, leather up· holstery, and cushions, auto tops, harness, reins, saddles, bits, wallets. leather gloves, etc. • • • • • • Enormous margin of profit on quick easy sales. • • • lllost sensational money maker ever offered to direct sellers. Waterproof, crack-proof-long wearing-Needs no polishing. Your $1.50 investment can build itself into tens, hundreds, and thousands of dollars in just a short while. Act today! Just got back to my room from a date with a shoe man. lie surely gflve Sav-An-Upper every test be knew and then some. When he got through 1Je told me it was the best product he bad ever seen. E,·ery !lemonstration makes you sales and profits galore. • • • Your profits are guaranteed-you have a fortune to gain and you cannot loHe· Your territory is open but It will not stay that way long. Your tenitory is a regular "gold mine" ready for digging. PERFECT MANUFACTURING CO. 1167 1163 Complaint De financially Independent.

You can earn as much money as you want because tile amount of your income depends entirely on your own efforts.

You simply make the sensational one-second demonstration and the prospect BUYs.

A. self-polished, good-looking flexible coating that is longer wearing, cracklll'oof, waterproof and permanent.

If you act quickly you can begin making as much as $2.00 in an hour at once, beginuing the first day.

• • • Its big margin of profit (up to 186o/o) means that just a few sales Will pay you $30.00, $50.00, $80.00 a week or more. • "' "' Even beginners are so swamped with orders that they must hire flUb-agents to help handle their business. Earnings up to $5000.00 in a year Should be reached by quite a few.

• • • I want to see you own your own home, your own car, and have a hank account. That's what Sav-An-Upper is doing for other men and women everywhere.

• • • Demonstrations of this kind made in a ~usy section, at fairs, at carnimls or markets, bring as high as $12.00 worth of sales in an hour, which can mean as much as $7.95 in profits to you. • • • Depending on the size of your territory and tbe number of subllgents you put to work, you can make as high as $18.00 in a day, besides what lou make on your personal sales to consumers and stores and tllrough demonstrations.

"' • • this sensational new discovery affords YOU AN OPPORTUNITY 'l'O GET IN ON THE GROUND FLOOR of a gigantic, world-wide business with llrospe1·ing representatives everywhere.

Our entire plant including manufacturing department, chemical laboratories, raw material storage, offices, occupies 5 acres with three railroad sidings, • • • A. million dollar company is back of you I . PAR. 4. \Vhen in truth and in :fact said statements and representations made by said respondent with respect to its product and the earnings to be derived :from the sale thereof, were and are :false, deceptive and misleading in the :following among other particulars: 1. Agents, dealers, solicitors and other selling respondent's product cannot and do not earn up to $2.00 an hour. 2. Men and women everywhere are not making tremendous profits-- Up to 202%, or getting their share of "the Big :Money", or realizing an enormous margin of profit on quick easy sales. d 3. Investments o:f $1.50 are not building themselves into tens, hunreds and thousands of dollars in just a short time. ,, 4. Every demonstration of respondent's product does not make sales and profits galore".

5. Territories in which respondent's product has not been sold are not "gold mines, ready :for digging".

6. Profits to the sellers o:f respondent's products are not "guaranteed'' nor have they a :fortune to gain which they cannot lose. 1168 FEDERAL TRADE COl\Il\IISSION DECISIONS Complaint 24F.T. C.

7. Salesmen are not being made "independent" in handling respondent's product, nor are they earning as much as they want, nor are the amounts of earnings limited only by their own effort. 8. One-second demonstrations do not cause prospective purchasers to buy.

V. Agents and sellers cannot and do not make as much as $2.00 in an hour at once by acting quickly or otherwise, beginning the first day; nor $12.00 an hour nor $18.00 in a day. 10. The sale of respondent's product is not providing and has not provided homes, cars and bank accounts for men and women sell· ing such product.

11. A few sales an hour of respondent's product will not pay $30, $50, $80 and more a week, and beginners are not so s\vamped with orders that they must hire sub-agents to help handle their business. 12. Earnings up to $5,000 in a year are not reached by "quite !t few."

13. Respondent's business is not "a gigantic, world-wide business with prospering representatives everywhere"; and no million dollnr company, including chemical laboratories, occupying 5 acres and having three railroad sidings, is back of those selling respondent's products.

14. Respondent's product is not crack-proof, nor water-proof, nor permanent, nor does it renew trunks, luggage, school bags, shopping bags, brief cases, leather upholstery and cushions, auto tops, harness, and other articles of leather.

15. Respondent's product cannot and does not make scuffed shoe tops look as neat and good as "the day they left the factory" or mal{e old shoes like new for 2¢ and 6¢ respectively. 16. The "attractive, polished, glowing neatness of brand new shoes'' is not restored to old uppers of shoes by use of respondent's product no matter ''how soiled, discolored, scuffed, scratched or faded the old uppers may be."

PAR. 5. Among the competitors of respondent referred to in par:J.· graph 1 hereof, there are those who manufacture anu sell in contlmerce products like or similar to those sold by respondent, and ,\"Ito do not make false, misleading, and extravagant claims and repre· sentations concerning such products, but advertise and represent tht> same fairly and accurately.

PAR. 6. Respondent by the use of the hereinbefore described nd· vertising in interstate commerce has thereby falsely represented to prospective agents, salesmen, dealers, or others, that large or sub· stantial sums of money are being or could be easily and quickly mttde in the sale of its said product, when in truth and in fact the selling PERFECT l\IANUF ACTURING CO. 1169 11G3 Findings Possibilities and sale qualities thereof are not and never have been of t.he character represented, and respondent has further, as herein shown, falsely represented in advertising matter the nature, character and qualities of its said product.

. lly the use of these false and misleading repi:·esentations appearing ln respondent's circulars, bulletins, sales talks, or instructions, ad- Veltisements in trade magazines and in other advertising matter employed by respondent, which representations are passed on to the Purchasing public by salesmen, agents, and dealers selling respond- \!Jlt's product, the consuming public and those induced to sell such Vtoduct, are and have been thereby deceived concerning the character and qualities of the said product and the uses to which i~_,properly and successfully may be put, and are and have been thereby induced to purchase respondent's product under the erroneous belief that the false and extravagant claims made for it are and were true. The ~foresaid practices of respondent are :further to the detriment and lnjury of manufacturers and sellers of products similar to those sold by respondent, and have had the capacity and tendency to divert to respondent the trade of competitors engaged in selling in interstate commerce products of the nature of that sold by respondent, and 'Vho fairly and accurately advertise and represent such products. PAn. 7. The above false, misleading, and deceptive acts, practices and methods of respondent under the circumstances and conditions hereinabove alleged are unlawful and constitute unfair methods of <:ompetition within the intent and meaning of Section 5 of an Act of Congress entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes." REPORT, FINDINGS As TO TIIE FACTs, AND Onder Pursuant to the provisions of an Act of Congress, approved Sep· te~ber 26, 1914, entitled "An Act to create a Federal Trade Comlh.Ission, to define its powers and duties, and for other purposes," ~he Federal Trade Commission on the 14th day of August 1936, 18~Ued and on the 17th day of August 1936, served its complaint in this proceeding upon respondent, Perfect Manufacturing Company, charging it with the use of unfair methods of competition in comlh.erce in violation of the provisions of said act. On September 5, 193G, the respondent filed its answer in this proceeding. Thereafter, ~ stipulation was entered into whereby it was stipulated and agreed hat a statement of facts executed by the respondent through its <:ounsel, Messrs. Paxton and Seasongood, and by ,V. T. Kelley, Chief Counsel, of the Commission, subject to the approval of the Commis- 1170 FEDERAL 'I'TRADE COMMISSION DECISIONS Findings 24F.T.0· sion, might be taken as the facts in this proceeding and in lieu of testimony in support of the charges stated in the complaint, or in opposition thereto, and that the said Commission might proceed upon said statement of facts to make its report, stating its findings as to the facts (including inferences which it might draw from said facts), and its conclusion based thereon and enter its order dispos· ing of the proceeding without the presentation of argument or the filing of briefs. Thereafter this proceeding regularly came on for final hearing before the Commission on said complaint, answer and stipulation, said stipulation having been approved and accepted, and the Commission having duly considered the same and being now fully ad-v-ised in the premises, finds that this proceeding is in the interest of the public and makes its findings as to the facts and its conclusion drawn therefrom:

FINDINGS AS TO THE FACTS PARAGRAPH 1. Respondent, Perfect Manufacturing Company, is a corporation organized, existing, and doing business under and by virtue of the laws of the State of Ohio, with its principal office and place of business located at 3325 Madison Road, in the city of Cin· cinnati, Ohio. Respondent is now and for more than two years last past has been engaged in the business of manufacturing and selling to the purchasing and consuming public in various parts of the United States, through the use of trade name companies, vari· ous appliances, products, and preparations. Among such is a liquid finish for shoes, made in different colors, known and designated ns "Sav-An-Upper." The said preparation, Sav-An-Upper, is manu· factured in Cincinnati, Ohio, where it is branded, labeled, and packed for sale and distribution by respondent trading under the naroe "Sav-An-Upper Company," and by its agent-salesmen, to the pur· chasing and consuming public in the United States. In consummat· ing such sales and in distributing such product, respondent causes the said shoe finish to be transported and delivered from its place of business in Cincinnati, State of Ohio, through and into variong other States of the United States to the respective purchasers thereof at their respective points of location. . PAR. 2. Respondent, in the course and conduct of its business, 19 now, ami has been at all times mentioned herein, engaged in sub· stantial competition with other corporations, and with firms and individuals likewise engaged in the manufacture, sale and distribu· tion of liquid finishes for shoes in commerce between and among the various States of the United States.

PERFECT MANUFACTURING CO. 1171 1163 Findings PAR. 3. Respondent, in the course and conduct of its said business, and as a means of obtaining the services of agent-salesmen to handle and sell its product "Sav-An-Upper" causes and has caused advertisements to appear in sales magazines and periodicals having a general circulation throughout the United States and in addition distributes and has distributed to prospective agents, circulars and other mail matter containing sales talks and instructions. The representations contained in said advertisements distributed as aforesaid among agent-salesmen throughout the United States are and have been eventually communicated to customers and consumers, actual and Prospective.

PAn. 4. Respondent, in the course and conduct of its business, in circulars, bulletins, sales communications and through other advertising media having general circulation, has made various claims, statements and representations concerning its product ''Sav-An- !J'paper." In certain of its advertisements respondent represents that lts product "Sav-An-Upper" has unusual sales appeal, or that selling qualities or possibilities of "Sav-An-Upper" are most exceptional and that large sums of money may commonly or easily be made by agents in handling and selling such product. In certain other statements and advertisements, respondent makes various representations concerning the permanent, wearing, lasting, and restorative qualities of the said product and concerning the size, scope, and character of respondent's business. Typical of the representations contained in said advertising matter of respondent, are statements that men and "'women everywhere are making tremendous profits, up to 202%, in ~he sale of "Sav-An-Upper," that an investment of $1.50 can build Itself into tens, hundreds, and thousands of dollars in just a short \\rhile, that earnings up to $5,000 a year should be reached by quite a few, and other statements of like import and effect. In other statements it is represented that "Sav-An-Upper," when applied, has !he characteristic of permanency and will renew articles to which it Is. applied, such as trunks, luggage, school and shopping bags, or "'Ill make scuffed shoe tops look as neat and good as the day they left the factory, or that when applied to old shoes they can be made to look new for as little as 2¢ to 6¢ respectively, and that old shoe 11Papers to which "Save-An-Upper" is applied, no matter how soiled or discolored, scuffed, scralched, or faded, will be restored to the glowing neatness of brand-new shoes. Further typical of respond- ~nt's representations are representations to the effect that respondent Is, owns or operates a million dollar company which is, or will be, hack of the salesmen selling its product "Sav-An-Upper," and that 1172 FEDERAL TRADE COl\Il\fiSSION DECISIONS Findings 24F. T.C.

such company has a world-wide business and prospering agents everywhere.

PAR. 5. The statements and representations made by respondent in selling and offering for sale its product "Sav-An-Upper" were, and are, false, deceptive, misleading, and exaggerated in various particulars. Respondent's product does not possess the sales appeal or possibilities that are being and have been claimed for it. Agents and salesmen can not and do not realize, as a result of the sale of said product, the large earnings and profits that have been held out to them by respondent as an inducement to have them handle and undertake the sale of said product. The respondent does not own, control or operate any million dollar company or business with world-wide trade or connections or any company or business even approximating such financial size, status or importance, and re· spondent's product "Sav-An-Upper," when applied to objects, does not produce or impart a coating which is permanent in character or which can or will renew or restore objects, no matter how old, worn or scuffed they may be, to a new or like-new condition. PAR. 6. Among the competitors of the respondent referred to in paragraph 1 hereof, there are those who manufacture and sell in commerce, products like or similar to those sold by respondent, and who do not make false, misleading and extravagant claims and represen· tations concerning such products, but advertise and represent the same fairly and accurately.

PAR. 7. The use of the hereinbefore mentioned false and misleading representations on the part of respondent and its agents, which are typical of the methods employed by respondent in the sale and offer· ing for sale of its product, the said liquid finish for shoes known and designated as "Sav-An-Upper" has had, and now has, the tendency and capacity to cause agents and salesmen to form the mistaken and erroneous beliefs that a million dollar company, with a world-wide business and prosperous agents everywhere, is back of them, that the product has a selling power or appeal which it does not possess, and that large and substantial profits can be earned from the sale thereof· The use of respondent's representations has further caused members of the purchasii1g public to form mistaken and erroneous beliefs concerning the character and qualities of the said product and the uses to which it properly and successfully may be put. Salesmen and agents have thereby been induced to handle and sell respondent's product and members of the purchasing public have thereby been induced to purchase said product under the erroneous belief that the misleading and extravagant claims made for it are and were true. PERFECT MANUFACTURING CO. 1173 1103 Order The aforesaid representations and practices of respondent are further t? the detriment and injury of manufacturers and sellers of products Similar to that sold by respondent and have the capacity and tendency Unfairly to divert to respondent the trade of competitors engaged in selling in commerce among and between the various States of the Dnited States and within the District of Columbia products of the nature of that sold by respondent, and who fairly and accurately advertise and represent such products.

CONCLUSION The aforesaid acts and practices of the respondent, Perfect Manufacturing Company, a corporation, 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, 1914, 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 Comlnission upon the complaint of the Commission, the answer of respondent, and the agreed stipulation as to the facts entered into between the respondent herein, Perfect Manufacturing Company, and W. T. Kelley, Chief Counsel for the Commission, which stipulation ~rovides, among other things, that without further evidence or other Intervening procedure, the Commission may issue and serve upon the respondent herein findings as to the facts (including inferences ':'which it may draw from the said stipulated facts) and the conclu- Sion based thereon and an order disposing of the proceeding, and the Coilllnission having made its findings as to the facts and conclusion that said respondent has violated the provisions of an Act of Congress approved September 2G, 1914, entitled "An Act to create a li'ederal Trade Commission, to define its powers and duties, and for other purposes."

It i8 ordered, That the respondent, Perfect Manufacturing Company, its officers, representatives, agents, individual or corporate, and It~ employees, in connection with the offering for sale, sale, and dis:. ~~lb~ition in interstate commerce or in the District of Columbia of a Iqtnd finish or product for shoes known as "Sav-.An-Upper-," or designated or described under any other name, do forthwith cease and desist from:

1174 . FEDERAL TRADE COl\11\USSION DECISIONS Order 24F.T.C.

1. Representing that agents or salesmen can or do earn or have ever earned certain specified sums daily, weekly, monthly, or for or during any stated period of time through the sale of respondent's said product unless and until said agents or salesmen actually have so made the earnings stated;

2. Representing that respondent's product when applied to objects possesses and imparts the quality, effect or condition of permancy, or has the renewing and restoring qualities or characteristics, which have been ascribed to it by the respondent, and which it does not possess.

3. Representing that respondent is a million dollar company, and that it has assets or a volume of business or business connections or operations substantially in excess of those which it actually possesses. It is further onlered, That the respondent shall, within GO days after service upon it of this order, file with the Commission a report in writing setting forth in detail the manner and form in which it has complied with this order.

FOOD DISPLAY MACHINE CORP. 1175 Complaint