Baer Laboratories, Inc

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IN THE MATTER OE' BAER LABORATORIES, INC.

COMPLAINT, FINDINGS, AND ORDER IN REGARD TO THE ALLEGED Violatioll OF SEC. IS OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1014 Docket 468/i. Complaint, Jan. 29, 1942-Decision, Sept. 17, 19~2 Where a corporation, engaged in the preparation, packing, nnd interstate sale and distribution of Its "Sulfuraid-21" medicinal pt·eparatlon; by means of ad· n!rtisements In newspapers and other periodicals, and by booklets and other advertising literature, including purported testimonials, directly and throug~l inference- {a) Falsely represented that its said product, when us<·d in hot baths, was llll effective relief, preventive, and cure for muscular, particular, and ligaruentnl pain, and all other pain except headaches, including that due to rupture o! muscles, contusions, neuralgia, tubes, and tumors; abdominal spasms, pleural palos, particular rheumatism of women during their climacteric period; and pain from rheumatism, arthritis, neuritis, gout, lumbago, and nen•ous exhaustion; and , (b) Falsely represented that in such bot baths, sulphur was absorbed from the water through the skin and mucuous membrane and thus bad a general pharmacological effect; that said preparation in hot' water tended to lllake one perspire mo~e quickly and freely and aided a more rapid elimination of the body's waste products and the counteraction of ovemcidity in tne body; and that "Sulfuraid-21" was the first successful effort to create sulphur in solution;

With effect of misleading and deceiving a substantial portion of the purchasing public into the ~mistaken belief that said representations were true, thereby inducing it, because of such belief, to purchase substantial quantities o! preparation in question: . Held, That such acts and practices, under the circumstances sd f~rth, were all to the prejudice and injury of the public, and constituted unfair and deceptive acts and practices in commerce.

Before :Air. 1Veb8ter Ballinger, trial exalniner. AIr. James :AI. Hammond for the Commission.

Mr. Emanuel B. Morgans.tern, of New York City, for respondent. Complaint Pursuant to the provision~1s of the Federal Trade Commission Act, and by virtue of the authority vested in it by said act, the Federal Trade Commission, having reason to believe that Daer Laboratories,· Inc., a corporation, hereinafter referred to. as respondent, has violated the provisions of said act, and it appearing to the Commission that 11o proceeding by it in respect thereof would be in the public interest, hereby issues its complaint, stating its charges in that respect as follows:

. BAER LABORATORIESJ INC. 489 488 Complaint • PARAGRAPH 1. Respondent, Baer Laboratories, Inc., is a corporation, organized, existing, and doing business under and by virtue of the laws of the State of New York, with its office and principal Place of business located at 30 East Twentieth Street, in the city of' ~ew York, State of New York. Said respondent is now, a.nd fol" lllore than 1 year last past has been, engaged in the preparation,. Packing, sale, and distribution of a medicinal product designated by respondent as "Sulfuraid-21."

PAn. 2. Respondent causes its said product, when sold, to be trans~ Ported from. its place of business in the State of New York to purchasers thereof located in various other States of the United States 11~d in the District of Columbia. Respondent maintains, ~nd at all hllles mentioned herein has maintained a course of trade in its said Product "Sulfuraid-21" in commerce among and between the various States of the United States and in the District of Columbia. PAR. 3. In the course and conduct of its aforesaid business, the respondent has disseminated and is now disseminating, and has caused and is now causing the dissemination of, false advertisements concerning its said product "Sulfuraid-21" by the United States mails. and by various other means in commerce, as commerce is defined in the F~deral Trade Commission 'Act; and respondent has also disseminated and is now disseminating, and has causea and is now causing ~he dissemination of, false advertisements concerning its said product, 'Y 'various means, for the purpose of inducing, and which are likely to induce, directly .or indirectly, the purchase of its said product in ~nunerce, as commerce is de~ned in the Federal Trade Commission ct. . . 1 Among and typical of the false, m"misleading, and deceptive state- • lllents and representations contained in said false advertisem,ents, dis- ~elllinated and caused to be disseminated by the United States mailst l 'Y advertisements in newspapers and other periodicals, and by bookets and other advertising literature distributed among purchasers and Drospective purchasers, are the following: , · . Itheumatlsm, arthritis, neuritis or gout relieved or you pay nothing I · New Scientific Achievement. ' lj "ton know, or have beard, how the world famous natural Ilot Sulphur Springs . that?s of this country and Europe have relieved persons of the tortures of Rheuothhsm, Arthritis, Neuritis, Gout, Lumbago, Nervous Elxhaustlon, ete.,~ after all er means failed.

n Sulphur in SOLUTION which hitherto defined mao's efforts to produce is now 1\ accomplished fact. / · . . . r(>J~ndoubtedly, the most E-ffective and yet the most economie treatment for lef of arthritic pains is a bot sulphur bath at home. llh Aledical research has delved to some extent into the therapeutic action and armacolo~ticnl value of these baths. and while much still remains. to be· done ·490 FEDE1RAL TRADE COMMISSION DE·CISION'S Complaint 35 F. r,r. c. In this field, evidence of their general efficaciousness for relief of rhemuatlc diseases and other affections is established beyond the sh'lldow of a doubt. One of the most characteristic effects of sulphur water is probably the sootb· · ter !ng of pain due to the exhausting sedative action of H2S. • Sulphur wa assuages all kinds of pain, except headaches, regardless of the cause or origin. They not only stop muscular, particular and ligamenta\ pain, but pain due to rupture of muscles, contusions, neuralgia, tubes and tumors; abdominal spasDl~· pleural pains, particular rheumatism of women during their climacteric per10 1'9 etc. One active factor in the soothing of pain Is doubtless heat, but here It . uv-e not the only factor. Every sedative alleviates at the same time, since seda wes !lnd analgesic effects are closely connected, and sulphur water probably o 1ts effect of alleviating pain to the sedative etrect of H2S apart from heat. r,rbus we see that even in the alleviation of pain, sulphur baths do not merely act a~ ;ft local stimulus on the body surface. Sulphur Is absorbed from the water throug .the skin and mucous membrane and exerts a general pharmacological effect. The name given this newly-discovered product Is SULFURA.Il>-21. In this connection it Is important to remember that inhalation of the sulpbur. ''apors emitted by these baths, tends to have a cleansing action on the passnges of the nose and throat; aids in relieving congestion in these parts and bel~ make breathing easier. Anyone taking these baths is llens!ble of this plea!lfill ' clarifying effect. ·re The action of the sulphur in solution In hot watet· tends to make one persP' . quickly .and freely, and thus aid more rapid elimination of the body's wuste products and counteract overacldity. · ~-1 As has already been shown by one medical. authot·ity whom we quoted, t phuretted hot water baths probably owe their powers of alleviating palo, aP11r from heat, to the sedative effect ·of the sulphur, which Is absorbed to a degr~e .and is, therefore more than merely a local stimulus on the body surface. It 8 empirically known that absorption of the sulphur is effected through tbe sJcill and through inhalation of its vapors.

Among the noticeable effects of hot baths with SULPHURA.ID-21, aside trolll nllaylng painful symptoms, Is the dellghtful feeling of refreshment usually follo\1'; • lng them; the easing of nervous tension; the impt·oved elasticity of stiffened I joints; the sound, restful sleep they help induce, and the mot·e buoyant 11n rested feeling they Impart the morning after. 119 ·occasionally~ more than one complete course of 21 baths may be required, those who visit the Spas have found. In the majority of cases, the full C011r~~ ot SUL~''URA.ID-21. baths should be sufficient for all purposes. To help prev-e t recurrence of the aches and pains~ it is wise, however, to continue taking a !JO SULFUR-UD bath ol)Ce every ten days.

And in addition certain commendatory expressions purporting to l:il"'~ come from users of the product, typical of which are the follow111g · I prescribed -your SULFURA.ID-21 for clinical test on my Mother who 11119 . , e been sulTerlng from a very severe rheumatic fot· the past 25 years or wor · J' can, with assurance, say that it has helped her a good deal. She tells Dle it has done more good for her than the baths she took at Saratoga and )itt .Clemens. She did obse,rve that the dally baths were too weakening because 0 the rapid loss of body ftulds. When she began to take the baths two or three tims a week, the results were more favorable. r do not hesitate to prescl'''bB ~·our product .and .rec(i)mmend it very highly, BAER LABORATORIES, INC. 491 488 ' ' Complaint When one has been ·rheumatic for as many years as I have, and tried almost everything that ofrered the ·slightest hope for relief with little or no sqccess, lou will hardly blame me for being skeptical a.t first over what SULFURA.ID-21 could do for me. Were it not for the fact that I learned from a. friend how greatly she was helped by taking the baths at A.lx-le-Balns In France, I would lll'obably ·still be In ignorance of what hot sulphur baths could do for a person · In my condition. .I completed your course of 21 baths three months ago. Since then I have had no pain at all, even during wet weather, except for an occa- Sional slight feeling of discomfort, which passes almost as quickly as it comes. tour Sulfuraid-21 has proved a boon to me. With this help for my future defense against such. suffering, I can look forward to enjoying life much more fully than I have. Does it not make you happy, too, to know how much your hot sulphur baths help? With all good wishes for your success, I am Cordially yours. ' P A!l. 5. Through the use of the foregoing representations and quotations, and others similar thereto, not specifically set out herein, ~he respondent represents, and has represented, directly and through ~nference, that its said product "Sulfuraid-21" when used in hot baths, ls an effective relief, preventative, and cure for muscular, particular, and ligamenta! pain, and all other pain except headaches, including :Pain due to rupture of muscles, contusions; neuralgia, tubes, and tumors; abdominal spasms, pleural pains, particular rheumatism of ":women during their climacteric period; pain from rheumatism, arth- 1'itis; neuritis, gout, lumbago, and nervous exhaustion; that as a result of the use of said preparation in hot water baths, sulphur is absorbed from the water through the skin and mucous membrane and thus has n. general pharmacological effect; that inhalation of sulphur vapors emitted from hot baths containing "Sulfuraid-21" has a cleansing action on. air passages of the nose and throat and aids in relieving congestion in these p[_trts; that the action of said preparation in hot ~after is such that it tends to make one perspire more quickly and freely and aids a more rapid elimination of the body's waste products and the counteraction of over-acidity in the body; and that "Sulfuraid- 21'' is the first successful effort to create sulphur in solution. PAR. 6. The aforesaid representations are grossly exaggerated, false, and misleading and constitute false advertisements. In truth and in ~act respondent's said product "Sulfuraid-21" when used in hot baths, ls not an effective relief, preventative or cure for muscular, particular, or ligamenta! pain or for pain due to rupture of muscles; contusions, .neuralgia, tubes, tumors, abdominal spas.ms, pleural pains, particular t·heumatism of wonl.en during their climacteric period; or for pain caused by rheumatism, arthritis, neuritis, gout, lumbago, or nervous 6:ll:haustion, or any other pain. The use of said preparation in hot \\'after baths will not result in sulphur being absorbed from the water through the skin and mucous membrane, and will not exert a general 492 FEDERAL TRADE Commisslon DECISIO'NS Findings 35F. T.C.

pharmacological effect on the body. The inhalation of sulphur vapors of hl:>t baths containing "Sulfuraid-21" does not have a cleansing .ac· tion on air passages of the nose and throat and does not aid in relieving congestion in these parts of the body, but may have a contrary effect. The addition Of said preparation to hot water bath will not, because of such addition, tend to make a person perspire \~lore quickly or freely, and will not aid more rapid elimination of the body's waste products or counteract acidity in the body. "Sulfuraid-21" does _not represent the first successful effort to create sulphur in solutia~· Moreover, said preparation when used in hot baths is of no therapeutic · effect in the treatment of any disease or condition of the human body' · PAR. 7. The use by respondent of said false and misleading 11 • vertisements with respect to its said product, disseminated. as afore· ~aid, has had, and now has, the tendency and capacity to, and does~ cause a substantial portion of the purchasing public to believe t~a respondent's product possesses therapeutic properties and values which it does not in fact possess, and has had, and now has, the tenden~Y and capacity to, and does, induce such portion of the purchasing pubh~ to purchase substantial quantities of said product as a result of sue mistaken and erroneous belief.

par. 8. The acts and practices of the respondent, as herein ane,ge?' are all to the prejudice and injury of the public and constitute unfal~ and deceptive acts and practices in commerce withil). the intent nn meaning. of the Federal Trade Commission Act. REPORT, FINDINGS AS TO THE FACTS, AND ORDER Pursuant to th~ provisions of the Federal Trade Commission A.ct, the Federal Trade Commissi()n on January 29, 1942, issued, and ojl January 30,1942, served its complaint in this proceeding upon respond· ent, Baer Laboratories, Inc., a corporation, charging it with the us~ of unfair and dece.ptive acts and practices in commerce in violation ° the provisions of the said act. After the issuance of said complain~ the filing of respondent's answer, and the taking of testimony and evidence thereunder, the Commission, by order entered herein, granted respondent's motion for permission to withdraw said answer and v> substitute therefor an answer admitting all the material allegations of fact set forth in said complaint and waiving all intervening pro· cedur~. and further hearing as to said facts, which substitute answer was duly filed in the office of the Commission. Thereafter, this P'!'0" ceeding regularly came on for final hearing before the Commissl0~ on the said complaint, te~timony, and evidence taken thereunder, a.:n d the substitute answer, and the Commission, having duly considered . BAER LABORATORIES, INC. 493 488 Findings the matter and b~ing no~ fully advised in the pre.lllises, 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 P.AnAGRAPH 1. Respondent, Baer Laboratories, Inc., is a corporation .organi:l:;ed, existing, an9- doing business under and by virtue of the laws of the State of New York, with its office and principal place of business located at 30 East Twentieth Street1 in the city of New Yorkt State of New York. Said respondent is now, and for more than 1 Year last past has been engaged in the preparation, packing, sale, and distribution of a medicinal preparation designated by respondent as ''Sulfuraid-21.'.' . ·. P.AR. 2. Respondent causes its said product, when sold, to be trans- Ported from its place of business in the State of New York tq pur- ~hasers thereof located in various other States of the United States and ln the District of Columbia. Respondent maintains, and at all times lnentioned herein has maintained, a course of trade in its said prod- Uct, "Sulfuraid-21" in commerce among and between the various States of the United States and in the District of Columbia. PAR. 3. In the course and conduct of its aforesaid business, the respondent has disseminated and is now disseminating, and has caused ~nd is now causing the disseminationof, false advertisements concernlng its said product "Sulfuraid-21" by the United States mails and by' "arious other means in commerce, as commerce is defined in the Federal ·trade Commission Act; and respondent has also disseminated and is ~ow disseminating, and has caused and is now causing the dissemination of false advertisements concerning its said product, by various ~cans for the purpose of inducing, and which are likely to .inducer directly or indirectly, the purchase of its said product in commerce as commerce is defined in the Federal Trade Commission Act. '.Among, and typical of, the false, misleading, and deceptive statelllents and representations contained in said false advertis~ments, disseminated and caused to be disseminated by the United States mails, by advertisements in newspapers and other periodicals, and by booklets nnd other advertising literature distributed· among purchasers and llrospective purchasers, are the followi~g:

ll.heumatlsm, arthritis, neuritis ~r gont relieved or you pay nothing I New Scientlftc Achievement.

l:ou know, or have beard, how the word famous natural Hot Sulphur Spring 'llo.ths of this country and Europe have relieved persons of the tortures of ll.heumatlsm, Arthritis, Neuritis, Gout, Lumbago, Nervous Exhaustion, etc.,. after 1111 other means failed.

~OOT49m--43--vol.3~----S4 494 FEDERAL TRADE COMMISSION DECISIO'NS · Findings 35F.T- 0· . 00 Sulphur in SOLUTION which hitherto defined man's et'forts to produce is '{{ an accomplished fact. · r Undoubtedly, the most effective and yet the most economic .treatment. to relief of arthritic pains is a bot sulphur bath at home. · d 1\Iedical research has delved to some extent into the therapeutic action an e pharmacological value of these baths, imd while much still remains to be d00 d1s· in this field, evidence of their general efficaciousness for relief of rheumatic eases and other affections is established beyond the shadow of a doubt. b One of the most characteristic effects of sulphur water is probably the soot ; ing of pain due to the exhausting sedative action of H2S. Sulphur water assuages all kinds of pain, except headaches, regardless of the cause or orlgi~~ They not only stop muscular, particular and ligamenta! pain, but pain due 8 rupture of muscles, contusions, neuralgia, tubes and tumors; abdominal spasllld' pleural pains, particular rheumatism of women during their climacter~c perlol~ etc. Every Sedative alleviates at the same time, since sedative and analge~ effects are closely connected, and sulphur water probably owes its effect of ale; viat!ng pain to the sedative effect of H2S apart from heat. Thus we see tbal even in the alleviation of ,pain, sulphur baths do not merely~ act as a 1ocab stimulus on the body surface. Sulphur Is absorbed from the water tbroug the skin and mucous membrane and exerts a general pharmacological effect. The name given this newly-discovered product is SULFURA.ID-21. tre The action of the sulphur in solution in bot water tends to make one presP d· quickly and freely, and thus aid, more rapid elimination of the body's waste pro ucts and counteract overacldity. · . ul· As has already been shown by one medical authority whom we quoted, 8 rt pburetted bot water baths probably owe their powers of alleviating palo, apaee from heat, to the sedative effect ot the sulphur, which is absorbed to a degr Jt and is, therefore, more than merely a local stimulus on the body surface. till "is empirically known that_ absorption of the sulphur is effected through the 8 and through inhalation of its vapors. !II Among the noticeable effects of bot baths with SULFURA.ID-21, aside fr~1 allaying painful symptoms, is the delightful feeling of refreshment usual if following them; the easing of nervous tension; the improved ela,sticity of st 0 ~ fened joints: the sound restful sleep they help induce, and the more buoya and restful teellng they impart the morning after. 8 Occasionally, more_ than one complete course of 21 baths may be required :el · those who visit the Spas have found. In the majority of cases, the full cournt ot SULFURAID-21 baths should be sufficient for all purposes. To help prev-e ot recurrence of the aches and pains, 1t is wise, however, to continue taking a b SULFURA.ID bath once every ten days.

And in addition certain commendatory exi?r~ssions p~rporting ~~ have come from users of. the product, typical of which are t following:

as I prescribed your SULFURA.ID-21 tor c~inical test on my Mother, who b J been sutrering from a very severe rheumatic for the past 25 years or more. it can, with assurance, say that it bas helped her a good deal. She tells !lie en·8 bas done more good for her than the baths she took at Saratoga and Mt. Clelll !d She did observe that the dally baths were too weakening because of th~ rap a loss of body fluids. When she began to take the baths two or three t1mail f· BAER LABORATORIES, INC. 495 488 FindingsI \Veek, the results were more . favorable. I do not hesitate to prescribe your llroduct and recommend it very highly.

When one has been rheumatic for as inany years as I have, and tried almost ~verythlng that otrered the slightest hope for relief with little or no success, You Will hardly blame me for being skeptical at first over what SULFURAID-21 could do for me. Were it not for the face that I learned from a friend how greatly she was helped by taking the baths at Alx-le-Bains in France, I would probably Still be in Ignorance of what bot sulphur baths could do for a person in my condition. I completed your course of 21 baths three months ago. Since then I have had no pain at all, even during wet weather, except for an occasional slight feeling of discomfort, which passes almost as quickly as it comes. Your Sulfuraid-21 has proved a boon to me. With this help for my future defense against such Stllfering, I can look forward to enjoying life much more fully than I have. Does It not make you happy too, to know how much your bot sulphur baths help? With an good wishes for your success, I am · Cordially yours, · · PAR. 4. Through the use of the foregoing represen.tations and quotations and others similar thereto, not specifically· set out herein, the respondent represents, and has represented, directly and through in- ~erences, that its said product "Sulfuraid-21,'' when used in hot baths, 1~ an effective relief, preventative, and cure for muscular, particular, and hgamental pain, and all other pain except headaches, including pain due to rupture of muscles, contusions, neuralgia, tubes, and tumors; ~hdominal spasms, pleural pains, particular rheumatism of women dur- Ing their climacteric period; pain from rheumatism, arthritis, neuritis, gout, lumbago, and nervous exhaution; that as a result of the use of said Preparation in hot-water baths, sulphur is absorbed from the w~ter through the skin and mucous membrane and thus has a general phar- ~acological effect; that the action of said preparation in hot water ls such that it tends to make one perspire more quickly and freely and aids a more rapid elimination of the body's waste products and the counteraction o£ over acidity in the body; and that "Sulfuraid_:21" is the first successful effort to create sulphur in solution. PAR. 5. The aforesaid representations are grossly exaggerated, false, and misleading and const,itute false advertisements. In truth and in ~act respondent's said product "Sulfuraid-21," when used in hot baths, 18 not an effective relief, preventative, or cure for muscular, particular, or ligamenta! pain, or for pain due to rupture of muscles, contusions, neuralgia, tubes, tumors, abdominal spasms, pleu,ral pains or particular rheumatism of women during their climacteric period; or for pain caused by rheumatism, arthritis, neuritis, gout, lumbago, or nervous exhaustion, or any other pain. The use of said preparation in hot- ·:water baths will not result in sulphur being absorbed from the water . through the skin and mucous membrane and will not exert a general Pharmacological effect on the body. The addition of said preparation 496 FEDERAL TRADE. COl\IMISSION DE·CISIONS Order 35F. T.C.

to hot-water baths will not, because of such addition, tend to ma~e a person perspire more quickly or freely, and will not aid more rapid elimination of the body's waste products or counteract acidity in the. body. "Sulfuraid-21" does not represent the first successful effort ~ 0 create sulphur in solution; moreo'9er, said preparation, when used 10 hot baths, is of no therapeutic effect in the treatment of any diseases or diseased condition of the human body.

. PAR. 6. The use by the respondent of said false and misleading stat~­ ments, representations, and advertisements with respect to its s~ld product, disseminated as aforesaid, has had, and now has, the capaclt~ and tendency to, and did, mislead and deceive a substantial portion ° the purchasing public into the erroneous and mistaken belief that such false and misleading statements, representations, and advertisements were true and has had the tendency and capacity to, and has induced a substantial portiqn of the purchasing public, because of such errone· ous and mistaken belief, to purchase substantial quantities of respond· ent's said product "Sulfuraid-21."

CONCLUSION ' .

The aforesaid acts and practices of respondent 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 i:nean· ing of the Federal Trade Commission Act.

ORDER TO CEASE AND DESIST I This proceeding having ·been heard by the Federal Trade Commis· sion upon the complaint of the Commission, the testimony and evidence offered and received thereunder, and the substitute answer of the respondent, in which substitute answer the respondent admits all the material allegations of fact set forth in said complaint, and states th~1 it waives all intervening procedure and further hearing as to sal facts, and the Commission having made its findings as to the facts and conclusions that said respondent has violated the provisions of the said Federal Trade Commission Act.

It is ordered, That the respondent, Baer Laboratories, Inc., a corpo· ration, its officers, representatives, agents, and employees, directly or through any corporate or other device, in connection with the offering for sale, sale and distribution of a medicinal preparation known ns "Sulfuraid-21," or any product of substantially similar composition or possessing subst~ntially similar properties, whether sold un~er 1he same na.me or under any other name, do forthwith cease ~_trid desist . from directly or jndirectly:

BAER LABORATORIES, L.~C. 497 488 .• ·Order 1. Disseminating or causing to be disseminated any advertisements: (a) by means of the United States mails, or · , (b) ..by any meaps in commerce, as commerce is defined in the Federal Trade Commission Act, wh~ch_ advertisements re~resent, directly or through inference, that its preparation "Sulfuraid-21" or any like or similar preparation, when used in hot water baths, is an effective ~elief, preventative or cure for rheumatism, arthritis, neuritis, gout, Uinbago or nervous exhaustion, or for muscular, particular or liga- :tnental pain, or for pain due to rupture of muscles, contusions, neuralgia, tubes, tumors, abdominal spasms, pleural pains, or particular rheumatism of women during their climacteric period; or that a~ a result of the. use of "Sulfuraid-21" in hot water baths, sulphur is absorbed from the water through the .skin and mucous membranes andth .t Us has a general pharmacological effect on the human body or that thl addition of said preparation to hot water, because of such aadition, ends to make a person perspire more' quickly or freely and aids a :tnore rapid elimination of the body's waste products·and the counteraction 'of acidity in the body; or that "Sulfuraid-21" is the first successful effort to create sulphur in solution or when used in hot baths I,>?ssesses any therapeutic effect in the treatment of any disease or CllSeased condition of the human body, . b 2. Di~seminating or causing to be disseminated any advertisement any means for the purpose of inducing or which is likely to induce,l dltectiy_ or indirectly, the purchas~ i_n c?mmerce ~s "comme~ce" is efined m the Federal Trade Comm1sswn Act, of said "Sul:furaid-21'' 'lthich advertisements contain any of the representations prohibited in J:lnragraph 1 hereof. 1 · It is further ordered, That the respondent shall, within 60 days ~after service upon it of this order, file with the Commission a report ;n. "Writing setting forth in detail the manner and form in which it las complied with this order.

' 498 FEDER-AL TRADE COMMISSION DECISION'S Syllabus 35Jl'.T.0·