Popular Science Publishing Co., Inc.
Volume 65 · 65 F.T.C. 622
deceptive advertisingdebt collection
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Popular Science Publishing Co., Inc., 65 F.T.C. 622 (1964). Consumer Law Library, https://consumerlawlibrary.org/decisions/v065-0025
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which it has complied w-ith this order.
Ix THE L\Tn:R OF POPT LAR SCmXCE Pl-BLISIIXG CO., IXC.
CONSENT ORDER ETC. , IX REG"\RD TO THE ALLEGED VIOL.\TION OF Tile l"EDEIUL TR.WE CO)DIISSlOX .\CT Docket C' 1. Complnil1t ljJl'. 3(), 1!Hi. Deci8Jo1l, Apr, 3D, 196. Consent order requiring Xew York City pulJ1isher of OJ ;'l'ovulal' Science lonthly" anu " Outdoor Life :Magazine, aho operating the ;;Ontllool' Life Book Club" and the "Popular Science Lh-ing Library, to cease representing falsely ill letter to purportedly c1elinqcJ1t customers that if !1ayment was Dot wade the delinquent's account would lie turned oyer to ,a bona fide collection agency with con:-equent injur.\ to bis credit rating, and by use of the fictitious letterhead " The ::lail Order Credit Reporting As,:uciation Inc. , that a separate organization hall received tlw accollnt for l'ollection and prepared the notice.
CO)IPh\IXT Pursuant to the proyjsions of the Feclernl Trade Commission \ct nel by virtue of the authority ycstec1 in it by saiel Act, the Federal Trade Commission, having reason to be.1eye thrt Popuhr Science Publishing Co., Inc., a corpol'Ration, hereinafter referred to as respollllent, has violated the provision11s of sflid Act, and it appearing to the Commission that a proceeding by it in respect thereof ,,-auld be in the public interest: hereby issues its compbint tilt,jng its charges in that respect as follmvs:
P..\lL\GRAPH 1. R.esponclent Popular Science Publishing Co. , Inc. , is a corporation organized, existing and doing business under and by virtue. of the la\\'s of the State of Xew York with its principal.l ofiice and , POPULAH SCIENCE PUB. CO, : IXC. 623 622 Complaint place of business located at ;-335 Lexington A \yenlle in the city of ?\T ew York, State of No" York.
PAIl. 2. Respondent is now and for some Lime last past has been engaged in the advertising, offering for sale, sale and distribution of publications, books and me,rchandise to the general public. Respondent publishes two monthly llulgazines Popular Science J\fonthly and the "Outdoor Outdoor Life J\Iagazine, and operates two book clubs Life Book Club" and the "Popular Science Living Library". The a.foresaid publications, books and merchandise are advertjserl sold and payment made therefor through the united States Mails. PAR. 3. In the course and conduct of its business, respondent now causes and for some time last past has ciluse(l, :its said publications books, and merchandise "hen sold, to be shipped from its place of business in the State of Nmy York to pure-hasel's and subscribers thereto located in the various other States of the United States and in the District of Collu11bia, andn1aintains. an(l at an times mentioned herein has maintained, a substantial COl1l' e of trade in said publications, books and merchandise in commerce, as "commerce" :is defined in the Federal Trade Commission Act.
\R. 4. In the e-Ol1rse and conduct of its business and for the pllrpose of inducing the payment of purportedly delinquent account.s respondent has made certain statements and representations in letters and ma.teria.1s sent through the -Cnited States mails to purportedly delinquent customers who have pl1rehased respondents publications: hooks or merchandise.
Typical, but not all inclusi ve of said statements and representations are the follo"ing:
a. On respondents letterheads:
IMPOR/plant-FINAL XOTICE YOGR ACCOUNT IS BEING TURXED OYER TO A COLLECTIOX AGEXCY UNLESS WE HEAR FROM YOT; DBIEDIATELY Dear Customer:
In order that there C8n be no misunderstanding cOIlcerning yonI' failure to pay the enclosed statement, we nre selHling yon this fillf!l letter. T)nless we bear from you within the next ten days, Jour account -wil be turned over to THE MAIL ORDER CREDIT REPOR'lTKG ASSOCIATION, IXC., which is f! VI'Ofessional collection agency.
Deal' Customer:
Your payment for the Outdoor Life Magazine subscription you ordereu i now TWO MONTHS PAST DUB and we need your HELP to straighten out ;vollr account.
Otherwise, won t you please HELP us-and help keep your o\yn credit standing in good shape-by sending your payment at OIJce ill the enclosed envelope. COmplaint 65 F, Fn..AL 1'NOTICE- This is the last letter we can send you about your unpaid account.
\Ve do not like to turn over names of our subscribers to a collection agency, but if we do not receive rout' payment we wil have no alternative. '" '" '" b. On the letterhead of:
The :\fail Order Credit Reporting Association, Inc. CREDIT REPORTS-SPECIAL INVESTIGATIOXS-COLLECTIOKS NEW YORK 18, N, We lwye been notified by one of our clients, the POPULAR SCIEKCE PUB- LISIIIl\G CO)lpa, IXCOHPORATED, of your failure to pay a long past-due account for a magazine subscription you ordered. Before we proceed further, we are giving you a final opportunity to make payment. Although the amount involved is small, it is our business to collect our clients' delinquent accounts regardless of size. And we are organized for this purpose. '" *' * Re: OUTDOOR LIFE BOOK CLUB The above firm, as a member of 'l'Hli. MAII, ORDER CREDIT REPORTING ASSOCIA'I'IO:\, IXC. , has reported to us your long past due account so that \ye may inform other members of their experience \with you upon request. *' * * \R. 5. By and through the use of the aforesaid state-ments, representations and practices, and others of similar.r import not specifically set ont herein respondent represents and has represented that: a. If pn,yment is not made, the delinquent customer s account is turned over to a. separate, bona fide collection agency. b. If payment is not made, the customer s general or public credit rating will be adversely affected.
c. .:THEMAIL ORDER CREDIT REPORTING AGENCY INC. is a separate bona, fide coJlechon and credit. reporting agency located in New York City.
d. Respondent has turned over to said " THE IAIL ORDER CREDIT RE- PORTING ASSOCIATION INC. " the delinquent account of the customer for caneetion and other purposes.
e. The letters and notices on ,the letterhead of the said "THE MAIL ORDER CREDIT REPORTING ASSOCIATION , IXC. ," ha"Fe been prapared and mailed by said organization.
PAl(. G. In truth and in fact:
a. If payment is not made, the delinquent customer s account is not t.urned oyer to a separate, bona fide collection agency. D. If payment is not. made, the customet S general or public credit rating is not adversely affected.
PQPVLAR SCIE::CE PUB. CO., INC. 625 622 Decision and Order e. " THE MAIL CREDIT REPORTING ASSOCIATION , INC. " is not aORDERseparate, bona fide collection or credit reporting agency. Said organization is a name utilized by respondent and others for the purpose of disseminating collection letters.
d. Respondent has not turned over to saiel ..TUEMAIL ORDER CREDIT REPORTI:'W ASSOCIATlO , INC. t the delinquent account of the customer for collection or any other purpose.
e. The letters and notices on the letterhead of the said "THE IAIL ORDER CREDIT REPORTING ASSOCIATION, INC.," have not been prepared or mailed by said organization. Said letters and notices have been prepared and mailed or caused to be mailed by respondent. Replies in response to said letters and notices are ionvarded unopened to respondent.
Therefore, the statements a.nd representations as set fort,h in Paragra.phs Four and Five hereof were and are false, misleading and deceptive.
PAn. 7. The use by respondent of the aforesaid false, misleading and deceptive statements, representa.tions and practices has had, and now has the capacity and tendency to mislead members of the purchasing public into the erroneous and mistaken belief that said statements Lnd re,presentations were and are true a.nd into the payment of substantia.l sums of money to respondent by reason of sa.id erroneous and mistaken belief.
PAR. 8. The aforesaid acts and practices of respondent, as herein alleged, were and are all to the prejudice and injury of the public and constituted, and now constitute" unfair and deceptive acts a.nd practices in commerce in violat.ion of Section 5 of the Federal Trade Com. mission Act.
DECISION AND OBDEB Commission having heretofore determined to issue its complaint cha.rging the respondent named in the caption hereof with violation of the Federal Trade Commission Act, and the respondent having been served with notice of said determination and with a copy of the complaint the Commission intended to issue, together.r with it proposed form of order; a.ncl The respondent and counsel for the Commission having thereafter executed a.n agreement containing a consent order, an admission by respondent of all the jurisdictional facts set forth in the cOInpbint to issue herein, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondent that the law has been violated as set forth in such complaint. and ,vaivers and provisions as reflllired by the Commission s rules; and , 626 FEDERAL 'rI-lade COMMISSION DECISIQXS Decision and Order G5 F.
The Con1llissioll) having cUllsiclere.d the agreement, hereby accepts same, issues its cor.iplaint in the form contemplated by saiel agreement rnn.kes the follo'iYlng jurisdictional.l findings, and enters the followillg order:
1. Respondent Popular Science Publishing Co., Inc., is a corporation organized, existing a,ncl doing business uncle.r and by drtue of the hws of the State of Xew York with its principal offce and place of business located at 353 Lexington A venue, in the city of New' York State of New Yark.
2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent and the proceeding is in the public interest.
OHDEH It is ordered That respondent Popular Science publishing Co., Inc. a corporation, and its officers, and respondent's agents, representati,ces and employees, directly or through any corporate or other device in connection ,-with the offering for saJe, sale or distribution of books maga.zines or other merchandise, in commerce, as "commerce " is defined in the Federal Trade Commission Act, do forthwith cease and desist fr01llrepresenting directly or by implication that: 1. Delinqucnt customet S accounts -will be or have been turned over to a bona fide, separate colle.ction agency for collection unless respondent in fact turns such accounts over to such an agency; 2. A customer s name has been turned over to a bona fide credit reporting agency or that a customer s ge,neral or public credit rating will be adversely affected unless respondent establishes that 'where payment is not received, the information of said delinquency is 1'8fe,rred to a separate, bona fide credit reporting agency; 3. Delinquent accounts have been or will be turned over to "THE ::r.\n.. ORDER CREDIT REPORTING ASSOCIATION INC. for collection or any ot,her purpose;
4. "THE l.IAIL ORDER CTIEDIT REPORTING ASSOCIATION, INC. ': any fictitious name, or any trade name owned in whole or in part by respondent 01' over which respondent exercises any direction or control, is flll independent, bona fide collection or credit reporting agency; 6. otices or other con1Jnunications which respondent has or has caused to be prepared, written or mailed, have been sent by "THE 3fail ORDER CREDl'l' REPORTING ASSOCL\.TION , INC. " or any other person, firm or agency.
It is fu?,their' onle1'ed That the respondent herein shan, within sixty (e,O) days after service upon it of this order, file with the Commission LOCIS FCRS IXC" ET AL. 627 CUllplaint a report in wrjting setting forth in detail the manner and for1n in which it has complied 'with this order.
Ix 'l-IE l\L TTER OF LO"GIS FCRS IXC., ET AL.
CO::HiENT ORDER , ETC. , IX REG"\RD TO THE /' ALLEGED Vlcd ATION OF 1' EDER -\L TRADE COllDlIS3IOl\ AXD THE YCR PRODUCTS LABELDW ACTS Dooket C- /42. Complaint, A.l)1. 30, 1.96J,-Doctsion, Apr. 30, 1964 Consent order requiring retail furriers hl Hammond, Ind., to cease violating the Fur Products Labeling Ac: by labeling, invoicing and advertising furs impr()perl - a" " Broadtail" flliling to :,110\" the true animal name of furs on inyoke. , failllg ro di.-;close ,,.lien fur,,; ilre n ed or 1:C'con(1-1H-lld; falsely repn.' entjng tlwt IH'iccs arc rt'dll(,lofi, ami failng to keep adequate records as i1 lw..;j. for pricing daim CO:\IPL\INT Pursuant to the provisions of the Fedentl Trade Commission Act and the Fur Products Labeling Act and by virtue of the authority vested in it by sl1id Acts, the Federal Trade Conm1ission having reason to believe that Louis Furs Inc., a corporation, and Louis Carmen incli vic1ually and as an offccr of said corporation, hereinafter referred to as respondents, have violated the provisions of sa.icl Acts and the J1uses nnc111egllhtions promulgated under the Fur Products Labeling Act, and it appearing to the Commission that a proceeding by it respect thereof ,,,ould be in the public interest, hereby issues its complaint stating its charges in that respect as follows: UL\GIL-\PH 1. Respondent LOllIs Fuls Inc., is a corporation organized, existing and doing business under a,nc1 by virtue of the laws of the State of Indiana.
Respondent Louis Carmen is an offcer of the corporate respondent and formulates, directs, and controls the acts, practices, and policies of the said c.corporate respondent including those hereinafter set forth. Respondents are retailers of fur products with their offce and principal place of business located at 5258 Hohman A venue, city of Hammond, State of Indiana.
m. 2. Subsequent to the effective dat" of the Fur Products Labeling :\.ct on A-august D , 1D52, respondents have been and arc now engaged in the introduction into commerce, and jn t.he sale, achedising, and oilering for sale in ('omnlE'rcc. al1(l in the tl'fLm.iportatioll and distributiOJ1 in comme,rcc, of fnr products; and han, sold, advertised, oiTerec1 for, nJe, trilllsported and (li thl)jted fur products which han:: been llliHlc in ,, holr. or in part of fu1's "I"hieh have been shipped and received , \\ , 628 FEDERAL TRADE CQMMISSIOC' DECISIONS Complaint G5 F.
in commerce, as the terms "commerce fur" and " fur product ' are defined in the Fur Products Labeling Act.
PAn. 3. Certain of said fur products were misbranded in that they were falsely and deceptively labeled or otherwise falsely or deceptiwly identified with respect to the name or designation of tlw animal or animals that produced the fur from which the said fur products J"d been manufactured, in violation of Section 4(1) of the Fur Products Labeling Act.
Among such misbranded fur products, but not limited thereto.o, ,yerc fur products labeled as "Broadtail" thereby implyiug that the furs contained therein were entitled to the designation "Broadtail LamV' 1\hen in truth and in fact they were not entitled to such designation. PAR. 4. Certain of said fur products Were falsely and decepti,'ely invoiced by the respondent in that they ",ere not invoiced as required by Section 5 (b) (1) of the Fur Products Labeling Act and the Rules and Regulations promulgated under such Act. Among such falsely and deceptively invoiced fur products, but not limited thereto, were fur products covered by invoices which failed t.o show the true animal name of the fur used in the fur product. PAR. 5. Certain of said fur products were falsely and deceptively in1'oiced with respect to the name or designation of the animal or animals ,that produced the fur from which ,the said fur products had been manufactured in violation of Section 5(b) (2) of the Fur Products Labeling Aet.
Among such falsely and deceptively invoiced fur products, but not limited thereto ere fur products which were invoiced as "BroadtniF thereby implying that the furs contained therein were entitled to the designation "Broadtail Lamb:' when in truth and in fact they were not entitled to such designations.
PAR. 6. Certain of said fur products ,,'ere falsely and deceptively invoiced in violation of the Fur Products Labeling Act in that they were not invoiced in accordance with the Rules and Hegulations promulgated thereunder in the following respects: (a) The term "Dyed Broadtail-processed LRmb" was not set forth on in1'oices in the manner required hy law, in violation of Rule 10 of said Rules and Regulations.
(b) The term "natural" was not used on inroices to describe fur pl'ducts which were not pointed, bleached, dyed, tip-dyed, or otherwise artificially colored, in violation of Hule 19 (g) of said Rules and Regulations.
(c) Required item numbers ,ycre not set forth on invoices, in violation of Rule 40 of said Hules ,md Regulations. :
LOUIS FURS INC. ) ET AL. 629 627 Complaint PAR. 7. Certain of said fur products were falsely anel decepti\cely advertised in violation of the Fur Products Labeling Act in that certain advertisements int.ended to aid, promote and assist, directly or indirectly, in the sale and offering for sale of such fur products were not in accordance with the provisions of Section 5 (a) of the said Act. Among and included in the aforcsaid advertisements but not limit.ed thereto, were advertisements of respondents which appeared in issues of the Hammond Times, a newspaper published in the city of Ham mond, State of Indiana.
Among such false and deceptive advertisements, but not limited thereto, were ad vertisements w hieh failed: 1. To show the true animall1ame of the fur used in the fur product. 2. To show that fur products "ere composed of used fur, when such was t.he fa.ct.
PAR. 8. By means of the aforesaid advertisements and others of similar import and meaning not specifically referred to herein, rcspondents falsely and deceptively advertised fur products in that certain of said fur products were fa.1ely or de.ceptively identified "it.h respect to the name or designation of the animal or animals that produced the fur from which the said fur products had been manufac tured, in violation of Section 5 (a) (5) of the Fur Products Labeling Act.
Among such falsely and deceptively advertised fur products, but. not limited thereto, were fur products advertised as "Broadtail' thereby implying t.hat the furs cont.ained therein were ent.it.led to t.he des ignation "Broadtail Lamb" when in truth and in fact they were not entit.led t.o such designation.
PAR. 9. By means of the aforesaid advertisements and ot.hers of similar import and meaning not specifically referred to herein respondent.s falsely and deceptively advertised fur products in violation of Sect.ion 5(a) (5) of the Fnr Products Labeling Act. in t.hat. t.he said advertisements represented through stat.ement.s such as "Public Sale of Fur Cancellations and uncalled for storage. A large number of fur coats, fur capes, stoles and scarfs which were partly paid in layaway and st.orage. On sale at 10 a.m. Tomorrow, payment. of balance due-Makes it yours" either direct.ly or by implicat.ion, that the prices of such fur products were reduced from the prices at. which t.he re spondents regularly and usually sold such fur products in the recent regular course of business and the amount of such purported reduction constituted savings to the purchasers of respondents' products, when in fact such fur products were not fur cancellations uncalled for or partly paid in layaway and storage and were not reduced in price from the price at \vhieh the rpspondents regularly and usually sold such 630 FEDERAL TRADE CO L\IISSIOX DECISIONS Dcds1011 and 01'(1('1' 63 P. fur proaucts and savinp:s \were not aironlecl pnr('11a8e1'S of responc1('nts products fl.., represented.
PAH. 10. By means of the aforesaid acll-ertisements and others of similar import a.nd D1meaning not specifically referred to herein respondents falsely and deceptively advertised fur products in violation of the Fur Products Labeling .:\ct in t1Ul.,f the said fur products were not advertised in accordance ,..jth the Hllles and Regulations promulgated thereunder in the following respects: (a) The term "Dyed Broadtail-processed Lamb" was not set forth in the manner required, in violation of Rule 10 of the said Rules aud Regulations.
(b) The term "natuI'nl ' was not used to describe fur products "hieh were not pointed, bleached dyed, tip-dyed, or otherwise artificially colored, in violation of Rule 19 (g) of the saiel rules and regulations. (c) The disclosure "second-hand", where required, was not set forth in violation of rule 23 of the said Rules and Regulations. (d) An parts of the information required under Section 5 (a) of the Fur Products Labeling Aet and the Rules and Regulations promulgated thereunder were not set forth in type of eqult) size and C.Ollspicnousness and in dose proximity with each other, in violation of Rule 38(a) of the aforesaid Rules and Regulations. PAR. 11. In a.dvcrtising fur products for sale, as aforesaid, respondents made pricing c.aims and representations of the types cO\-creel by subsections (a), (b), (c), and (,I) of HuJe H of the Regulations U11I,,1' the Fur Products Labeling Act. Respondents in making such c1a,jms and representations failed to maintain fnn and adequatr. records clisclosing the facts upon v, which such pricing e1aims and rrpresenbtions were basod, in violation of Rule H(e) of the said rules and Regulations.
PAH. 12. The 'aforesaid acts and practices of respondent, as herein alleged, are in violation of the Fur Products Labeling Act and the Rules and Regulations promulgated thereunder ancl constitute unfair and deceptive acts and practices and unfair methods of competition in commClTC under the Federal Trade Commission Act. DECISION AND Order The Commission having heretofore determined to issue its compla.int charging the respondents named in the caption hereof with violation of the Federal Trade Commission Act and the Fur Products Labeling Act, and the respondents having been served with notice of said determination a,nd with a copy of the complaint the Commission intended to issue, together with a proposed form of order; and LOUIS l"URS INC. ! ET AL. 631 627 Decisioll and Grclel' The respondents and counsel for the Commission having thereaft,er executed an agreemEmt containing a consent order, an admission by respondents of all the jurisdictional facts set forth in the complaint to issue herein a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondents that the law has been violated as set forth in such complaint, and waiycrs and provisions as required by the Commission rules; and The Commission, having considered the agreement, hereby accepts same, issues its complaint in the form contemplated by said agreement makes the follml"ing jurisdictional findings, and enters the following order:
1. Respondent Louis Furs Inc., is a corporation organized, existing and doing business under and by virtue of the laws of the State of Indiana, with its offce and principal place of business located at 5258 IIohman Avenue, in the city of I-Iammond State of Indiana. Respondent Louis Carmen is an offcer of said corporation and his address is the same as that of said corporation. 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is 1n the public interest.
ORDER It is ordered That respondent Louis Furs Inc. a corporation: and its offcers, and respondent Louis Carmen, illc1iyjdualJy flnd as an offcer of said corporation, and respondents' representatives, agents Hnd employees, directly or through any corporate or ot,her device in connection with the introduction into commerce, or the sale, advertising or offering for sale 1n commerce, or the transport.ation or dist.ribution in commerce, of any fur product; or in connection with the sale, advertising, offering for sale, transportation or distribution, of any fur product "which is made in whole or in part of fur which has been shipped and received in commerce, as the terms "commerce "fur" and "fur product" are defined in the Fur Products Labeling Act, do forthwith cease and desist from:
A. Misbranding fur products by falsely or deceptively labeling or othern-jse identifying a.ny such fur product as to the name or designation of the 'animal or animals that produced the. fur contained in the fur product.
B. Falsely or deceptively invoicing fur products by: 1. Failing to furnish invoices to purchasers of fur products shov,-ing in "orels and figures plainly legible all the jnforma- 1"ion required to be disclosed in each of the subsectjons of Section 5(b) (1) of the Fur Products Labeling Act. 632 FEDERAL TRADE COyD1ISSIO DECISIOKS Decision and Orclel' 60 j.-' 2. Setting forth on invoices pert.aining to fur products any false or deceptive information with respect to the name or designation of the animal or animals that produced the fur contained in such fur product..
3. Failing to set forth the term "Dyed Broadtail-processed Lamb' in the manner required where an election is Inade to use that term instead of the words "Dyed Lamb" 4. Failing to set forth the term " N atnral" as palt of the information required to be disclosed on invoices under the Fur Products Labeling Aet and Rules and ltegnlations promulgated thereunder to describe fur products which are not pointed, bleached, dyed, tip-dyed or otherwise artificially colored.
5. Failing to set forth on invoices the item number or mark assigned to fur products.
C. Falsely or deceptively advertising fur products through the use of any advertisement, representation, public announcement or notice \\which is intended to aid, promote or assist, directly or indirectly, in the sale, or offering for sale of any fur product, and which:
1. Fails to set forth in words and figures plainly legible all the information required to be disclosed by each of the subsections of Section 5 (a) of the Fnr Products Labeling Act.
2. Falsely 01' deceptively identifies any such fur product as to the. name or designation of the animal or animals that produced the fnr contained in the fur product. 3. Fails t.o set forth the term "Dyed Broadtail-processed Lamb" in the manner required where an election is made to use that term instead of the words "Dyed Lamb" 4. Fails to set forth the t.erm "Natural" as part of the information required to be disclosed in advertisements under t.he Fur Products Labeling Act and the Rnles and Regulations promulgated thereunder to describe fur products which are not pointed, bleached, dyed, tip-dyed or otherwise artificially colored.
5. Fails to disclose that fur products contain or are composed of second-hand used furs.
6. Fails to set forth all parts of the information required under Section 5 (a) of the Fur Products Labeling Act and the Rules and Hegnlations promulgated thereunder in type of equal size and conspicuousness and in close proximity with each other.
, STYLE CRAFT CLOTHING co. 633 627 Complaint T. i\fisreprescnts in any manner the savings available to purchasers of respondents' fur products.
8. Falsely or deceptively represents in any mallner that pric2s of respondents' fur products are reduced. 9. Hepresents directly or by implicat.ioll contrary to fact that any such fur products ate fur cancellations, uncallell for or partly paid in layaway and storage.
D. laking daims and representation of the types covered by suboections (a), (b), (c) and (d) of Rule 44 of the Rules and Regulat.ions promulgated under the Fur Products Labeling Act unless there arc maintained by respondents full and adequate records disclosing the facts upon which such claims and representations are based.
It further' oi'dered That the respondents herein 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 have complied with this order.