Bible Institute, the, Etc. et al

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IN THE l\fATfER OF ll. W. LEDERER AS PRESIDENT OF THE DIBLE INSTI- ' TUTE, ETC., ET AL. COhJpLAINT, FINDINGS, AND ORDER IN REGARD TO THE ALLEGED VIOLATION 01<' Sli:C, 5 OF AN ACT OF CONGitESS APPROVED SEPT. 26, 1914 Docket ,9687. Complaint, Jan. 29, 19,92-Decision, July 9, 19,92 Where the president and principal owner of the common stock of three cor- Dot·ations, engaged in the interstate sale and distribution of (1) Dibles, Prayer books and other religious pnlllications, which they had emllossed With the names of purchasers by a stamping concem having the same office and principal place of business as themselves, and which, sold by them Principally to tuneral parlors, were distributed by latter to Sunday School chl!tlren us u means of allvertlsing; and (2) hand-hag mirrors purchased from a dealer in New York City which they had similarly embossed with ·names of purchasers, and which, sold by them to such pm·chasers as cafes, ( .' night clubs and banks, were distributed by latter to their own customersa) Adopted the name of."The Bible Institute, Inc.," for one of said corporations, nnd "The Bible Institute" for its corporate successor, to deceive the buying PUblic Into the belief that they were religious Institutions dedicated to the same wot·thy purposes as the reputable Dible Institutes, thereby permitting them to make wide distribution of their publications at nominal prices, and to conceal the fact that they were C01'110I'atlons formed to l.Juy and sell Inexpensive Bibles, prayer books and other religious publications ·Solely for pre fit; and (b) Adopted for afor·esald third corporation the name of "American Plate Glass . Co." for the purpose of llereivlng the buying public Into the belief that it Was a manufacturer o! glass products, Including hand-hag mlrrot·s, thereby enabling It to make )ower pri!'eS than would be possible otherwise, when In fact It purchased such mirrors ft·om a dealer for· resale; and '\\There the saiesmen und solicitors of said two "llible Institutes," including its said president- (c) Falsely represented, through use of said corporutions' deceptive and misleading let-terheads nod nllvertising, that sa ld two corporations were religious institutions and Identified with the reputable Bible Institutes; that a J. C. l\lacDonald was "trustee" therefor; and that they furnished free Sunday School distribution of religious publications; and represented falsely also that they were endowed hy philanthropic interests which }lermitted them to make a wide distribution thereof; and 'Vhere the salesmen and solicitors of said third corpomtlon, Including its said president, In selling such hand-bag mirrors to the purchal;liug public- (d) Falsely represented, through the use of said "American Plate Glass Co." letterheads und advertising material, that it _was a large glass manufacturer with plants and advertising offices In Pittsburgh, Chicago, and New Yorlc; and that It had a number of depnr'tments and a superintendent named J. C. MacDonald; and represented falsely also that it was affiliated with a large and well-known Pittsburgh plate-glass company, and that It manufactured said mirrors ;

122 FE,P,]i:RAL TRADE COMMISSION DECISIONS Complaint . 35F. T.C. The facts being It had no more than three employees, its salesmen above referred to; did not manufacture, but purchased such mirrors; and Us various representations aforesaid were false; - . With effect of misleading and deceiving a substantial portloa of the purchasing \ public into the belief that said representations were true, thereby Inducing \ the purchase of products in question: . · Held, That such acts and practices, under the circumstances set forth, v.·ere all \ to the prejudice and injury of the public, and constituted· unfair and de- i cept~ve acts and practices in commerce. • · Defore Mr. lV. lV. Sheppard, trial examiner. ill r. [( (lrl E. Steinhauer for the Commission. llir. Morton Brislcin, of Hollywood, Calif., and J(irlcland, Fleming, Green, M(J/f'tin & Ellis, of Washington, D. C.,.for respondents. Complaint 1 .

J->ursuant to the provisions of the Federal Trade Commission Act, and by virtue of the authority vested in it by said act, the Feder~l Trade Commission having reason to believe that H. \V. Lederer, indi· vidual_ly, and aspresident of The Dible Institute and American PJate Glass Co., respectively, and The Dible Institute, a corporation, and American Plate Glass Co., a corporation, hereinafter referred to ns respondents, have violated the provisions of said act, and it appearing to the Commission that a proceeding by it with respect thereof would be· in the interest of the publi_c, hereby issues its complaint, stating its charges in that respect, as follows: · . · P ;\R.\GR.\FII 1. Respondent, II. \V. Lederer, is president and salesman . of both respondents, The' Dible Institute and American Plate Glass Co., the principal owner of the common capital stock of both of said corporations, and· controls the policies and activities of both of said corporations, including the conduct of sales and the character of advertising representations made in connection therewith. Respond~ ent, The llible Institute, is a New York corporation, and respond~nt, American Plate Glass Co., is a Delaware corporation, both of said companies having their principal office and place of business located at 224 West Thirty-fourth Street, in the city of New York, State of New York. . PAn. 2. Respondent, II. \V. Lederer, through said respondent, The Dible Institute, and respondent, The Dible Institute, are now and for several years last past have been engaged in the sale, transportation lind distribution for profit in interstate commerce of cheap editions of llibles, prayer books, and other religious publications, principally . ' . . i ----• 1 Dy OJ'!lor dated lllay 21, 1942, In response to reapondenh' motion, ns more fully set forth at p. 126 of the tln!llnJ:s, The llihle Institute, a Delaware corporRtlon bavin'l wntved formal ameudment nnd ~ervlce upon It of the eompla.int, was a!l.ded as a party respondent. · THE BIBLE INSTITUTE, ETC., ET AL. 123 Complaint ~·funeral parlors. Said r~sponde~ts have said publications embossed . lth the names of the purchasers by a stamping concern whose office ~s t~le same as the one designated as the principal office and place of S n~ss of respondent, The Dible Institute,in the city of New York. std funeral parlors, in turn, distribute the publications to selected llnday School children as a means of advertising. PAn. 3. Resi-londent, H. \V. Lederer, through said respondent, A.Jnerican Plate Glass Co., and respondent, American Plate Glass Co., :re now and for severo,! years last past have been engaged in the sale, transportation and distribution in interstate commerce of hand .. bag lllirrors .which they purchased from a dealer in New York City for r:sale to purchasers in the various States, umong whom are cafes, ~Jght clubs, and banks, which in turn distribute them to their cus- 0111ers as a means of advertising. Saidrespondents have the names of Stich purchasers embossed on said hand-bag mirrors by a stamping concern whose office in New York City is the same as the one desig- ~ated as the principal office and place. of business of respondent, 111erican Plate Glass Co. · b PAn. 4. In the course and conduct of their businesses, as hereindare described, each of the said respondents, The Dible Institute and American Plate Glass Co., employed and utilized the services of ;rProximately three salesmen or solicitors, including said respondent, l .· \V. Lederer, who canvassed individual _prospective customers ocated in various States of the United Stutes. When orJcrs are ~ceived by such solicitor~ or snJesmen, the orders are forwarded to the ew York office of the said corporate respondents, and the wares Called ·for therein are then shipped directly to the purchasers through· ou~ the various States from th~· ~t~ck on hand purchased for that ~Urpose by said respondent, H. "\V. Lederer, for said corporate, respondents. ' ·. PAn. 5. In order to facilitate and effect the sales of its cheap editions of Dibles, prayer books and other religious publications, the said respondent, H. W. Lederer, adopted the name of The Dible Insti~ !lite for that respondent ~or the purpose of deceiving the buying public ~llto the belief that the said The Dible Institute was and is a religious Institution dedicated to the same worthy purpose!;) for which 'the. reputable Dible Institute throughout the Stutes were orgunl.zed, which t~lereby permitted respondent to make a wide distribtltion of publications at nominal prices, and to conceal from the said buying public the fact that the said The Dible Institute was merely a corporation formed t? buy· and sell cheap Bibles, prayer books and other religious 'publica- . hons solely for profit to its customers throughout the various States Of the United States. · . · . 124 FE.DEUAL TRADE COMMISSION DECISIONS Complaint · 35F. T.C. PAR. 6. In order to facilitate and effect the sales of hand-bag mir· rors, respondent, H. ,V. Lederer, adopted the name of American Plate Glass Co. for that respondent, for the purpose of deceiving the buying ·public into believing that respondent, American Plate Glass Co., wus .a manufacturer of glass products, including said hand-bag mirrors, which thereby enabled respondent to make lower prices than would he possible otherwise, and to conceal from said buying public that respondent merely purchased said hand-bag mirrors from a dealer in New York City for resale to purchasers throughout the various States of the United States.

PAR. 7. The salesmen and solicitors of respondent, The Dible Insti· tute, including the respondent, H. \V. Lederer, have used the following means and methods in soliciting the sale of and in selling its said publications to tJ1e consuming public;

1. Said agents and solicitors have knowingly given the false irn· pression to prospective purchasers, through the use of said respond· .ent's deceptive and misleading name and respondent's deceptive and misleading letterheads and advertising, that the said· respouclent, The Dible Institute, is a religious institution and is one of the worthy .and reputable Dible Institutes located throughout the United States, and that a J. C. MacDonald is "trustee" for said respondent, and thltt respondent furnishes a free Sun<;lay School distribution of religious publications, whereas,. on the contrary, said respondent is not .11 religious organization, its operations being conducted solely for profit, .and it is not identified with any other Dible. Institute in the country Itml is not engaged in any of the worthy causes for which such other Dible Institutes were organized, and it does not have any persoll named J. C. MacDonald on its pay roll, or at all, and does not have a "'trustee," but only uses such title to conceal from the buying public the mercenary character of the business of said respondent, The Diblo Institute, and said respondent does not furnish a free distribution of its publications. · 2. Said agents and solicitors have falsely represented to prospective purchasers that said respondent, The Bibleo Institute, is a religious institution; that it is identified with other institutions in various States of the country having the same or a similar name; that it is endowed by philanthropic interests which permit·said respondent to make a wider distribution of bibles, prayer books, and other religious publications; whereas, on the contrary, respondent is not a religious institution and is not identified with other institutions throughout the various States having the same or a similar name, and is not endowed by philanthropic interests, or at all. THE BIBLE INSTITUTE., ETC., ET AL. 125 12! Findings G p Alt. 8. The salesmen and solicitors of respondf'nt, American Plate f lass Co., including the respondent, H. vV. Lederer, have used the allowing means and methods in soliciting the sale of and in selling its 1 trtnd-bag mirrors to the purchasing public. · 1. Said agents and solicitors have knowingly given the false im- P~ession to prospeptive purchasers, through the use of respondent's · lnlsleading and deceptive name and respondent's misleading and de- ~Ptive letterheads and advertising, that said respondent, American t' late Glass Co., is a large glass manufacturer with plants and advf'ralsing offices in Pittsburgh, Chicago, and New York, and that it has. Mnun1ber of departments, and has a superintendent named J. C. acDonald, whereas, on the contrary, said. respondent is not a glass lnanufacturer and has no plants or departments or advertising offices, ~nd not more than three employees, all of whom are salesmen, includ- Ing respondent II. '\V. Lederer, and has no superintendent, and has no J. C. MacDonald. · t' 2. Said agents and solicitors have falsely represented to prospeclve purchasers that said respondent is affiliated with the large and ~ell known Pittsburgh Glass Co. and that it manufactures the handa.g rnirror which is the only article it sells, whereas, on the contrary, sald respondent is not affiliated with said Pittsburgh Glass Co., or uny Other glass company; and it does not manufacture the hand-bag mirrors Which it sells as aforesaid, but m~rely purchases the snme from some dealer in New York City for purposes of resale. , PAn. 9. The acts and practices o:f the respondents as above alh,ged, 111 the course of selling and offering for sule their wares in commerce as hereinabove described, are calculated to have the capacity and tende~cy to, and do, mislead and deceive a substantial portion o:f the pure asing public into the erroneous belief, that said false, mislt>ading llnd deceptive representations are true, thereby inducing the purchase of respondents' wares. .

h P ~n. 10. The foregoing nets and practices of the respondents, as erem alleged., are all to the prejudice and injury of the public and c1onstitute unfair and deceptive acts and practices in commerce within t te intent and meaning of the Federal Trade Commission Act.· REPORT, FINDINGS AS TO THE FACTS, AND ORDER Pursuant to the provisions of the Federal Trade Commissio~ .Act, the Federal Trade Commission; on the 2Dth day of J auuury, A. D. ~942, issued and on the 3d day of February 1942, served its complaint 1ll this proceeding upon respondents, II. '\V. Lederer, individually, and as president of The Bible Institute, Inc., a New York corporation, 509749'"-43-vol. 311-11 126 FEDE,RAL TRADE COMMISSION DE·CISIONS Findings 35F. T.C.

and American Plate Glass Co., a corporation; The Bible Institute, l Inc., a New York corporation; and American Plate Glass Co., a cor· ' poration, charging them with the use of unfair and deceptive acts and ~~ practices in commerce in violation of the provisions of said net. After the issuance of said complaint and the filing of respondents' answer,. I the Commission permitted the respondents to file herein an amendment Ito said answer withdrawing the specific and general denials therein l contained and admitting all. of the material allegation:;; of. fact set :forth in said complaint except as the same may be qualified by aver· ~ents of fact set out in said answer other than the averments of fact contained in paragraph 5 thereof, and waiving all intervening pro·· cedure and further hearing on the said material allegations of fact set forth in said complaint. Later, respondents offered for filing, and the same was thereafter filed, a stipulation that The Bible Institute, !l Delaware corporation, may be added as a party respondent herein, for the reason that the busines's and business operations of respondent, The Bible Institute, Inc., a New York corporation, were discontinued on ,July 12, 1941, at which time The Bible Institute, a Delaware corpora· tion, was incorporated under the laws of that State to take over and continue the business and business operations of the said respondent,· The Bible Institute, Inc., a New York corporation, which business and business operations it still continues. At the same time, all of the respondents herein filed a stipulation and agn•Pment making the answer and amendment to answer theretofore filed herein by respon· dents, II. '\V. Lederer, The Bible .Institute, Inc., a New York Qorpora· tion, and American Plate Glass Co. the answer and' nmf.'nument to answer of all of said respondents. Thereafter, this proceeding regu· lnrly came on for hearing before the Commission, and the Commission having duly considered the matter and being now fully advised 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 Tile FACTS PARAGRAPH 1. Respondmt, H. '\V. Lederer, is an individual, "'itb his principal Qffice and place of business located at 224 West Thirty· fourth Street, in the city of New York, State of New York, and is president of respondents, The Bible li1stitute,. Inc., The Bible Institute, and American Plate. Glass Co., the principal owner of the common capital stock of said corporate respondents, and controls the policies and activities of said corporations, including the conduct of sales and the character of advertising and other representations made in con· nection therewith. . , 1 • THE BIBLE INSTITUTE., E.T.C., ET AL. 127 . 121 Findings ~e~p~ndent, The Bible Institute, Inc., is a corporation orga1_1ized and e~Istmg under and by virtue of the laws of the State of New York,. Wtth its principal office and place of business at 22-1 West Thirtyfourth Street, in the city of New York, State of New York. ~e~pondent, The Dible Institute, is a corporation organized and e~tsbng under and by virtue of the laws of the $tate of Delaware, "'tth its principal office and place of business at 224: West Thirtyfourth Street, in the city of New York, State of New York. . Uaspondent, American Plate Glass Co., is a corporation organized n~d existing under and by virtue of the laws of the State of Delaware,. Wtth its principal office and place of business at 224: West Thirty-. fourth Street, in the city of New York, State of New York. l P.:n. 2. Respondent, H. W. Lederer, through respondent, The Dible nstttute, Inc., and respondent, The Bible Institute, Inc., for several t~a:s lust past have been engaged in the sale, transportation, and distri- /hon for profit in interstate commerce of inexpensive and other ecli~ ~ons of llibles, prayer books, and· other religious publications, prin- . etpaUy to funeral parlors. Said respondents have said publications embossed with the names of the purchasers by a stamping concern w~ose office is the same as the principal office and place of business of 13 ~ 1d respondents. Said funeral parlors, in turn, distribute the publica- ;ons to selected Sunday School children as a means of advertising. he New York corporation discontinued business on or abo~t July 12, t"9H,1 and was succeeded by The Dible Institute, a Delaware corporut~on organized by respondent, H. 1V. Led~·er, to continue the business leretofore conducted by the New York corporation. The Delawam corporation continued to use the acts, practices, and methods used by l'e~pondent, The Dible Institute, Inc., the New York corporation, Prtor to its discontinuing business.

PAn. 3. Respondent, H. 1V. Lederer, through said respondent, American Plate Glass Co., and respondent, American Pbte Glass Co., :re 'now and for several.l years last past have been engaged in the sale, r~nsportation, and distribution in interstate commerce of hand-bag mirrors, which they purchase from a dealer in New York City for r~sale to purchasers in the various States, among whom are cafes, ~Ight clubs, and banks, which in turn distribu,te them_ to their cns- 0ll1ers as a means of advertising. Said respondents have the name~ ?f such purchasers embossed on 'said hand-bag mirrors by a stamp- Ing. concern whose office in New York City is the s~me as the one designated as the principal office and place of business of respondent, American Plate Glass Co. , d PAR. 4. In the course and conduct of their busiri~ss, as hereinbefore ,escribed.~ each of the said respondents, The Dible Institute, Inc., The . • I·128 FEDERAL TRADE COMMISSION DE-CISIONS Findings 35 F. T. C. I:. Dible Ins.titute, and American Plate Glass Co., have employed and '• utilized, and now employ and utilize, the services of approximately ! three salesmen or solicitors, including respondent, H. W. Lederer, who canvassed, and now canvass, individual customers located in various I. States of the United States. 'Vhen orders are received by such so· licitors or salesmen, the orders Are forwarded to the New York office ! of the said corporate respondents, and the wares called for therein are then shipped directly to the purcha~ers throughout the various States from the stock on hand purchased for that purpose by respond· .ent, H. ,V, Lederer, for said corporate respondents. PAR. 5. In order to facilitate and effect the sales of said Bibles, -prayer books, and other religious publications, the said respondent, :n. W. Lederer, adopted the name of The Dible Institute, Inc., for that 1·respondent and the name The Bible Institute for its successor, for the purpose of deceiving the buying public into the belief that the re· spondents were and are religious institutions dedicated to the same worthy purposes for which the reputable Bible Institutes throughout the United States were organized, which thereby permitted them to make a wide distribution of publications at nominal prices, and to conceal from the said buying public the fact that said respondents were merely corporations formed to b\lY and sell inexpensive and other Bibles, prayer books, and other religious publications solely for profit to their customers throughout the various States of the United States.

PAR. 6. In order to facilitrrte and effect the .srrles of handbag mirrors, respondent, II. ,V, Lederer, adopted the name of American Plate Glass Co. for that respondent for the purpose of deceiving the buying public into believing that respondent, American Plate Glass Co.., was a manufacturer of glass products, including said hand-bag miTl'ors, which thereby enabled said respondent, American Plate Glass Co., to make lower prices than would be possible otherwise, and to conceal from said buying public that said respondent merely pur· chased said hand-bag mirrors from a dealer in New York City for resale to purchasers throughout the various States of the United States.

PAR. 7. The sale~men and solicitors of res.pondents, The Bible In· ·£titute, Inc., and The Bible Institute, including the respondent, II. ,V. Lederer, have used the following means and methods in soliciting the sale of and in selling their said publications to the consuming public.

(a) Said agents and solicitors have knowingly given the fall:e im· pression to prospective purchasers, through the use of their deceptive :and misleading letterheads and advertising, that respondents,· The. THE BIBLE INSTITU'fE, E.T.C., ET AL. 129 121 Findings ~ible Institute, Inc., and The Dible Institute, are religious institutions and identified with the worthy and reputable Bible Institutes located throucrhout the United States, and that a J. C. MacDonald is "t b . rustee" for said institutes and- that said respondents furnish a free Sunday School ·distribution o£ religious publications, whereas, on the .contrary, said respondents are not religious institution~ or organizatons, their operation.s being conducted solely for profit, and they are not identified with any Dible Institute in the country and are not engaged in any of the worthy causes for which such Dible Institutes Were organized an.d they do not have any J. C. MacDonald in their CllJ.ploy, and they do not have a trustee, but only use such title to conceal from the b~ying public the mercenary character of the busin:ss of said respondents; and said respondents do not furnish a free distribution of their publications. . . (b) Said agents and solicitors have falsely represented to prospectrve purchasers that said respondents, The Dible Institute, Inc., and 1?e Bible Institute, are religious institutions; that they are identified 'With other institutions in various States of the country having the sa:rne or similar names; that they are endowed by philanthropic inte~~:sts which permit said respondents to make a wide distribution of lhbles, prayer books, and other religious publications; wh~areas, on the ~ontrary, said respondents are not religious institutions and are not Identified with other institutions throughout the various Stutes having ~he same or similar names, and are not endowed by philanthropic Interests, or endowed at all.

G PAR. 8. The salesmen and solicitors of respondent, .American Plate f lass Co., including and respondent, II. "\V. Lederer, have used the l ollowing means and methods in soliciting the sale of and in selling ·land-hag mirrors to the purchasing public.

(a) Said agents and solicitors have knowingly given the false imlression to prospective purchasers, through the use of respondent, lllerican Plate Glass Co.'s letterl1eads and advertising, that said re- . spondent, American Plate Glass Co., is & large glass manufacturer with l?lants and advertising offices in Pittsburgh, Chicago, and New York, llnd that it has a number of departments, and has a superintendent ~atned J. C. MacDonald, whereas, on the contrary, said respondent 18 not a glass manufacturer and has no plants or departments, or advertising offices, and has not more than three employees, all of whom ~re salesmen, including respondent, II. ·w. Lederer, and has no superlntendent and has no J. C. MacDonald .

. (b) Said agents ,and solicitors have falsely represented to prospccbve purchasers that said respondent, American Plate Glass Co., is FEDERAL TRADE COMl\HSSION DECISIONS. lI Order 35 F. T. C. ~ II.affiliated with a large and well-known Pittsburgh glass manufactur· ing company and that it manufactures the hand-bag mirrors which are the only articles that it sells, whereas, on the contrary, said · ,. respondent is not affiliated with any glass manufacturing company; and i"t does not manufacture the hand-bag mirrors which it sells as 1 1aforesajd, but purchases same from dealers in New York City for pur· I poses of resale.

PAR. 9. The acts and practices of the respondents as above found, ·l in the course of selling and offering for sale their wares in commerce 1. as hereinabove described, have the capacity and tendency to, and do, mislead and deceive a substantial portion of the. purchasing public ! into the erroneous belief that said false, misleading and deceptive representations are true, thereby inducing the purchase of respond· ents' wares. ' · CONCLUSION The aforesaid acts and practices of the respondents, as herein found, are all to the prejudice and· injury of the public and constitute unfair and deceptive acts and practices in commerce within the intent and meaning of the Federal Trade Commission Act: ORDER TO CEASE AND DESIST 'I'his proceeding havingbeen heard by the Federal Tr~de Commis· sion upon the complaint of the Commission, the original answer and amended answer of respondents, in which amended answer respond· ents withdraw the specific and general denials of fact set forth in said original answer with certain exceptions, admit all of the material aile· gations of fact in said complaint with certain qualifications, and waive all intervening procedure and further hearing as to said facts, and a stipulation executed by all of said respondents, and the Commission having made its findings as to the facts and conclusion that said respondents have violated the provisions of the Feder11l Trade Commission Act. . · . It is ordered, That respondent, H. ,V, Lederer, his representatives, :agents and employees, directly or through respondent, The Bible Institute, Inc., The Bible Institute, or any other corporate or other rl.evice, and respondents, The Bible Institute, Inc., and the Bibleinsti:· tute, their officers, agents and employees, in connection .with the offer· ing for sale, sale or distribution of Bibles, prayer books and other z·eligious or other publications in commerce, as "commerce" is. defined in the Federal Trade Commission Act, do forthwith cease and desist from:

THE BIBLE INSTITUTE•, E.TC., ET AL. 131 Order 1. Using the word "Institute" as part of the trade or corporate ~;me. under which their said business is coriducted, or using the word nstttute" or any word of similar import, to, in any way describe or .tefer to Baid business.

2·. Representing in any manner or by any method that said respondents ar~ engaged in work of a religious nature, or that they are conhected with any institution. . · 3· Representing in any manner or by any method, that the busihers of said respondents is conducted by 11 trustee. 4· Represen.ting in any manner or by any method that said responde~ts furnish free religious publications for Sunday Schools or other c urch activities.

5· Representing in any manner or by any meth9d that the businesfl co~ducted by said respondents is endowed by philanth~·opic or any ot er interests in order. to. permit a wider distribution of religious Pllblications, or for any other purpose. · · · It iB fwrther ordered, That respondent, H. ,V. Lederer, his repre- ~ntath es, agents and solicitors, directly or through respondent, tn.ericun Plate Glass Company, or any other corporate or other 1 c evice, and respmident, American Plate Glass Company, its officers, agents and employees, in connection w·ith the offering for sale, sale or distribution of hand-bag or other mirrors or glass products iq com- ~<'rce, us "commerce" is defined in the Federal Trade Commission • et, do,forthwith cease and desist from: ' 1. Hepresenting, directly or by implication that said resp~ndents ~ro 111anufacturers of the glass products offered for sale and sold . Y them.

2. Representing, directly or by implication, that said respondents ~'"n, control, or operate plants or brunch offices in Chicago, ~11., Pittslltgh, Pa., New York City, N.Y., or elsewhere. 3. Representing, directly or by implication, that the business con- ~ltcted by said respondents is a substantial one, consisting of a numl'r of departments, and requires the services of a superintendent. :.re4. inRepresenting,any way connecteddirectly withor byanyimplication,glass manufacturingthat said respondentscompany, '<cept n~ n purchaser of glass products for resale. ,,_ It iB further ordered, That the respondents shall, within 60 days arter service upon them of this order, file with the Commission a report in writing, setting forth in detail the manner and form in \\·which they have complied with this order. . 132 FEDERAL TRADE COMMISSION DE·CISIONIS Syllabus 35F.T.C·