Walter J. Black, Inc.

Text (OCR of the scan at left; may contain errors)

and form in which they hate comp1iecl \with this order. T THE l\L6.TTEn OF WALTER .J. BLACK, IXC.

COXSEXT orner: ETC. , IN REGARD TO THE ALLEGED VIOLATION OF THE FEDERAL TR rllnssIO:!'" AC'I' Docket 0- /77, Complaint June BO , 19G' Decision, June 30, 196-1 Consent order requiring a Rosl.vn, XY. , seller to the general public of pul.licacations, books and other merchandise under its own name and under the names "The Classics Club" Black' s Readers Service Company " and "The Detective Book Club", to cease representing falsely in letters and other materials sent to purportedly delinquent customers that, if payment was not made, customer s name would be transmitted to a credit rel)urting agency and his credit rating adversely affected; and, by use of letterheads of the fictitious "Tile MAIL CRBJDIT REPORTING ASSOCIA- TIO::\ I::TO", and "John J. ::lurpby, Attorney at Law, that accounts wouldORDERbe or had been turned over to a bona fide collection agency or an out:-icle attorney for collection or legal proceedings. CO:YIPL.UXT Pursuant to the provisions of the Federal Trade Commission Act Rnd by virtue of the authority vested in it by said Act, the Federal 1VALTEH J, BLACK, INC. 1269 l::li Complaint Trade Commission, having reason to believe that '''alter J. Black Inc., a corporation, lwreina.after referred to as respondent, has violated the provisions of said Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest hereby issues its complaint stating its charges in that respect as follows:

PAIL\GRAPH 1. Respondent 'V alter J. Black, Inc., is a corporation orga,nized, existing and doing business under and by virtue of the laws of thc State of New York, with its principal offce and place of business located at Northern Boulevard, in the city of Roslyn, State ofKew York.

PAR. 2. Respondent is now, and for some time last past has been engaged in the advertising, offering for sale, sale and distribution of publications, books, and other merchandise to the general public. Hcspondent sells the aforesaid publications, books and other merchandise under its own name and lmder the names "The Classies Club" Black' s Readers Service Company" and "The Detective Book Club" The aforesaid publications, books and merchandise are advertised 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 caused, its said publications books and merchandise, when sold, to be shipped from its place of business in the State of K ew York to purchasers and subscribers thereto located in the various other States of the Uuited States and in the District of Columbia, and maintains, and at all times mentioned herein has maintained, a substantial course of trade in said publications, books and merchandise in commerce, as "commerce" is defined inthe Federal Trade Commission Act.

\R. 4. In the course and conduct of its business and for the purpose of inducing the payment of purportedly delinquent accounts respondent has made certain statements and representations in letters and materials sent through the United States Mails to purportedly delinquent customers who have purchased respondent's publications books, or other merchandise.

Typical, but not all inclusive of said statements and representations arc the following:

a. On respondent's letterheads:

Is there any reason * * * 'VHY PAY).ient O THIS P.AST DVE .ACCOUKT HAS BEEX WITHHELD? MEMO FHO i: THEASUEER'S OFFICE PLEASE KOTE: It is with regret that we send OU the attached notice. However, we have been instructed to do so by Oil' Auditor because of the delinquent condition of your account.

1270 FEDERAL TRADE CO:\L\JISSION DECISIONS Complaint G5 F. T.

FINAL NOTICE:

On date mentioned above your account wil be placed with THE :\IAIL ORDER CREDIT RFJPOR'l'IXG ASSN. INC., 15 West 38th Street. New York 18, X.

Our firm is a subscriber to the Mail Credit Reporting Association 15 'Vest 38th Street, New York, N. Y. Like all other subscribers, we are en-Ordertitled to check any Dalles against their master file of mail order non-payer;;. Under the terms of our subscription, we are also required to make available to the Association the names of persons who have ordered and received books from us, and who have failed to settle their account with us after repeated. notificationsovei' a period of tjme * '" * b. On the letterhead:

THE MAIL CREDIT REPORTING ASSOCIATION, INC. Credit Reports '' '" * CollectionsOIWER New York 18, N, y, C(UW Xo. 72- Claim of THE CLASSICS CLUB A.'l'TEKTIO?\' PLEASE! The Classics Club has requested us to write you in the hope that we can help bring about a friendly 8settlement fJf your long over due acc01tnt. TAKE KOTICE rhat:

1Ve have been authorized by THg CLASSICS CLTJB to collect the arnoum you owe them for books they delivered to yon at your specific ill stance and request.

You mayor may not know that there are legal means open to our client of enforcing payment of a debt of this kind. Whether or not they must employ such measures in your case is entirely up to you. Prompt payment wil clear the slate 'Ivithout any nnpll' :1santncss " .. '" FI:\AL NOTICE! Your failure to settle yonI' account lea,es onr client no choice but to t.'ke immediate action against YOll.

If, within fifteen days from date of attached invoice, settlement in full is not in tile hands of The Clas,'iics Club, our cient has stated that they .011 unconditionally turn your account over to their legal representath-e with ii"' structions to proceed wit.h the necessary steps to enforce collection. You realize, of course, that such action may result in court costs payable by you in addition to the amount due.

c. On the letterhead:

John J. Murphy, Attorney at Law, 15 West 38th St., Xew York 18 Re: THE CLASSICS CLUB TAKE NOTICE 'l' HAT:

I have been consulted by my client in connection 'Ivith their claim against: you for goods sold and clelivered, in the amount shown on the enclosed statement.

(g) WALTER J. BLACK, INC. 1271 1268 Complaint :\fy client advises that this claim arises out of books ordered by you, shipped to you but not paid for despite several demands by my client. I have been requested to write you to offer one final opportunity to pay this small bil. .

PAR. 5. By a,nel through the use of the aforesaid statements, representations and practices and others of similar import not specifically set out herein, respondent has represented that: (a) If payment is not made, the delinquent customer s na,me is transmitted to a bona fide credit reporting age,HCY. (b) If payment is not made, the customer s general or public credit rating will be adversely affected.

(c) If payment is not made, respondent is required to refer the information of such delinquency to "THE IAlr. ORDER CREDIT REPORTING ASSOCIATION , INC.

(d) ..THEMAIL onder cmmIT REPORTING ASSOCIATION, INC. " is a separate bona fide collection and credit report agency Jocated in New York City.

(e) Respondent ha.s turned over to "THE r.IAIL ORDm CREDIT REPORT- IXG ASSOCIATION, INC. " the delinquent account of the cllstomer for collection and other purposes.

(f) If payment is not made, the delinquent sells tomer s account "\ill be transferred to an outside attorney with instructions to institute suit or take other legal steps to collect the outstanding amount due. .:11'. John J. Murphy" is an outside attorney at law, located in Kew York City, to \vhomt.he delinquent customer s account has been transferred for institution of suit or other legal stBps. (h) Letters and notices on the letterheads of the said "THE, MAIL ORDER CREDIT REPORTING ASSOCIATION, INC." and "John J. )lurphy, At.torney at Law" have been prepa.red and mailed by said organization or named attorney.

PAR. 6. In truth and in fact:

(a) If pa,yment is not made, the delinquent customer s name is not transmitted to a bona fide credit reporting agency. (b) If payment is not made, the customer s general or public credit rating is not adversely affected.

(c) If payment is not made, respondent is not required to refer the information of such delinquency to "THE MAIL CREDIT REPOHTI ASSOCIATION, INC. , or any other organization or agency.ORDER (d) "THE MAIL CREDIT REPORTING ASSOCIATION, IXC." is notORDERseparate, bona fide collection or crcdit reporting agency. Said organization is a fictitious name utilized by respondent and others for purposes of disseminating collection letters.

J272 FEDERAL TR.-ide COMMISSION DECISIO Decision and Order 65 F. T. (c) Respondent has not turned over to "THE l\L\1L ORDER CREDIT nE PORTIXG ASSOCIA'l'IOK , I : t.he delinquent account of the customer for collection or any other purposes.

(f) If i)ayment is not ma,cle, the delinquent customer s account is not transferred to an outside attorney with instructions to institute sllit or other legal steps to conect the outstanding amount due. (g) The delinquent cust..mer s account has not been transferred to Mr. John J. lurphJ"" fol' institution of suit or other legal steps. (h) The letters anclnotices on the letterheads of "THE :!IAIL ORDER CREDlT REPORTING ASSOCL\TION , INC.:: and " John J. Murphy, Attorney hate not been prepared and mailed by said organization or at La\y:i named attorney. Said letters and notices haye been prepared and mailed or caused to be mailed by respondent. Replies and responses to said letters and notices are forwarded unopened to respondent. Therefore, the statcmcnts and representations as set forth in Para.graphs Four and Five hereof ,were and are false, misleading and deceptive.

\.R. 7. The use by respondent of the a.foresaid false, misleading and deceptive tatements, representations and practices has had, and now has, the capacity and tendency to misle Ld members of the purchasing public into the erroneous and mistaken belief that said statements and representations were and are true and into the paymel t of subst,lntial sums of money to respondent by reason of said 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 and practices in commerce, in violation of Section 5 of the Federal Trade Commission Act.

DECISION AND OUDER The COll1nission having heretofore determined to issue its complaint charging the respondent naJned in the caption hereof with violation of the Federal Tmde 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 with a proposed form of order; and The respondent and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by respondent of all the jurisdictional facts set forth in the complaint to issue herein, a statement that the signing of sa,id agreement is for settlement purposes only and does not constitute an admission by l'e pondent that. the law has been violah d as set forth in such com- WALTER J. BLACK, INC. 1273 1268 De.cision and Order plaint, and waivers 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 agreeme,nt., makes the following jurisdictional findings, and enters the fol- Imying order:

1. .Respondent W alter J. Black, Inc. , is a corporation organized existing and doing business under and by virtue of the laws of the State of Sew York, with its principal offce and place of business located at Xorthern Boulevard, in the city of .Roslyn, State of Xew Yark.

2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is iu the public interest.

GIWEn It is ordered That respondent ,"1alter J. Black, Inc., a corporation and its offcers, agents, representatives and employees, directly or through any corporate or other device, in connection with the offeringfor sale, sale or distribution of publications, books or other merchanelise, in commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cea.se and desist from representing directly or by implication that:

1. a. A customer s name will be or has been turned over to a bona fide credit reporting agency unless respondent establishes that "\here payment is not received, the information of said delinquency is referred to a separate, bona fide credit reporting agency;

b. A customer s general or public credit rating will be adversely affected unless respondent establishes that yvhere payment is not received, the infonnation of said delinquency is referred to a separate, bona fide credit reporting agency or other busines organizations;

2. a. Respondent is required to refer information of a customs delinquency to "THE ::L\IL ORDER CREDIT REPORTJKG c\SSOCIA- 'rIDX , IXC.

b. Respondent is required to refer information of a customer delinquency to any other agency or bureau, unless respondent e,tablishes that such is the fact;

:3. Dclinqnent accounts wi! bc. or hayc. been tlll'llec1 over to a bona fide, separate collection agency 01' attorney for collection unless respondent in fact turns f.uch accollnts over to such agencjes or attorneys;

313-121--70-- 1274 FEDERAL TRADE CO:.L\fISSIOK DECISIONS 'llabll:' 65 F.

4. Delinquent accounts have been or will be turned over to THE ::IAIL ORDER CREDIT Importing ASSOCIATION, IXC. " for collection or any other purpose;

5. " THE MAIL CREDIT REJ' ORTING ASSOCIATW:;T , INC. , any fictitious name, or any trade l1Rm8 owned in whole or in partORDER by respondent or oyer \)which respondent exerc.ises operating control, is an independent, bona fide collection or credit reporting agency;

G. " John J. ::.ful'phy " or any other person or finn is an outside, independent attorney at hw or firm of attorneys representing respondent for collection of past clue accounts, unless re sponclcnt establishes that a bona fide attorney-client relationship exists beLlreen respondent a,ncl said attorney or attorneys for purposes of collecting such accounts;

7. Delinquent accounts have been or will be turned OYer to TUE :;IAIL ORDER CREDIT REPORTING .ASSOCIATlOK. INC. with instructions to institute suit 01' other legul action to collect amounts purportedly due; or that any account.s have bCCH or \will be turned over to any organiza.tion flt:0l'1CT or fin); of attorneys, or pcrsons '\with instructions to institute suit 01' other legal action unless l' respondent establishes that such is the fact; 8. Letters, notices or other commlllications in connection '\with the collection of respondent' s accounts which have been prepared or originated by respondent have been prepa.red or Ol'jg:inntcd by any other persoll firm 01' corporation.

J tis further ordered That the respondent herein shall, '\vit 11 in ixt.y (60) days niter service upon it of this order, file with the Commi .sion a. report in writing setting forth in detail the manner ancl form in ,Yhieh it has complied with this order.

I x THE -:L\ TTElt Ol ROBERT M. SPELLMAN TRADING AS BOB SPELLMAN FFRS ETC, COXSEKT ORDER, ETC. , IN REGARD '1'0 'Tile ALLEGED VIOU'lTIOX OF THE FEDERA.I, TRADE COi\nI1SSIOX AXD THE FUR PROD"CCTS LABELING ACTS Docket C-"i78. Comr,zaiut, Julie 30, lY6. Deci.sion, June 30 19DJ, Cm.lsent onJ('1' requiring a rrtail furrier in Los \angeles to cease violating the Fur Proclnds Labeling _-\ct by failing to use the term "natural" for furs that were not artificially colored, in advertising, in,oicing and labeling; failing to set forth the term "Dyed Broadtail-processed Lamb" on labels as , BOB SPELLMA), F"GRS, ETC. 1275 1274 Complaint required; failng to show the true animal name of fur and the country of origin of imported furs in invoicing; failing to maintain adequate records as a basis for pricing claims; substituting non-conforming labels for those originally affxed to fur products and failng to preserve the records requi red; and failng in otller respects to comply with requirements of the Act.

CO)Il LAI Pursuant to the provisions of the Federal Trade Commission Act and the Fur Products Labeling Act and by virtue of the authority vested in it by said Acts, the Federal Trade Commission having reason to believe that Robert :VI. Spellman, individually and trading as Bob Spellman Furs, Furs by Bob Spellman, and Mordell Furs, hereinafter referred to as respondent has violated the provisions of saiel Acts and the Rules and Regulations promulgated under the Fur Products Labeling Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest hereby issues its cOlnplaint stating its charges in that respect follows:

PAfu\CRAPH 1. Respondent Robert :VI. Spellman is an individual trading as Bob Spellman Furs, Furs by Bob Spellman, and Mordell Furs who formulates the acts, practices and policies of said business. Respondent is a retailer of fur products with his offce and principal place of business located at 3710 'Wilshire Boulevard, Los Angeles 5 California.

P AU. 2. Subsequent to the effective date of the Fur Products Labeling Act on August 9, 1952, respondent has been and is now engaged in the introduction into commerce, and in the sale, advertising, and offering for sale in commerce, anll in the transportation and distribution in commerce, of fur products; and has sold, advertised, offered for sale, transported and distributed fur products which have been made in whole or in part of furs which have been shipped and received in commerce, as the terms "commerce fur" and "fur product" are defined in the Fur Products Labeling Act. PAR. 3. Certain of said fur products were misbranded in violation of the Fur Products Labeling Act in that they were not labeled in accordance with the R.llles and Regulations promulgated thereunder in the following respects:

1. The term "Dyed Broadtail-processed Lamb" was not set forth on labels in the manuer required by law, in violation of Rule 10 of said Rules and Regulations.

2. The term "natural" was not used on labels to describe fur products which were not pointed, bleached, dyed, tip-dyed, or otherwise artificially colored, in violation of Rule 19 (g) of said Rules and Regulations.

313-121--70- FEDERAL TRADE LV1ISSIOK DECISIONS1276 Complaint 65 F.

3. Information required under Section 4(2) of the Fur Products Labeling Act and the Rules and Regulations promulga,ted thereunder wa,s not set forth in the required sequence, in violation of Rule 30 of said Rules and Regulations.

4. Required item lllUnbers were not set forth on labels, in violation of Rule 40 of said Rules and Regulations.

PAR. 4. Certain of said fur products were falsely and deceptively invoiced by the respondent in that they were not invoiced as required by Section 5 (b) (1) of the Fur Products Labeling Act and the Rules and Heguhttions promulgated under such Act. Among such falsely and deceptively invoiced fur products, but not limited thereto, were fur products covered by invoices which failed: 1. To show the true a,nimnl name of the fur used in the fur product. 2. 'lo show the country of origin of imported furs used in fur prod ucts.

PAR. 5. Certain of said fur products were falsely and deceptively invoiced in violation of the Fur Products Labeling Act in that they were not invoiced in accordance with the Rules and Regulations promulga ted thereunder in the following respects: (a) Information required under Section 5(b) (1) of the Fur Products Labeling Act and the Rules and Regulations promulgated thereunder was set forth on invoices in abbreviated form, in violation of llule 4 of said Rules and Hegll1ations.

(b) The tern1 "natural" was not used on invoices to describe fur products which were not pointed, bleached, dyed, tip-dyed or otherwise artifcia,JJy colored, in viobtion of Rule 19 (g) of saidllules and Regnhltions.

(c) Required item 111lnbers were not set forth on invoices, in violation of Rule 40 of said Rules a,ndllegulations. PAR. 6. Certain of said fur products were falsely a,nd deceptively advertised in viola,tion of the Fur Products Labeling Act in that certain advertisements intended to aid, promote and assist, directly or indirectly, in the sale and offeri.ng for sale of such fur products were not in accordance with tho provisions of Section 5 (a) of the said Act. Among and included in the aforesaid advertisements but not limited thereto, were advertisements of respondent which appeared in issues of the Los Angeles Times, a newspaper published in the City of Los Angeles, State of California.

PAR. 7. By meallS of the aforesaid advertisements and ot11ers of similar import and meaning not specifically referred to herein, respondent falsely and deceptively advertised fur products in violation of the Fur Products L.abelil1g Act in that the term "natural" was not used to describe fur products which were not pointed, blea,checl, dyed BOB SPELLMAK FURS , ETC. 1277 1274 Decision and Order tip-dyed or otherwise artifically colored, in violation of Rule 19(9) of the said Rules and Reguh1tions.

PAH. 8. In advertising fur products for sale, as aforesaid, respondent made pricing claims and representations or the types covered by subsections (a), (b), (c) and (d) of Rule 44 of the Regulations under the Fur Products Labeling Act. Respondent in making such claims and representations failed to maintain full and adequate records dis. dosing the facts upon which such pricing claims andre-presentations were based, in violation uf Rule 44 (e) of the said Rules and Regulations.

PAR. 9. Respondent in introducing, selling, advertising, and ofiering for sale, in commerce, and in processing for commerce, fur products j and in selling, advertising, oih ring for sale and processing fur products which have been shipped and received in commerce, has misbranded such fur products by substituting thereon, labels which did not conrorm to the requirements or Section 4 or the Fur Products Labeling Act, for the labels affxedlo said fur products by the manufacturer or distributor pursuant to Section '1 or said Act, in violation of Section 3 (e) of said Act.

\R. 10. Respondent in .snbstiT116ng labe lei as provide, d for in Section ;::(e) of the Fur Products Labeling Ac:t, has failed to keep and preserve the records required, in violation of said Section 3 (e) and Hule 41 of the 11ules and Regulations promulgated under the said Act.

PAR. 11. The aforesaid acts and practices of respondent, as herein alleged, are in violation or the Fur Procluds Labeling Act a.nd the 1\ulos and Regulat,ionspromulgated thereunder and constitute unfa.ir and deceptive acts and pra,ctices a,ncl unfair methoels of competition in commerce under the Federal Trade Commission Act. DECISION AND ORDER The Commission having heretofore determincd to issue its complaiut charging the respondent na,mod in the caption hereof with violation of' the Federal Trade Commission Act and the Fur Products Labeling Act, and the respondent having been served with notice of sold detennination and with a copy or the complaint the Commission intended to issue, together with a ,proposed rorm of order; and The respondent and counsel ror the Commission having ther alter executed an agreement containing a consent order, an admission by respondent of all the jurisdictional facts set forth jn the complaint to issue herein, a statement that the signing of saiel agreement is for settlement purposes only and does not constitute an acunissioll by Decision and Order 65 F.'l'. respondent that the law has been violated as set forth in such complaint, and waivers and provisions as required by the Commission rules; a.nd The Commission, having considered tlle agreement, hereby accepts same! issues its complaint in the form contemplated by said agreement, makes the following jurisdictional findings, and enters the following order:

1. Respondent Robert :\1. Spellman is an individual trading as Bob Spellman Furs, Furs by Bob Spellman, and Mordell Furs, with his offce and principal place of business located at 3ilo .Wilshire Bouleyard, in the city of Los Angeles, State of California. 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is in tlle public interest.

onder It is ordered That respondent Robert I. Spellman, individually and trading . as Bob Spellman Furs, Furs by Bob Spe1Jman, and lorden Furs :l1d respondent' s representatives, agents and employees, directly or through any corporate or other device, in connection with the introduction, into commerce, 01' the sale, ad \ erLisillg or oii'erlng Jar sa1eill commerce, or the transportation or distribution in commerce of any fur product; or in connection with the sale, advertising, offer ing 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 cmnmerce, as "col111erce, "fur and " fur product" are defined in the Fur I)roclucts Labeling Act, do forthwith cease and desist from: A. :llisbranding fur products by:

1. Failing to set forth the term "Dyed Broadtail-processed Lamb" on labels in the manner required where an election is made to use that term in Jieu of the term "Dyed Lamb" 2. Failing to set fort.h the term "natural" as part of the information required to .be disclosed on labels under the Fur Products Labeling Act and the Rules and Hegulations pro- 111ulgatec1 thereunder to describe fur products which are not pointed, bleached, dyed, tip-dyed or otherwise artificially colored.

3. Failing to set forth informaiion required under Section 4 (2) of the Fur Products Labeling Act and ,the Rules and Regulations promulgated (hereunder on labels in the sequence required by Rule 30 of the afores id Rules and Regulations. 4. Failing to set forth on labels the item number or mark assigned to a fur product.

BOB SPELLMAN F1:RS, ETC. 1279 1274 Decision and Order B. Falsely or deceptively invoicing fur products by: 1. Failing to furnish invoices to purchasers of fur products showing in words and figures plainly legible aU the inform aation required to be disclosed in each of the subsections of Section 5 (b) (1) of the Fur Products Labeling Act. 2. Setting forth information required under Section 5 (b) (1) of the Fur Products Labeling Act and the Rules and Regulations promulgated thereunder in abbreviated form. 3. Failing to set :forth the term "natural" as part of the blformation required to be disclosed on in'l'oices under the Fur Products Labeling Act and Rules and Hegulations promulgated thereunder to describe fur products which arc not pointed, bleached, dyed, tip-(Jyed or otherwise artificially colored.

4. Failing to set forth on invoices the item number or ma.rk assigned to fur products.

C. Falsely 01' decepti\'ely advertising fur products through the use of any adverti::cement, representation, public announcement or notice which is intended to aic1 promote or assist, directly or indirectly, in the sale, 01' offering for sale of any fur product, and which :fails to set forth the term "natural' as part of the in101'nation required to be disclosed in advertisements under the Fur Products Labeling Act and the Rules and Hegulatiol1s promulgated thereunder to describe fur products which a.re not pointed bleached, dyed, tip-dyed or othenrise artificially colored. D. l\laking claims and representations of the types covered by subsections (a), (b), (c) and (d) of Rule 44 of the Rules and R.egulations promulgated under the Fur Products Labeling Act unless there arc ma1nta1ncd by respollllent full and adequate records disclosing the fact.s upon ",which such claims and repre3ellta tions are based.

/t is further ordeJ'xl That respondent Robert),1. Spellman, inc1iyidually and trading as Bob SpeJlman Furs Furs by Bob Spellman and l\lorc1ell Furs and rcspondenfs representatives, agents and emplo ecs directly or through any corporate or other device, in connection ,,-ith the introduction, sale, advertising or offering for saJe, in commerce the processing for comme.rcc, of fur products; or in connection "\ith the selling, advertising, oUering for sale or processing of fur products \"111('h hf1\-e been shipped and rc('ei\-ed in commerce, do forthwith cease and desistfrorll :

A. J\1isbranding fur products by substituting for the labels nf fixed to such fur products pursuant to Section 4 of the Fur Products Labeling Act labels "\which do not conform to the requirements 1280 FEDERAL 'TRADE COMMISSION DECISI01\ Complaint 65 :I.

of the aforesalc1 Act and the Rules and Hcgulations promulgated thereunder.

B. Failing to keep and preserve the records required by the Fur Procll1cts Labeling ..-\ct and the Rules and R.egnlations promulgated thereunder in substit.uting bbels as permitted by Section 3 ( e) ofthe said Act.

It is furthe' onlered That the respondent herein shall, within sixty.y (GO) clays after service upon him of t.his order, file with the Commission a report in Wrill11g setting forth in detail the manner and form in which he has complied with this order.