Ed Hamilton Furs, Inc., of Oregon

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IN THE MATTER OF ED HAMILTON FURS, INC., OF OREGON, ET AL.

CONSENT ORDER, ETC., IX REGARD TO THE ALLEGED VIOL, TION OF THE FEDER.1.L TR. DE COl\UnSSIOX ACT A D OF Tile FUR PRODUCTS LABELING ACT Docket 6159. Complaint, Feb. 1954-Decision, Ang. , 1.954 Consent settlement order requiring furriers in Portland, Oreg., and Seattle, WasIl. to cease violating the Fur Products Labeling Act and the Federal Trade Commission Act through failng to label fur products as required and through advertising falsely as to prices, quality, value of their products, etc. Before 1'. A bne1' E. Lipscomb hearing examiner. lift. 0 hades S. 0 ox for thc Commission.

ill;" George lV. /JI cad of Portland, Oreg., for respondents. CO:iiplaint Pursuant to the provisions of the Federal Tracle Commission Act and the Fur Prod uets Labeling Act, and by virtue of the authority vested in it by saiel Acts, the Federal 'I'trade. Commission, having reason to believe that EdllnmiJton Furs, Inc., of Oregon, a. corporation, Ed Ha,miltoll Furs, Inc., of \Vashington, a corporation, and Ed Hamilton and Elizabeth IIarnilton, inelivieluany and as offcers of said corporations, hereinafter referred to as respondents, have violated the provisions of saiel Acts and the Rules a.nd Regulations promulgated under the Fur Products Labeling Act, and it appea.ring 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 Ed I-IamiHon Furs, Inc., of Oregon is a corporation organized, existing and doing business by virtue of the laws of the State of Oregon with its office and principal place of business located at 910 S. 'V. fol'ison Street, City of Portland State of Oregon; respondent Ed HamjJton Furs, Inc., of "\Yashington is a corporation organized, existing and doing business under and by virtue of the Ja,ys of the State of \Vashington with an offce and princip,tJ place of business located at 1522 Fifth A venue, City of Seattle, State of iVashington. Individual respondent Ed Hamilton is president of respondent Ed Hamilton Furs, Inc., of Oregon, a corporation, and respondent Eclllamilton Furs, Inc. , of V ashington, a COl'- ED HAMILTON FURS , C\TC. , OF OREGOK ET AL. 187 186 Complaint poration. Individual respondent Elizabeth Hamilton is secretarytreasurer of respondent Ed Hamilton Furs, Inc. , of Oregon, a corporation, and was vice-president of Ed Hamilton Furs, Inc., of 'Vashington a corporation, until approximately :May 15, 1953, since which time she has been secretary-treasurer of same. The post offce address of this individual respondent and of respondent Ed Hamilton is 910 S. IV. Morrison Street, Portland, Oregon. The individual respondents, Ed Hamilton and Elizabeth Hamilton have act-ed and no act in conjunction and cooperation with e-ach other in formulating, directing and controlling the business, acts practices and policies of said respective corporate respondents, including the labeling and invoicing of merchandise and the advertising claims made directly and indirectly by said respondents Ed Hamilton Furs, Inc., of Ore,goal, a corporation, and Ed Hamilton Furs, Inc., of vVashington, a corporation.

PAn. 2. Individual respondents Ed Hamilton and Elizabeth IIami1ton and respondent Ed Hamilton Furs, Inc., of Oregon, a corporation, since 19"17, and respondent Ed Hamilton Furs, Inc., of 'V ashington, a corporation, since April 1952, have bee.n engaged in the pl1r chase, sale and distribution of fur products, including fur coats, fur jackets, fur stoles, fur scarfs and relate.d fur garments. Respondents cause and have can sed the aforesaid fur products, when sold, to be transported from their respectivc places of business in the State of Oregon and in the State of \Vashington to purchasers thereof at their respective points of location in various States of the United States. Respondents maintain, and at all times mentioned herein have maintained, a course of trade in saiel products in commerce among and beeen variolls States of the United States.

AH. 3. R.respondents are engaged in the receipt in commerce, the introduction into commerce, and in the sale, advertising, and offering for sale, transportation, and tbstribution of fur products in commerce as such products are defined in the Fur Products Labeling Act; mal as commerce" is defined in said Act. Responde,nts; fur protlncts are composed of "fui" as that term is defined in the Fur Products Labeling Act, and which products are subjpct to the provisions of said .Act and the I\ules and H,egulations prol111lgntec1 therennder. Since' Al1gust 8, 1952, respond nts have violated the provisions of said Fur Products Labeling Act and said Hules and Hegulations pl'ollml.untell thereunder in the introduction into commerce, and in the sale, nc1yertising and offering for sale transportation and distribution or fur products jn sai(1 commerce, and in the sale advertising offering: fol' sale, transportation and distribution of fur products compo f'd in 51 F. T. c Complaint whole or in part of furs which had been shipped and received in com. merce, by causing them to be misbranded and falsely and deceptively advertised and invoiced within the intent and meaning of the Fur Products Labeling Act and said Rules and Uegulations promulgated therennder.

PAR. 4. Among the products referred to in Paragraph Three here. of were scarfs, coats, capes, stoles and other articles of ladies .."hearing apparel composed in whole or in part of fur. Exemplifying respondents' practice of violating said Fur Products Labeling Act and the Rules and Regulations promulgated thereunder is their (A) 11isbranding, false advertising and false invoicing of such rur products by:

(1) Failing to affx labels to fur products, failing to show in ad. vertisements of fur products, and failing to furnish invoices to purchasers of fur prod ucts showing:

(a) the name or names of the animal or animals producing the fur contained in the fur products as set forth in the Fur Products K arne Guide and as permitted under the Hllles and Uegulations; (b) that the fur product contains or is composed of used fur; (c) that the fur product is secondhand;

(d) that the fur product contains or is composed of bleached, dyed or othenvise artificially colored. fur;

(e) that the fur product is composed in whole or in substantial part of paws, tails, bellies or waste fur;

(f) the name of t.he country of origin of any jlnpol'ted furs used in a fur product;

(2) Abbreviating parts of the required information in violation of t.he Fur Products Labeling Act and Hule 4: of the Regulations thereunder;

(3) Using certain tenus descriptive of the breed, spccie: strain or coloring of an animal which connote a false geographical origin of the animal. Exemplifying this practice, but not limited thereto: is the practice of c1eseribing an animal as '" A.le,lltian :\Iink': in violation of the Fur Products Labeling Aet and Eule 7 of the Regulations thereunder:

(4) losing a cojned name as being descriptive of Ule fur of an animrd which is in Llct fictitious or non-existent, in violation of the Fur Prodnets Labeling Act and Rule 11 of the Regulations thereunder. Exemp1ifying this practice, but not limited thereto, is the practice of describing the fur as "Hudson Seal," when there is in fact no such .animal;

ED HA:MILTON FURS, INC., OF OREGON ET AL. 189 186 Complaint (5) Using the term "assembled" to describe fur products or fur mats or plates made of the pieces set out in Rule 20 (a) of the Regnlations under the Fur Products Labeling Act without disclosing the named pieces, in violation of the Fur Products Labeling Act and such rule;

(6) Using the name of another animal in addition to the name of the animal actually producing the fur contained in the fur product. (B) Further misbranding their fur products by: (1) Falsely and deceptively labeling and otherwise identifying said fur products, and in the use of labels affixed to such products containing various forms of misrepresentation and decept.ion with respect to such fur products. Exemplifying this practice, but not limited there- , is the use of non-required labels containing statements conflicting with the required information appearing on the requirecllabels; (2) Setting out on labels required information in type smaller than pica or 12 point; mingling non-required information with required information; using handwri6ng in describing parts of the required information in violation of the Fur Products Labeling Act and Rule 29 of the Regulations thereunder:

(3) Failing to set out the applicable parts of the required infOlma- 60n in the sequence provided in Hule 30 of the Hegnlations under the Fur Products Labeling Act;

(4) Failing to sct forth on labels the name or other identification issued and recorded by the Commission of one or more persons who manufactured such fur products for introduction into commerce introduced it jn commerce, sold it in commerce, advertised or offered jt for sale in commerce, or transported or distributed it in commerce. (C) Further falsely advertising fur products by: (1) :Tfisrepresenting the prices of their fur products as being wholesale prices and as being so low as to attract other retailers as customers; (2) 1disrepresenting prices of fur products as being reduced from the regular or usual prices where the so-called regular or usual prices are i11 fact fictitious in that they are not the prices at which such lnerchnlldise is wmally or regularly sold;

(;3) Iisreprpsellting prices as being reduced where no reduction has been m:ldc;

(4- ) J:lisrepresenting the savjngs afforded by redne-ed prices on said products in that the represented savings are in excess of the savings actually afforded from any recent or current market values of said products;

(;)) JIisrepresenting the grade, quality and value of said products; (6) Jlisrepresenting fur products as having been acquired at ;' close- 190 FEDERAL ':TRADE COMMISSION DECISIONS Complaint 51 F. T. C.

out sales dist.ress sales" and under .other circumstances, indicating that they were purchased at bargain prices contrary to fact; (7) Misrepresenting fur products as "furs of the Hollywood stars Hollywood Fashion Furs " "Fabulous designer Furs/ purchases from the leading l\link designers Each intended originally for IIollywood star" and by other representations indicating that the designer of said products, the source from which they "ore obtained and the persons for whom they were originally intended is other than the fact;

(8) l\lisreprescnting that any fUl'product was originally intended to be priced higher than is the fact.

PAIL 5. The aforesaid acts, practices and methods of respondents as herein a.lleged, were in violat.ion of the Fur Products Labeling Act and the Rules and Regulations promulgated thereunder and constitutec1uufail' and deceptive acts and practices and unfair methods of c.ompetition in commerce under the Federal Trade Commission Act. PAR. 6. Hespondents, during the. periods herein stated, in the course and conduct of said business in commerce, as ' co11merce" is defined in the Federal Trade Commission Act, have made many statements and representations, including those misrepresentations described in Paragraph 4 (C) of this complaint which are incorporated herein by refercnce, concerning their said business, methods of operation of same the composition, quality, price and value of the fur products offered for sale by them by means of advertisements inserted in newspaper!: in circulars and in other advertising media, all of ,vhieh were circulated and distributed among the purchasing public. Typical of the said statements and representations, made in addition to those set out or described in Paragraph 4 (C) of this complaint, but not all inclusive, are. the following:

You see our designers took the soft, underfur of the Squirrel J.auks and created these glorious new fashions! 1000 furs * '" * offered under one roof at a single :price 1000 furs " * '" counts * '" '" capes * * '" jackets "' '" * scarfs '" , * at one astonisbing price $125 Marvelous l\Juskrut. In four luxurions shac1es * '" '" Dyed Deep Brown chocolate'" '" * moonglow 235 plus tax.;Only *Ed Hamiiton'" wbeatoffers you sncb a marvelousshadeselection in the newest smartest shades'" '" '" and in the new sweeps for ' 53. These are the choice of the market " '" .. We suggest comparison ,,,itll coats priced up to $375 elsewbere. Ed I-amiiton s Anniversary sale '" " * a sale four months in the making * A feast of values as great as any in our 98 years! '" * '" It' s a new year and Ed Hamiiton furs is 98 years old'" '" * PAR. 7. Hespondents, through the nse of the statements appearing in the aforesaid advertiseme.nts, represented that they employ their ED HAMILTOX Furs, INC., OF OREGON, ET AL. 191 186 Complaint own fur designers and manufacture their fur products; that they offered for sale 1 000 fur products at $125.00 each; that their muskrat coats offered for $235.00 were comparable in quality to muskrat coats sold for $375.00 by their competitors; and that respondents' fur business has been in existence for 98 years.

PAR. 8. In fact, respondents do not employ fur designers or manufacture their fur products; they did not have 1 000 fur products for sale at $125.00 each; their muskrat coats offered for 8235.00 were not comparable to the quality of muskrat coats sold by their competitors for $375.00; and respondents' fur business has not been in existence for 98 years, Ed IIamilton having established said business in 1946. PAR. 9. Respondents, in addition to the foregoing, also engaged in unfair and deceptive acts and practices as follows: (1) placing tags on their f1l products listing prices thereon which were far in excess of those at which respondents intended to sen said ll1erchandise;

(2) changing price tag labels on fur products with increases in prices listed thereon in order to offset any credit given on any merchandise certificates or trade-in allo'\';aIlces toward the purchase of a fur or fur product from respondents.

PAR. 10. Respondents, in the conduct awl operation of said business, have also engaged in promotional activities, t.typical 01 which is the "Free Squirrel Cape otfer. In cOllnection t.he1'8\\ ith, respondents represented tha.t during their "JANUARY FUH CLEAll- ANCE SALE twenty-five beautiful luxurious Russian Squil'el capes ' would be awarded at no extra cost, and that said capes were of a $200. 00 value.

Said representations were false, misleading and deceptive. In truth and in fact no such capes '\were awarded during said sale Rt the store in the City of Seattle, State of 1Vashington, and only two were awarded during said sale at the store in the City of Portla.nd, State of Oregon. Furthermore., the capes that '\,;cre awarded were not of a $200.00 value, that is, '\There not sold by respondents for $200.00 in their regular course of business.

PAR. 11. Respondents, in connection with the conduct and opera- Lucky number COl1test'tion of said business, also operated a. " which it was representeel that $38 000 in prizes would be a'\vardec1; that the first fifteen prizes would ( consist 01 various fur capes and coats and that there would be at Jeast 500 extra awards of S65 each in merchandise certificates good tc)\yarc1 the purchase of any Ed IIamilton fur coat or jacket.

42378;)-58- , Complaint 51 F. T. C.

Said representations were false, misleading and deceptive. In truth and in fact, respondents did not award $38 000 in prizes either in dollars or in merchandise. The so-called merchandise certificates were ,vorthless in that respondents marked up the prices of all coats and jackets so as to absorb the amount listed on the merchandise certificate.

PAR. 12. Respondents, in connection with said business, also operated a "$55 000 Fur Puzzle Contest" in which it was represented that the first ten prizes -were a stole, a cape, coats and a scarf of values ranging from 200 to $1 500, and that the "tenth" through the twentieth" prizes would each be a $100.00 Siberian Kolinsky scarf; that the total value of all the fur or fur products offered as prizes from one to hventy, inclusive would be $5 500. In addition to the fur or fur products to be given as prizes, respondents representeu that there was added "at least 1 000 $50 certificates * * * good on the purchase of any Ed Ham.ilton fur coat, cape, jacket, or scarf for a full 30 clays.

Said representations were false, mislenc1ing and deceptive. The represented value of the prizes was greatly in excess of the uSllal and regular prices respondents charged for merdumdise comparable to that given as prizes. Furthermore, practically every person entering the so-caned contest \yas considered a "winner flnd H\vardecl a merchandise certificate. Ho\vever, respondents marked up the price on the merchandise onwhic.h they would nl1mv the merchandise certificate to be applied, so that ally article sold would be at a price ill exe-ess of the usual or regular price so as to offset the amount the credit given for the merchandise certificate. Furthermore, respondents have on occasions refused to honor the said merchandise certificates \1,hen the same \were presented at respondents' said stores in accordance with the terms of the certificate Hnd have stated that the.:l 'were not acceptable toward the purchase of ;;sale j merchandise. PAR, 18. The use by respondents of the statements, representations nnd prnctic.cs set ant or refcned to in Paragraphs 6 to 12, inclusive has had and no\\ has the tendency and cnpaeity to confuse, mislead and deceive members of the public into the erroneous and mistaken belief that such statements and represcntnticJls are true, and to induce them to purchase respondents' saiel fur products. PAR. 1 J. The acts nncl practices of respondents, as herein al1egec1 in Pa!'agraphs 6 to 12, inclusive, ",were all to the pre-judice of t.he public and constituted unfair and deceptive acts and practices in commerce \vithill the intent and lling of the Federal Trade Commission Act.

ED HAMILTON FURS , INC., OF OREGON, ET AL. 193 186 Decision DECl8ION OF THE COMl\IISSION Pursuant to Rule XXII of the Commission s Rnles of Practice and as set forth in the Commission s "Decision or the Commission and Order to File Report of Compliance " dated August 26, 1954 the initial decision in the instant matter of hearing examiner Abner E. Lipscomb, as set out as follows, became on that date the decision or the Commission.

INITIAL DECISION BY ABNER E. LIPSCOMB HEARING EXAMINER On February 2, 1954, the Federal Trade Commission issued its complaint against the above-named respondents, charging them with acts and practices in violation or the Federal Trade Commission Act the Fur Products Labeling Act and the Rules and Regulations promulgated thereunder. Subsequent to service or this complaint upon respondents, and the filing of respondents ' ansvo, cr thereto, a hearing was held at Portland, Oregon on June 1, 1954, at which respondents and tl1eir attorney entered into an agreement with counsel in support or the complaint, and, pursuant thereto, submitted to the hearing examiner a Stipulation For Consent Order.

In this stipulation respondent Ed Hamilton Furs, Inc., of Oregon is identified as a corporation organized under the laws or the State of Oregon, with its office and principal place or business located at 908 S. 1V. Morrison Street, Portland, Oregon; respondent Ed Hamilton Furs, Inc., of "'Vashington is identified as a corporation organized under the laws of the State of 'Vashingtoll, with its offces and principal place of business, at ihe time of the issuance or the complaint herein and prior thereto, located at Hj22 Fifth Avenue, Seattle, \Vashington and at 908 S. ,Yo ),Iol'rison Street, Portland, Oregon; andl'respondents Ed Hamilton and Elizabeth I-Iamilton are identified as individuals and offcers or the corporate respondents, with their offces and principal place of business Jocated at DOS S. IV. Morrison Street, Portland Oregon.

Respondents admit all the jllrisclictional allegations set forth in the complaint and stipulate that the reconl herein may be taken as if the Commission had made findings of juriscbctional facts in accordance wit.h such allegations. All respondents request that their answer fied herein on February 25, 1954, be withcln1.vn, and expressly waive the filing of an ans' er to the complaint and further procedure before the hearing examiner and t11e COlnmission. R.respondents agree that the order contained in said stipulation shall have the same force and effect as if made after a fuji hearing, present.ation of evidence, and 194 FEDERAL TRADE COM.\fISSIO DECISION'S Order 51 F. T. C. findings and conclusions thereon, and specifically waive all right power or privilege to contest the validity of said order. Said stipulation recites that saiel complaint may be llsed in construing the terms of the aforesaid order, and that said order may be altered, modified, or set aside in the manller provided by statute for orders of the Commission. It is further agreed therein that said Stipulation For Consent Order, together with the complaint, shall constitute the entire record of this proceeding, and that the order contained therein may be entered upon the record, in the disposition of this proceeding, without further notice.

In view of the provisions of the Stipulation For Consent Order as outlined above, it appears that respondents' request that their answer to tbe Gurnplaint herein be withdrawn should be granted, and that such action, together with the issuance of the order contained in the stipulation, will resolve all the issues arising by reason of the complaint in this proceeding and respondents' anSiVer thereto, and will safeguard the public interest to the same extent as could be accomplished by full hearing, and all other adjudicative procedure, waived ill said stipulation. Accordingly, the hearing examiner, hl consona,nce with the tenns of said agreelnent, accepts the Stipulation For Consent Order submitted herein; grants respondents' request that their answer to the complaint herein, filed on February 2;) 1954, be withdrawn; and issues the following order:

It is ordered t.hat respondent Ed I-Iamilton Furs, Inc., of Oregon a corporation, and its offcers, respondent Ed I-Iamilton Furs, Inc., of \Yashington, a corporation, and its offcers, and respondents Ed HamDton and Elizabeth IIamilton, individually and as oflicers of said corporations, and their respective representatives, agents and employees, directly 01' through any corporate or other cleyice, in connection with the introduction, or manufacture for introduction, into commerce, or the sale, advertising or offering for sale in commerce, or the transportation or distribution in commerce of any fur product; or connection with the manufacture for sale, sale, advertising, offering for sale, transportation 01' distribution of any fur product which is made in whole 01' in part of fur which has been shipped and received in eOllUnel'Ce; as "commerce fur :' and ': fur product" are defined in the Fur Products Labeling Act, do forthwith cease and desist from: (A) Jlisbranc1ing, false. nd,'ertising, or false invoicing of fur products by:

(1) Failing to affx labels to fur products, failing to show in advertisements of fur products, or fn.filing to furnish invoices to PUl'chasers of fur plo(1uets, showing:

, , ,, ED HAMIL'IOX Fers, INC. , OF OREGOX, ET AL. 195 186 Order (a.) the name or names of the animal or animals producing the fur 'contained in the fur products as set forth in the Fur Products Xamc Guide and as permitted under the Hules and Regulations; (b) that the fur product contains or is composed of used fur, when such is a fact;

(c) that the fur product is secondhand, when such is a ffll (d) that the fur pro duet contains or is composed of bleached, dyed or otherwise artificially colored fur when such is a fact; (e) that the fur product is composed in 'whole or in substantia.l vart of paws, tails, bellies or waste fur hen such is a fact; (f) the llame of the country of origin of any -imported furs used in a fur product;

(2) Abbreviating parts of the information required under t.be Fur Products Labeling Act and t.he R.ules llld Regulations thereunder; (3) Using terms descriptive of the breed, species, sirain, or coloring of an animal ,which connote a false geographical origin of t.he animal; (4) Using the lelTn "Ilndson Seal " or any other coinec1name, as being descriptive of the fur of an animal which is in fact fictitious or JlOu-existcnt;

(6) Using t.he term "llssembled ' to c1escr-ibe fur products 01' fur mats or plates lnadc of the pieces set ont in Itule 20 (a) of the Regulations under the Fur Products Labeling .."tct ,without disclosing the named pieces;

(6) l sing on labels attached to flll' products, in achertisements of Tur produds, and on invoices of fur products, the name of another animal in addition to the name of the animal actually producing the fur contained in the fur product.

(B) )Iisbranding their fur products by:

(1) Falsely or deceptively labeling or otherwise identifying said fur product, or using labels affixed io such products which contain any form of misrepresentation or dccE'vtion ,with rE', spect to such fur l)rod ucts ;

(2) Setting out on labels attached to fur products the required infonnation in type smaller than pica or 12 point; mingling non-required illfonrmtion with require.d information; or using hand"Titing in describing a.ny of t.he required information; (3) Failing to set out the applicable, parts of the re(1uil'ecl infornwtion on labels in t.he sequence provirlccl in Rule ;-j() of the Regulations under the Fur Products Labeling Act;

(c1) Failing to set 10rth on required labels attached to fur products the name or other identification issued and registered by the Commission of one or marc persons ,yho manufactured such fur products for , Order 51 F. T. C.

introduction into commerce, introduced it in commerce, sold it in commerce, advertised or offered it for sale in commerce, or transported or distributed it in commerce.

(C) Falsely advertising fur products by representing, directly 01' by implication:

(1) That the price of any such product is a wholesale price or is so low as to attract other retailers as Cllstomers unless such is the fact; (2) That the customary or regular price of any such product is any amount in excess of the price at \"which such product has been offered for sale in good faith or has been sold by respondents in the recent regular course of business;

(3) That the regular price of any sneh proclnet is a reduced price; (4) That a price enables purchasers to make any saving in excess of the difT'erence between said prico and the price at ,,"hieh comparable products sold at the time specified or, if no time, is specifiecl, in excess of t.he diiIerence between said price and the Cl1rre,nt price at which comparable products are sold;

(5) That any such product is of a higher grade, quality or value than is the fact;

(6) That any said products \were acquired nt ';dosc out sales :' 01' other distress sa,les or were acquired under other special conditions conducive to low or bargain prices unless such is the fact; (7) That the designer of any such product, the source from which it \fas obtained: or the person for whom it \fas originally int.ended is other than the fact;

(8) That all)' such product ,,'as originally intended to seh or be priced at a higher price unless products of Eke gl'fl,cle and quality '"ere customarily so priced and sold.

It is further ordered that respondent Ed Hamilton Furs, Inc. Oregon, a corporation, and its offcers, respondent Ed I-Iamilton Furs Inc., of \Vashington, a corporation, and its offcers, respondents Ed J-Iamilton and Elizabeth Hamilton, individually and as offcers of said corporations, and their re,spective representatives, agents and employees, directly or through any corporate or other device, in connection \with the oflering for sale, sale and distribution of fur products in commerce, as "commerce" is defined in the Federal Trade Commission Ad, do fortlnvith cease and desist from: (1) Making any of the representations listed in sub-paragraphs C (1) through (8) of this order;

(2) Representing, directly or by implication: (0) That they manufacture or design any of said products, unless such is the iad;

ED HAMILTON FURS , INC. , OF OREGON, ET AL. 197 186 Order (b) That the number of said products available for sale is other than the fact;

(c) That the price of any said product is lower than competitors products of comparable quality, unless such is the fact; (d) That they have engaged in the fur business for a longer period of time than is the fact;

(e) That merchandise certificates have any value in excess of the amount of reduction from thc regular price of a fur product allowed a purchaser presenting said certificate for credit; (f) That the total value, individual value, or number of the awards to be made by respondents in any manner is other than the fact; (3) Increasing thc price of any of said products for the purpose of nullfying any part of the value of their merchandise certificates presented for credit on the purchase of' said product; (4) Refusing to honor at face value or placing any limitation on the honoring of any merchandise certificate or other award issued by them unless the basis for refusal or limitation is clearly and conspicuously set forth in the certificate or award and in the advertising referring to said certificates or a wards.

It is further ordered that the answer to the complaint herein filed by respondents on February 25 1954, be, and the same hereby is, withdra \\11 from the record.

ORDER TO FILR HEPORT OF CO IPLIANCE It is ordered that respondents Ed Hamilton Furs, Inc., of Oregon a corporation; Ed Hamilton Furs, Inc., of ,Yashington, a corporation; and Ed Hamilton and Elizabeth Hamilton, individually and as offcers of said corporations, shall, within sixty (60) days after 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 ha.ve complied with the order to cease and desist Cas required by said declaratory decision and order of August 26, 1954j. 198 FE DE HAL TRADE CO LvIISSIO ,T DECISIONS Decisi on 51 F. T. C.