Brown Auto Stabilizer Co

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In THe Matrer oF BROWN AUTO STABILIZER CO., ET AL.

ORDER, OPINION, ETC., IN REGARD TO THE ALLEGED VIOLATION OF THE FEDERAL TRADE COMMISSION ACT Docket 8863. Complaint, Sept. 21, 1971—Decision Nov, 8, 1972 Order requiring an Orlando, Florida, retailer and distributor of “Dynamic Absorbers,” among other things to cease misrepresenting the qualities and properties of its products; using the word “stabilizer” as part of its corporate or trade name; and misrepresenting the extent, kind, character, or results of any scientific tests performed on any of its products. Complaint Pursuant to the provisions 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 Brown Auto Stabilizer Co., a corporation, and Charles R. Brown, individually and as an officer of said corporation, hereinafter referred to as respondents, have 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:

Paracrapn 1. Brown Auto Stabilizer Co. is a corporation organized, existing and doing business under and by virtue of the laws of the State of Florida, with its principal office and place of business located at 5503 South Orange Blossom Trail, Orlando, Florida. Respondent Charles R. Brown is an individual and an officer of the corporate respondent. He formulates, directs, and controls the acts and practices of the corporate respondent including those hereinafter set forth. His address is the same as that of the corporate respondent.

494-841—73——48 746 FEDERAL .TRADE .COMMISSION. DECISIONS Complaint 81 F.T.C.

-. Par. 2. Respondents are now, and for some time last past have been, engaged in the advertising, offering for sale, sale and distribution of Brown “Dynamic Absorbers” to distributors and to the public. Par. 3. In the course and conduct of their business as aforesaid, respondents have caused, and now cause, their said “Dynamic Absorbers” to be shipped from their. place of business in the State of Florida to purchasers thereof located in various other States of the United States. Respondents, therefore, maintain, and at all times mentioned herein have maintained, a substantial course of trade in commerce, as “commerce” is defined in the Federal Trade Commission Act. Par. 4. In the course and conduct of their aforesaid business, and for the purpose of inducing the purchase of the Brown “Dynamic Absorbers,” the respondents have made, and are now making, numerous statements and representations i in newspaper advertisements, in brochures and pamphlets, and in oral promotional presentations with respect to the performance of the Brown “Dynamic Absorber.” Typical and illustrative of said statements and representations, but not all inclusive thereof, are the following: — The. Brown Dynamic Absorber takes. over where your -shocks leave off..* * *- ‘The Brown Absorber dampens the lateral or side sway motion of your car keeping the rear wheels tracking the front to give you utmost control of your car under all driving conditions.

We know and our customers agree that any ear equipped with a Brown Dynamic Absorber is a safer car to drive under all conditions than a car not Similarly equipped.

* *.* the Brown Dynamic Absorber to augment conventional controls on automobiles to give drivers better control of their cars under all driving conditions. Blow outs can cause serious accidents under the best driving conditions. The Brown Dynamic Absorber could provide the extra margin of safety that could save your life.

‘You can have a Brown Dynamic Absorber installed in your car to augment the conventional controls and get automatic, mechanical help when you need it to prevent many needless auto accidents from happening. It helps drivers stop cars faster and straighter. Does a Brown Auto Stabilizer help on slippery surfaces? Yes. * * * Par. 5. By and through the use of the above-quoted statements and representations, and others of similar import and meaning, but not expressly set out herein, and by and through the use of the word | “Stabilizer” in their corporate and trade name or to describe or refer _ to their Dynamic Absorber in any other manner, separately and in connection with the oral statements to prospective purchasers and purchasers, respondents have represented, and are now representing, directly and by implication:

1. That the Brown Dynamic Absorber is an effective safety device. 2. That the Brown Dynamic Absorber is an anti-skid device which BROWN. AUTO STABILIZER CO., ET AL. 747 745 Complaint will help prevent skidding, spin-outs, unwanted motion, and accidents. 3. That the Brown Dynamic Absorber will help save lives. 4, That the Brown Dynamic Absorber will keep the rear wheels of an automobile tracking the front wheels, give the driver added control, and help keep a skidding automobile going straight. . 5. That the Brown Dynamic Absorber will help control automobiles during panic stops or sudden turns.

6. That the Brown Dynamic Absorber will help control automobiles on wet or sandy road surfaces.

7. That the Brown Dynamic Absorber performance representations have been substantiated by competent scientific tests or by authenticated, controlled and duly recorded tests. Par. 6. In truth and in fact:

1. The Brown Dynamic Absorber is not an effective safety device. 2. The Brown Dynamic Absorber is not an anti-skid device which will help prevent skidding, spin-outs, unwanted motion, and accidents. 8. The Brown Dynamic Absorber will not help save lives. 4. The Brown Dynamic Absorber will not keep the rear wheels of an automobile tracking the front wheels, give the driver added control, and help keep a skidding automobile going straight. 5. The Brown Dynamic Absorber will not help control automobiles during panic stops or sudden turns.

6. The Brown Dynamic Absorber will not help control automobiles on wet or sandy road surfaces.

7. The Brown Dynamic Absorber performance representations have not been substantiated by competent scientific tests or by authenticated, controlled and duly recorded tests.

Therefore, the statements and representations set forth in Paragraphs Four and Five-hereof were, and are, unfair practices and are false, misleading and deceptive.

Par. 7..In the course and conduct of their aforesaid business, and at all times mentioned herein, respondents have been, and now are, in substantial competition, in commerce, with corporations, firms, and individuals engaged in the business of selling stabilizer, traction, and other safety devices and equipment.

Par. 8. The use by respondents of the aforesaid false, misleading and deceptive statements, representations 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 and representations were and are true and into the purchase of substantial quantities of respondents’ product by reason of said erroneous and mistaken belief.

748 FEDERAL TRADE COMMISSION: DECISIONS Initial. Decision 81 F.T.C.

Par. 9. The aforesaid acts and practices of respondents, as herein. alleged, were and are all.to the prejudice and injury of the public and of respondents’ competitors, and constituted, and now constitute unfair methods of competition in commerce and unfair and deceptive acts and practices in commerce in violation of Section 5 of the Federal Trade Commision Act.

_ Mr. C. Powers Dorsett and Mr. William E. Mumford supporting the complaint.

Mr. William L. Eagan, Arnold, Mt atheny & Hagan, Orlando, Florida. for respondents. ;

Inttrat Decision By Epwarp Creer, Haring EXAMINER APRIL 24,1972 PRELIMINARY STATEMENT The Federal Trade Commission. issued its complaint i in this pro-~ ceeding on September 21, 1971, charging respondents Brown Auto: Stabilizer Co., a corporation, and Charles R. Brown, individually and as an officer of the corporation, with violations of Section 5 of the Federal Trade Commission Act. It was alleged that the respondents had represented that a mechanical device when attached to an automobile would make it safer to operate by helping to prevent skidding, spin-outs, unwanted motion, and accidents. It was also alleged that respondents had represented that the performance claimed for the device had been substantiated by competent scientific tests or by authenticated, controlled, and duly recorded tests. It was further. alleged that these advertising claims for the product were false and that the performance of the device had not. been substantiated by competent scientific tests or by authenticated, controlled, and duly recorded tests.

A prehearing conference was held in advance of the hearings at which a clarification of the pleadings and some admissions of minor allegations were made. It was later agreed between counsel that the only issue to be tried was “whether or not the Brown Dynamic Absorber is effective for its intended purpose.” (Tr. 80) 1 Hearings were held for 3 days in Orlando, Florida. Following the close of the presentation of evidence in support of the complaint, the respondents moved for dismissal of the complaint. Ruling was reserved on this motion until this time and the motion is now denied. 1The abbreviations used herein are “Tr.” for transcript of prehearing conference and testimony, and “CX” for Commission Exhibit. BROWN AUTO STABILIZER CO., ET AL. 749 745, Initial ‘Decision This proceeding is before the hearing examiner for final consideration upon the complaint, answer, testimony and other evidence, and proposed findings of fact and ‘conclusions filed by the parties. As stated above, the only ..contested issue: is the. effectiveness of respondents’ device as claimed in their advertising. Consideration has been given to the proposed findings of fact and briefs, and all proposed findings of fact and conclusions not hereinafter specifically found or concluded.are rejected; and the hearing examiner, having considered the entire record herein, makes the following findings of fact and conclusions drawn therefrom and issues the following order: ~ FINDINGS OF FACT 1. Brown Anto Stabilizer Co. is a corporation organized, existing, and doing business under and by virtue of the laws of the State of Florida, with its principal office and place of business located. at 5503 - South Orange Blossom Trail, Orlando, Florida (Tr. 6). 2. Respondent Charles R. Brown i is an individual and an officer of the corporate respondent. He formulates, directs, and controls the acts and practices of the corporate respondent including those hereinafter set forth. His address i is the same as that of the corporate respondent. (Tr. 6) 3. Respondents are now, and for some time last past have been, engaged in the advertising, offering for sale, sale, and distribution of Brown “Dynamic Absorbers” to distributors and to the public (Tr. 32-33, 40).

4. In the course and conduct of their business as aforesaid, respondents have caused and now cause their said “Dynamic Absorbers” to be shipped from their place of business in the State of Florida to purchasers thereof located in various other States of the United States. Respondents, therefore, maintained and at all times mentioned herein have maintained a substantial course of trade in commerce, as “commerce” is defined in the Federal Trade Commission Act. (Tr. 6-7) 5. In the course and conduct of their aforesaid business and for the purpose of inducing the purchase of the Brown “Dynamic Absorbers,” the respondents have made and are now making numerous statements and representations in. newspaper advertisements, in brochures and pamphlets, and in oral promotional presentations with respect to the performance of the Brown “Dynamic Absorber” (Tr. 7-8; CXs 7, 8,9,14).

Typical and. illustrative of said statements and representations, but not all inclusive thereof, are the following: . Initial Decision: 81 ETC.

. The. Brown Dynamic Absorber takes over where your shock absorbers leave off. * * * The Brown Absorber dampens | the lateral or side sway: motion of your. car keeping the rear wheels tracking, the front: ‘to’ give you utmost control of your car under ali driving conditions."

“We know and our customers agree’ that any ear equipped with a Brown Dynamic Absorber is a-safer car to drive’ under. all: conditions: than a ear not. similarly: equipped. |...

** * the Brown Dynamic Absorber: ‘to augment conventional controls on automobiles to give drivers better control of their cars under all driving conditions.

- Blow outs’ can cause serious accidents under the best driving conditions. The Brown Dynamic:Absorber could provide the-extra margin of safety that could save your life.

You can have a Brown Dynamic. Absorber. installed in your car to augment the conventional controls and get automatic, ‘mechanical help when you need it to prevent many needless auto,accidents from happening... Q. What does it do? A. It helps drivers stop« cars faster and straighter, _ Q. Does a Brown Auto Stabilizer help on slippery surfaces? A. “Yes, ila _ 6. By and ‘through | the use of the ‘above-quoted ‘statements and représentations, and others of similar import and meaning but not expressly set out herein, and by and through the use of the word “Stabilizer” in their corporate and trade name or to describe or to refer to their Dynamic Absorber, separately and in connection with oral statements to prospective purchasers, and purchasers, respondents have represented and are now representing, directly and by implication:

That the Brown Dynamic Absorber is an effective safety device. That the Brown Dynamic Absorber is an anti-skid device which will help prevent skidding, spin-outs, unwanted motion, and accidents. That the Brown Dynamic Absorber will help save lives. That the Brown Dynamic Absorber will keep the rear wheels of an automobile tracking the front wheels, will give the driver added control, and will help keep a skidding automobile going straight. That the Brown Dynamic Absorber will help control automobiles during panic stops or sudden turns.

That the Brown Dynamic Absorber will help control automobiles on wet or sandy road surfaces.

That the performance representations for the Brown Dynamic Absorber have been substantiated by competent scientific tests or by authenticated, controlled, and duly recorded tests. None of the facts found in Findings 1 through 6 above are contested by respondents.

7. In order to support their contention that the device is without merit beyond its value as a deadweight in stabilizing a vehicle, com- ‘BROWN AUTO STABILIZER CO:, ET AL. 751 4B. Initial Decision plaint counsel offered testimony and written results of testing of respondents’ device by Dr. Andrew A. Frank, a highly qualified engineer and an expert in testing vehicular behavior, who, together with Professor A. H. Easton, another such expert, conducted carefully. controlled tests. These tests were made with the device installed in an automobile, and then the same tests were made. with the equivalent weight of lead in an affixed box in the same position at the rear of the trunk of the car. The opinion of this expert witness and the © results of the tests were to the effect that the device was of no value for the purpose for which it was intended and for which it was advertised. Respondents have. contended that because the device used in these tests was first affixed to a plywood board before being bolted to the floor of the trunk, the results were invalid. It was, however, the opinion of this expert witness that the presence of the plywood board | had no effect upon the results obtained. (Tr. 49-114, 123-156, 178-220) ‘8. Respondents offered testimony of another well-qualified engineer to the effect that the theory of the design of the device was based upon a standard, mechanical engineering vibration theory. His explanation of this theory was:

' Well, it’s not a new idea. It’s been, let’s say, in the field of mechanical vibrations for some years. The idea is that if there is a—let’s say a mass spring system oscillating at a natural frequency, that the amplitude of a vibration can be decreased by tuning a second mass spring system to the vibrating mass, with the idea that the subsystem will oscillate out of phase with the prime system, and in so doing will reduce the vibration effort. (Tr. 158) It was also his view that the tests which had been performed by the previously mentioned expert who had performed the testing at the request of the Federal Trade Commission did, in fact, show some measurable effectivenes of the device (Tr. 163-64). 9. Respondents also offered testimony of another engineer who had designed the device. He explained the theory of a dynamic absorber as follows:

A dynamic absorber, by definition, is a mass suspended within another mass with the same resident frequency, or the same natural frequency, so that when one mass moves the other one tries to resist it, but it’s being excited by the same force, and so, when they each complete its cycle they’re at other ends of the stroke, and the other one’s trying to come back and this one’s trying to go this way. That’s the whole purpose of the dynamic absorber, so that one can oppose the other so that the secondary mass can help to dissipate the first one, and that’s where the dampening effect is; and that’s what it’s because of. (Tr. 279) He also stated that he had conducted some practical tests of the device in automobiles and had observed that it was effective for the purposes Initial. Decision 81 F.TC.

claimed for it, but he did not record any findings or results of such tests. (Tr. 284-89) ;

10. About one hundred of these units was supplied to the Florida Highway Patrol for use in its vehicles, and evidence was offered by complaint counsel and respondents’ counsel that expressed the views _ of the various patrolmen to the effect: that the device was useful; that it was not useful; or that they couldn’t be sure what. the effect of the device was. It is concluded. that. all of the evidence from the.users of the device is inconclusive and cannot be relied upon. 11. Although. there is a dispute regarding the theory of the manner in which the device may,.or could, operate, itis unnecesary to decide whether this is a valid mechanical theory because it is found that the tests conducted by the expert. whose testimony was offered by complaint counsel show that the device did not produce the results: which were claimed for it.. The facts must. be found on. the basis of what appears to be the most carefully controlled.and competent tests shown to have been conducted, and. here it: is believed they were the tests conducted by Dr. Frank and Professor Easton (Tr. 51, e¢ seg.). It-is found that the device, which weighs about 53 pounds, has no value in stabilizing a vehicle beyond its value as an added weight. It: is therefore found that, in truth andin fact, The Brown Dynamic Absorber is not an effective safety device. The Brown Dynamic Absorber is not an anti-skid device which will help prevent skidding, spin-outs, unwanted motion, and accidents. The Brown Dynamic Absorber will not help save lives. The Brown Dynamic Absorber will not keep the rear wheels of an automobile tracking the front wheels, will not give the driver added control, and will not help a skidding ‘automobile going straight. The Brown Dynamic Absorber will not help control automobiles during panic stops or sudden turns. _ The Brown Dynamic Absorber will not help control automobiles on wet or sandy road surfaces.

The performance representations for the Brown Dynamic Absorber have not been substantiated by competent scientific tests or by authenticated, controlled and duly recorded tests. CONCLUSION The aforesaid acts and practices of respondents, as herein found, were and are all to the prejudice and injury of the public and of respondents’ competitors, and constituted and now constitute unfair methods of competition in commerce and unfair and deceptive acts and practices in commerce in violation of Section 5 of the Federal Trade Commission Act.

BROWN AUTO STABILIZER CO., ET AL. 753.

| 45 Initial Decision ORDER It is ordered, That. the respondents Brown Auto Stabilizer Co., a. corporation, its successors and assigns, and its officers, and Charles R. Brown, individually, and as an officer of said corporation, and respondents’ agents, representatives and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the advertising, offering for sale, sale, or distribution of “Dynamic Absorbers” or any other products, in commerce, as “commerce” is defined in the Federal, Trade Commission Act, do forthwith cease and desist from: - 1. Representing, directly or by implication, that respondents” “Dynamic Absorber” or any similar device when installed or used in any manner in the operation of a motor vehicle: (a) Is an effective safety device, or -(b) Is an anti-skid device, will help prevent adding, spin-outs, unwanted motion, or accidents, or (c) -Will help save lives, or (d) Will help keep the rear wheels tracking the front wheels, will give the driver added control, or will help keep: - a skidding motor vehicle going straight, or (e) Will help control motor vehicles during panic stops or sudden turns, or (f) Will have any value in helping to control motor vehicles on wet or sandy road surfaces, beyond its value as added weight.

2. Using the word “Stabilizer” or any other word, term, or phrase of similar import or meaning, as part of the corporate or trade name or in any other manner to describe or refer to respondents’ device or any similar device.

3. Representing, directly or by implication, that the performance representations for respondents’ “Dynamic Absorber” have been substantiated by competent scientific tests or by authenticated, controlled, and duly recorded tests; or falsely representing, in any manner, the extent, kind, character, or results of any scientific tests performed on any of respondents’ products. It is further ordered, That respondents notify the Commission at least thirty (30) days prior to any proposed change in the corporate respondent, such as the dissolution, assignment, or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries, or any other change in the corporation that may affect compliance obligations arising out of this order. 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2160 97 26 96.869987 About5 1 6 4 1 11 1968 2163 29 24 96.102585 It5 1 6 4 1 12 2017 2163 81 25 96.102585 Now.4 1 6 4 2 0 773 2197 1146 36 -1 5 1 6 4 2 1 773 2197 106 24 87.707443 Installs 1 6 4 2 2 904 2204 7 18 96.213020 a5 1 6 4 2 3 926 2198 108 25 96.916199 Brown5 1 6 4 2 4 1050 2199 144 29 96.513336 Dynamics 1 6 4 2 5 1208 2200 147 26 96.862411 Absorbers 1 6 4 2 6 1370 2201 48 24 96.033020 for5 1 6 4 2 7 1433 2202 67 25 96.489166 that5 1 6 4 2 8 1516 2202 93 25 96.358093 Extras 1 6 4 2 9 1624 2203 118 30 96.858315 Margins 1 6 4 2 10 1758 2203 33 25 96.575211 of5 1 6 4 2 11 1808 2203 111 30 96.609886 Safety.3 1 6 5 0 0 809 2239 1090 34 -1 4 1 6 5 1 0 809 2239 1090 34 -1 5 1 6 5 1 1 809 2239 58 25 96.521629 Ares 1 6 5 1 2 886 2246 57 23 96.651688 you5 1 6 5 1 3 962 2241 105 28 96.194839 Really5 1 6 5 1 4 1086 2241 164 26 96.475426 Interested5 1 6 5 1 5 1270 2243 30 23 96.013390 in5 1 6 5 1 6 1320 2244 167 29 96.379646 Protecting5 1 6 5 1 7 1506 2244 80 25 96.605980 Yours 1 6 5 1 8 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95.981216 tions.5 1 6 7 3 2 2047 2513 2 2 15.221375 :3 1 6 8 0 0 769 2536 1328 114 -1 4 1 6 8 1 0 806 2536 1290 36 -1 5 1 6 8 1 1 806 2536 83 24 96.582626 Blows 1 6 8 1 2 911 2538 67 24 96.085953 outs5 1 6 8 1 3 1002 2544 56 18 96.562012 cans 1 6 8 1 4 1081 2545 88 18 96.562012 causes 1 6 8 1 5 1192 2539 112 25 73.364227 serious.5 1 6 8 1 6 1329 2541 148 25 80.048981 accidents5 1 6 8 1 7 1502 2542 93 24 96.385742 under5 1 6 8 1 8 1619 2542 50 24 96.771736 thes 1 6 8 1 9 1694 2542 63 24 96.590027 best5 1 6 8 1 10 1783 2542 117 30 94.989929 driving5 1 6 8 1 11 1923 2544 173 25 94.989929 conditions.4 1 6 8 2 0 770 2578 1327 38 -1 5 1 6 8 2 1 770 2578 62 30 96.511520 Thes 1 6 8 2 2 850 2578 108 26 96.641159 Brown5 1 6 8 2 3 976 2580 145 29 95.913643 Dynamics 1 6 8 2 4 1139 2581 147 25 96.409012 Absorbers 1 6 8 2 5 1305 2583 86 25 95.357552 could5 1 6 8 2 6 1408 2584 121 28 96.419762 provides 1 6 8 2 7 1549 2584 49 24 96.326782 thes 1 6 8 2 8 1618 2584 85 24 95.749481 extras 1 6 8 2 9 1724 2584 114 30 96.532806 margins 1 6 8 2 10 1859 2585 32 25 96.680084 of5 1 6 8 2 11 1910 2586 99 30 95.782768 safety5 1 6 8 2 12 2029 2587 68 24 96.334091 that4 1 6 8 3 0 769 2621 318 29 -1 5 1 6 8 3 1 769 2621 85 25 96.225945 could5 1 6 8 3 2 864 2628 69 19 96.783447 saves 1 6 8 3 3 943 2629 74 21 96.494675 yours 1 6 8 3 4 1027 2623 60 24 96.457184 life. BROWN AUTO STABILIZER CO., ET AL. 755 145 Opinion You can have 4 Brown Dynamic Absorber installed in your car to augment the conventional controls and. get automatic, mechanical help when you need it to prevent many needless auto accidents from happening. Q. What does it do? , A. It helps drivers stop cars faster and straighter. s * * * _* * * Q. Does a Brown Auto Stabilizer help on slippery surfaces? A. Yes, * * * : :

The parties are in agreement that through these and other advertisements respondents have made the following representations : 1. That the Brown Dynamic Absorber is an effective safety device. 2. That the Brown Dynamic Absorber is an anti-skid device which will help prevent skidding, spin-outs, unwanted motion, and accidents. 3. That the Brown Dynamic Asborber will help save lives. . 4, That the Brown Dynamic Absorber will keep the rear wheels of an automobile tracking. the front wheels, will give the driver added control, and will help keep a skidding automobile going straight. 5. That the Brown Dynamic Absorber will help control automobiles during panic stops or sudden turns.

6. That the Brown Dynamic Absorber will help control automobiles | on wet or sandy road surfaces.

7. That the performance representations for the Brown Dynamic Absorber have been substantiated by competent scientific tests or by authenticated, controlled, and duly recorded tests. The only issue in dispute during the hearings was whether the device is in fact effective for the above intended purposes. Complaint counsel submitted detailed test data and supporting expert testimony comparing the results of use of the device in a car with use of an equivalent deadweight in the same car.’ This evidence supports the view that the device does not perform as claimed in respondents’ advertisements. Respondents submitted no test data but relied on evidence from drivers who have used the device and believe that it improves stabilization of their car. They also presented testimony by an engineering expert to the effect that the theory upon which the device is claimed to operate is a valid one and testimony by the inventor of the device to the effect that it performs as intended. | The administrative law judge found that whether or not the theory for the device relied upon by respondents is sound, the tests offered 1 Although respondents dispute certain aspects of the tests and the weight to be given to the tests, they do not dispute the validity of comparing the behavior of a car with the device (properly installed) as compared to performance of the car with an equivalent deadweight substituted for it. Therefore there is no contention that the tests should have compared performance with device versus performance with the device removed and no deadweight substituted.

<< 756 FEDERAL TRADE COMMISSION ‘DECISIONS Opinion — - 81 FTC.

by complaint counsel show‘that the device does not in fact produce the results claimed for it. He also concluded that the evidence from users of the device was inconclusive and could not be relied upon. He issued an order prohibiting respondents from. making. the abovedescribed representations and from using the word “stabilizer” or similar term in their trade name. In their appeal, respondents challenge his acceptance of the tests and claim error in the initial decision in other respects. Before taking up these-points,.a description of the tests. submitted by complaint counsel would be appropriate. ' | Tests Performed. by A. H. Easton a Associates ‘Complaint counsel introduced analyses of ‘road tests: using the Brown “Dynamic Absorber” through Dr: Andrew A. Frank, an as- _sociate in the firm of A. H. Easton & Associates, which is in the business of testing the behavior of atitomobile vehicles under various: ‘driving: conditions Dr. Frank explained that he ‘and his associate, Professor A. H. Easton,’ performed a ‘series of tests on a Brown . “Dynamic Absorber.” He explained that using testing equipment which they had designed they ran a séries of road tests designed to: measure the efficacy of the device under common Kinds of conditions: that could be encountered by drivers.

The test car used was a 1968 Oldsmobile. Since respondents claim that the device is effective for any make of car, no contention has been: raised that more than one type of car should have been used. The test equipment consisted of an accelerometer package in which there were three accelerometers to measure lateral and other motions of the car and a set of two gyros—a directional gyro and a pitch-roll gyro—to measure the angles of the body of the car as the car was maneuvered. The accelerometers gave off electrical signals proportional to the accelerations in each of their axes, and the gyros provided electrical signals providing an indication of the angles that the car was expe- 2Dr. Frank has a bachelor’s degree in mechanical engineering, automotive option, from the University of California at Berkeley; a master’s degree in mechanical engineering in automotive control systems; a Ph. D. in systems electrical engineering from the University of Southern California in 1966; and has written a number of articles on vehicle behavior. He is presently a professor at the University of Wisconsin, Engineering College and he has. worked for North American Aviation from 1955-1966 on vehicular problems involved in the aerospace industry, including dynamic simulation, design of control systems for dynamic control of vehicles.

* A. H. Haston is also a professor of mechanical engineering at the University of Wisconsin. He teaches courses in vehicle dynamics, vehicle testing, and has had 18 years in the business of automobile testing. He has authored a number of articles on methods and results of automobile testing. In addition, he is a member of the National Safety Council and past chairman of a section of the Council on winter hazards. BROWN AUTO STABILIZER CO., ET AL. , 757 745: Opinion riencing. The information was recorded on a special tape recorder which ‘was then..taken to a computer laboratory and put onto. strip charts from which the data could be compared and interpreted..These strip charts are in the record (CX 2l1a=f). Tables prepared by Dr. Frank summarizing the more salient data, such as maximum lateral acceleration of the car during the tests, are attached to this opinion as Appendices. The following road tests were conducted by Dr. Frank and Professor Easton.

A. Four-Wheel Locked Braking: Tests.

The first series of tests were designed to measure the effect of the “Dynamic Absorber” in a panic stop situation. After affixing the device in the trunk of. a test car, Professor Easton took the car up to a given speed.(40 mph) and applied the brakes suddenly. The electronic calibration equipment in the car measured various responses of the car, including the.amount of acceleration of lateral movement. Also the: final degree of “yaw” (lateral movement) of the stopped car from the original line of direction was recorded. The same maneuver. was made with the Brown device removed and.a deadweight substituted. Each type of test was repeated more.than once. Qn. their face the. results might seem to indicate that there. was somewhat greater yawing and lateral acceleration using the Brown device. Thus, the lateral acceleration using the Brown device reached a peak of .86 G’s and a degree of yaw of 17, whereas the deadweight tests did not exceed. .22 G’s and 8 degrees, respectively. See Appendix I.* However, Dr. Frank explained that the range of difference was not statistically significant and that the results should be interpreted to mean that the Brown device had about the same effect as the deadweight substitute.

2. Three-Wheel Locked Braking Tests.

A second series of tests involved blocking (disconnecting) the right front brake of the automobile and applying the brakes suddenly, causing the car to go into a violent spin-out or skidding condition and changing its direction 140-145 degrees. The results are summarized in Appendix IT. Again, Dr. Frank stated that based on his experience the data shows there was no significant difference in the behavior of the car, whether the Brown device was used or a deadweight was used.

athe test runs marked “#1” under Column B in the Appendices indicate use of the Brown device. Tests marked “#1 wt.’ indicate the deadweight tests. (Subsequent runs involving stabilizers not involved in this case have been deleted from the exhibits.) 758 FEDERAL TRADE “COMMISSION: ‘DECISIONS Opinion 81 F.T.C.

3. Constant Oscillatory Steering Tests.

A third series of tests involved using’ a mechanical ‘steering ‘wheel oscillator to rotate the steering wheel back and forth, causing the car to go in an “S” direction at a constant speed, at approximately 45-to-50 mph. A summary of peak-to-peak lateral acceleration and roll angle is shown on Appendices III and IV. ‘Appendix ITT shows the comparative results with tire pressure equal in all four tires. Appendix IV shows the results when the pressure in the rear tires was significantly reduced. The rear tires were softened, Dr. Frank explained, to. cause the car to go into what automobile testers call an “oversteer condition,” giving the car a greater tendency to spin or skid. - The data in Appendix III shows somewhat: lower measurements for lateral acceleration in the test using the Brown device (Appendix — III). Respondents contend that this indicates: the stabilizing effect of the Brown device. However, it’should be noted that in these runs the speed of the test vehicle was somewhat lower than the speed ‘of the vehicle in the runs when the deadweight was installed. In subsequent runs shown in Appendix IV where speeds were more comparable, no significant’ difference appeared between the effects of the Brown device and the deadweight. Dr. Frank testified that the difference was within the normal tolerance of measurements and that in his opinion both sets of tests showed that the “Dynamic Absorber” would not help control automobiles on’ sudden turns or skids (Tr. 87-93). 4. Another series of tests involved placing instruments on the moving element within the Brown “Dynamic Absorber” and then measuring the motion of this element with respect to the automobile’s movements. According to the underlying theory of mechanics attributed to the device by its inventor, for effective performance the device should at least be so constructed that it would vibrate approximately 180 degrees out of phase with the automobile’s lateral oscillatory frequency. The test automobile was driven at different speeds and the steering wheel oscillated to cause lateral sway that would occur in avoidance situations. Also, the car was shaken while in a stationary position. Normal left-turn and right-turn tests were also made. Finally, what is called a “nibbling” test was run, which involved driving along a raised ledge in the road causing the car to constantly swerve back and forth.

The results of these tests show that the phase lag between the automobile and the Brown “Dynamic Absorber” was about 10 degrees when the vehicle was shaken while standing still, rather than the 180 degrees if the device was to operate according to theory. Dr. Frank BROWN AUTO STABILIZER ‘CO., ET AL. 759 745 Opinion stated that this amount of phase lag indicates that the device is practically insignificant in its effect on the vehicle (Tr. 126). In the moving tests the phase lag was even less, going down to zero in a number of maneuvers. See Appendix V:

As a result of these tests and his knowledge and experience in the testing and behavior of automobiles under such conditions, Dr. Frank stated that it was his opinion that the device was not an effective . safety aid, would not help prevent skids, accidents, or unwanted motion, nor would it increase controllability of a car. Respondents’ Contentions on Appeal Respondents challenge the above tests on the ground that the testers: did not mount the Brown “Dynamic Absorber” properly in the test car. In this connection, Dr. Frank had explained that he and Dr. Easton bolted the device on a piece of three-eighths inch plywood . instead of bolting it directly to the body of the car. Respondents’ counsel during oral argument suggested there was no evidence that the plywood board was then fixed to the bottom of the car trunk. However, examination of the testimony shows that Dr. Frank on several occasions stated that the plywood mounting was in turn bolted securely to the trunk floor (Tr. 57, 58, 75). The plywood mounting was used to facilitate installation and removal during the series of tests. Dr. Frank stated that mounting of the device on the board could not have had any material effect on its performance (Tr. 195). Respondents presented no evidence that such installation was contrary to or inconsistent with the manufacturer’s instructions. Nor have they suggested how use of the plywood mounting might have interferred with the tests. Accordingly, no basis for attacking the test results. on this ground is found.

Respondents presented as expert witnesses, Dr. J. Walter Harrington, a professor of mechanical engineering at Villanova University, and Dr. Gary Tolley, inventor of the Brown “Dynamic Absorber.” These witnesses testified that a dynamic absorber is not a new concept; that it is recognized that if there is “a mass spring system oscillating at a natural frequency, * * * the amplitude of a vibration can be decreased by tuning a second mass spring system to the vibrating mass, with the idea that the sub-system will oscillate cut of phase with the prime system, and in so doing will reduce the vibration effort.” (Tr. 158; see also Tr. 279.) However, it is clear that whether a particular absorber will work on a given piece of machinery de- 760 FEDERAL TRADE COMMISSION: DECISIONS Opinion 81 FUL.

_ pends on a number of variables: Dr. Harrington stated that whether the Brown device works “basically centers upon the amount of the mass and the way it is pivoted: And the stiffness of the rubber element which serves as a basic storing device [for the energy absorbed]” (Tr. 159). a Although Mr. Tolley claimed to have tested the Brown device with instruments and that it performed successfully, no records of these tests were kept or. produced, nor were the resulting measurements ever specifically described on the witness.stand. Lacking any probative proof as to the degree to which the Brown device was observed “to work,” we fail to see how this testimony refutes complaint counsel’s test data or demonstrates that respondents had adequate test data to substantiate their advertising claims.° Respondents also rely on evidence which they submitted that certain users of the Brown device have vouched for its effectiveness. In this connection, respondents showed that they had provided the Florida State Highway Patrol with over 100 Brown “Dynamic Absorbers” to use in patrol cars. They submitted survey questionnaires that of the 102 units which were used, 76 patrolmen reported the device to be a “definite aid” in the control: of the vehicle and 26 found it to be of “some value” but “not conclusive.” None appeared to give a completely negative report on the questionnaire, although some did orally when called as witnesses by complaint counsel. Three representatives from the Highway Patrol and two Florida County sheriffs appeared as witnesses at respondents’ request and testified to having favorable experiences with the device.

Complaint counsel, on the other hand, called eight Florida Highway Patrolmen and former patrolmen as witnesses. The thrust of their testimony was that the device did not substantially aid in the control of their patrol cars. At least three believed that the device made driving control more difficult in some situations. We believe the administrative law judge was correct in giving inconclusive weight to user endorsements. Not only were these opinions in conflict but this type of evidence inherently lacks probative value 5 Dr. Harrington suggested that the data shown on one set of the ¥Frank-Haston “‘constant oscillatory steering” tests (Appendix III) indicate some measurable effectiveness. However, as previously noted, supra p. 7, Dr. Frank stated that the variance was within normal tolerances. Also, as noted, subsequent runs of similar tests of the test vehicle showed no such differences. Considering all tests that were performed by Dr. Frank and his associate, we think the evidence clearly demonstrates that the device does not signifieantly aid in the control of vehicles as advertised. -<BROWN: AUTO: STABHAZER: CO., ET. AL. ‘761 745 Opinion where a product’s efficacy is not readily apparent and can be measured by more objective means. Here, rigorous scientific tests, performed under conditions that would minimize subjective influences, were placed in the record. We think thé scientific tests override any reliance ‘on user testimonials. Cf. Vacu-Matic Carburetor Co. v. Federal Trade Commission. 157 F. 2d 711 (7th Cir. 1946). Our view of this matter does not conftict with Fois M fg. Co. v. Federal Trade Commission, 287 F. 2d 831 (9th:Cir. 1961). In that case the court held that the Government’s experts’ tests had been successfully impeached. Evis had presented detailed evidetice showing that the ‘manufacturers’ explicit instructions had not: been followed and’ tsug- _gested why. it was necessary to follow them. The experts were nit ‘familiar with the theory of Evis’ invention and the court found error “in hot. following the instructions. In- the’ present case, respondents introduced no installation instructions into the, record and ‘no evidence ‘suggesting that mounting the device first on @ piece of three- -eighths ‘inch plywood would or might affect operation. of the Brown device. Dr. Frank showed that he was fully: familiar with the scientific prin- , ciples which the Brown device is:supposed to incorporate and no attempt was made to discredit his testimony that the plywood mounting could not have affected the results...

Respondents also rely on Gelb. v. Federal Trade Comméssion, 144 F.2d 580 (2d Cir. 1944). But that case is also distinguishable. There a chemist’s opinion as to the results of using a hair conditioner was held not to constitute reliable evidence where it was predicated upon an erroneous statement as to chemical analysis. Other uncontradicted expert testimony based on a correct analysis of the product corroborated user testimony that the product worked in the manner advertised. No similar circumstance exists here. A number of other challanges, mostly procedural in nature, are raised in respondents’ briefs. We ‘and no error in the administrative law judge’ s rulings on these points. Since they do not involve material issues, extended discussion of these issues is not necessary. We find no error in the administrative law judge’s findings: that respondents’ advertisements were false and deceptive 1 in the manner set forth in the complaint. We find no-error in any other respect. Accordingly, the initial decision is affirmed and adopted. An appropriate order accompanies this opinion. woe:

Commissioner MacIntyre concurred in the result, 494—-841—73——_49 81 ETC.

‘Opinion a (cc ae A eT acide ten rarerD 0 sane ayy uf | , beesy on igs, Bae 3 “parent jaipog _ . €# Teun JO yusy. 8s WYSTOM pea ~ GMb F NOISSIINGO HAVEL TWiadas | wt c# Four Fo quaTeATNbs 4UZrEM pesy - 4Mc# : me: i fa SIUM GO SeSLBATODS QUBLOM peo + IAL¥ 6S" e “TE 5 gut g*hL 9thl O'Oh HLT 34T# T9° -g- 62 = ht HSL b'Gh = 9°OR QLT 3MTH# 09° TT enee ~~ ake g°cL greL 0°Ohn - 2Lt T# 96° lt .. “9° 21° O°SL 2°Eh G*6E TLE oT# SS: = Tt Lz el: 6'SL 6°SL 0°0H Lit t# QWad-uvga): “Qwad) . . .

JUS - - SVD OT Sed | .tpaad Jtogd--*owd. = s.0 SONVESTG dead Hd “ON. *ON WIG ‘'OOV MHA OOV5 1 17 8 3 5 1179 1135 31 64 18.970192 VT -MVA “TOU -HOLId “"THOUd -daLOAWNOD ‘DESIG CaadS SENNOD LINN NAN owe a OP We Be EBS Hs 8 a a a 9 q@ Vv _ are “7 7S Sisaa ONINWHE TSd G2 al ‘Ise S2 UT ESL oe UH fIsd $2 ay iseunueoar ouTy Sipe BS o2G adanqRaodu; Maly © oto . = - OkSTrat Giecuh HRZTTIQVESSULAY +++. + YLUTINT © ox grave ANMTWN APPENDIX I BROWN AUTO STABILIZER CO., BT AL. = 763 “745 Opinton “TABLE IV INERTIA ANTI-SKID STABILIZER TESTS 10-15-70. - 4:20 pam. Clear, Dry Temperature - 50° Tire Pressures: RF-25, RR 25, LF 25, LR 25 THREE-WHEEL-BRAKE TESTS A Be D=. E oF -G Hes RUN: UNIT SPEED FINAL LAT. ACC. LAT. ACC. ROLL YAW NO. NO. MPH ANGLE (PEAK) RATE ANGLE ANGLE MEAS. ns Ve G'S G'S/SEC. DEG. ~“-DEG. ~-DEG:

16 #lwe. 30.00. 2) 210 aL B66 ee 17 “#1 wt 30 1.04 -T1 8.9 18 #2 30 +719 = 1.08 -71 8.9 144 19 1. 30 MOM TR 8 a eeees aeee teem # Tire pressure reduced to 10 PSI by tests #1 wt ~ Dead weight equivalent of unit #1 #2 wt - Dead weight equivalent of unit #2 #3 wt - Dead weight equivalent of unit #3 FEDERAL TRADE COMMISSION Docket No. //A2 tn the Matter otherere Mate Mh Erbbarsrad. Dated: 62s ZAW ness ---- 275 nepanet APPENDIX ITI 164 FEDERAL TRADE MMISSION DECISIONS Opinion | 81 EVT.C.

TABLE II INERTIA ANTI-SKID STABILIZER TESTS-..10-15-70 1:38 p.m. Clear, Dry: ~:

Wire Pressures: RF 25, RR 26, LF. 259.2: :LR.25 “Temperature 52°.) 2 secig rau O.dne te CONSTANT OSCILLATORY STEERING TESTS RUN. UNIT SPEED LAT. ACC. _ ROLL ANG.

NOs". NO. MPH. oo GIS |, DEGREES - a > _(PEAK-PEAK) © '(PEAK~PEAK) ~~ 8 #1 wt 4B 72° Bh 38 i UG 58 29 19 1 45 62 33 20 1 45 cece eee ween ON ee eee ABD anne eo X #1 wt - Dead weight equivalent #2 wt - Dead weight equivalent #3 wt - Dead weight equivalent of unit #1 of unit #2 of unit #3 cTORRAL TRADE CMIMISSION secret Hi PPGS. 2 RSE snibit no.Care&.! Ngchet HALL ES. teeth .

{ In the Mattes wi Leowoe fects hiatehe, Reporter APPENDIX IIL BROWN AUTO STABILIZER CO., ET AL. 765 T4500 Opinion TABLE III INERTIA ANTI-SKID STABILIZER TESTS 10-15-70 3315 Pem. Clear, Dry | Temperature 52° Tire Pressures: RF 25, RR 15, - LF 25, LR 15 CONSTANT OSCILLATORY STEERING TESTS A B Cc D OB RUN UNIT SPEED LAT. ACC. ROLL ANG.

No. NO. MPH , G's DEGREES ~ . (PEAK-PEAK) (PEAK-PEAK) 1 1 45 55 Se 2 1 50 -70 ee 3 #iwt = 45 72 30 * & #1 wt 45 64 2.28 5 1 40-45 -70 426 6 1 45-50 71 425 i 43-45 £60 . 428 #1 wt - Dead weight equivalent of unit. #1 #2 wt -~ Dead weight equivalent of unit #2 #3 wt - Dead weight equivalent of unit #3 FEDERAL TRADE COMMISSION Docket No. M63. geseanuins *? tn the Matter of: Cerrar, Lathe, heabshizgs 24) _ weaparter AAA APPENDIX IV ‘a (aoFAap Uy BuTduep Jo Het o4. an bi UOTIBTTFOSO TVUCTEPpe eqou) dt m ~ a yout suo e uo BuTTaqtu ‘udu $9 peedg tt’ 0 gT°s .. = BUTTAQIN T Tl : Teanbs beauty aTqeeotjou Trqun ho PaseTTFOSo Teeus Buyaeess ‘udu 09 peads 29° (0) . 0G6°3 °° « /BuyTueaqs I OT ye. . reenbs 3aT4 STLQeaoTGOu -TT9UN ey O° PaIBIT FOSS [aeum “Buyrsays ‘udu o£ paeds ‘ G+ g9G°s Butaiee4s T 8 Pa; “Teanbs oat) aTqeesotyou TT4un . Sas 5B PaIeTT Togo TaouM: “Buyaeeqs udu oF paedg: c- GG°z. But1994¢9 I L A. ; . : 0 TE*= . -Udny 45987 T 9 a” . 0) fife 2 2 Udnh *9y T S wo puey £q uaxeus - S$5 1 8 1 12 7 1573 1102 22 53 84.299538 aed5 1 8 1 12 8 1574 1178 21 54 23.403259 auq5 1 8 1 12 9 1573 1254 22 34 67.453224 go5 1 8 1 12 10 1569 1311 26 74 24.867783 awed5 1 8 1 12 11 1546 1407 48 54 47.349808 ou5 1 8 1 12 12 1569 1532 31 28 52.440380 Te5 1 8 1 12 13 1572 1710 22 54 72.902985 OTr5 1 8 1 12 14 1571 1881 25 73 0.000000 €'s5 1 8 1 12 15 1571 2091 22 91 31.149818 ayeug5 1 8 1 12 16 1571 2319 21 14 53.139084 t5 1 8 1 12 17 1567 2454 24 13 56.960449 tt4 1 8 1 13 0 1534 438 32 2029 -1 5 1 8 1 13 1 1534 438 25 53 54.075512 ome5 1 8 1 13 2 1564 1545 2 3 7.598946 t5 1 8 1 13 3 1540 1710 22 53 81.093513 OT+5 1 8 1 13 4 1540 1881 25 71 0.000000 Te? 2 9yeus T € a 29°03 peaour qUsTON . “QtTBO T c MD: 8,280 04 peaow 4Zuszom: ; ~ *QtTeo T T : : Saguoad Sid one i Z0YaH OVI THOOV5 1 8 1 17 6 1344 2091 22 73 71.918144 AWVN5 1 8 1 17 7 1344 2287 21 50 50.365986 “ON5 1 8 1 17 8 1343 2421 22 49 55.043392 “ON4 1 8 1 18 0 1301 439 39 2031 -1 5 1 8 1 18 1 1301 439 39 48 35.040451 Be:5 1 8 1 18 2 1303 1131 24 39 27.660614 a5 1 8 1 18 3 1306 1258 7 3 5.269226 '5 1 8 1 18 4 1313 1312 23 149 12.004013 SLNEWWOO5 1 8 1 18 5 1303 1525 34 89 0.000000 *Oaud5 1 8 1 18 6 1312 1692 22 33 71.792755 AS5 1 8 1 18 7 1312 1734 22 49 71.792755 VHd5 1 8 1 18 8 1301 1863 38 130 24.402657 TWHaALVT5 1 8 1 18 9 1312 2091 22 74 30.788185 LSab5 1 8 1 18 10 1311 2281 22 76 63.120739 “INQ5 1 8 1 18 11 1311 2416 22 54 42.107216 NY4 1 8 1 19 0 1270 438 41 2013 -1 5 1 8 1 19 1 1278 438 22 41 67.256805 a.5 1 8 1 19 2 1275 1130 29 130 21.125168 re:5 1 8 1 19 3 1279 1349 24 68 17.329041 rt?5 1 8 1 19 4 1279 1482 23 94 27.713989 ee5 1 8 1 19 5 1280 1730 21 16 74.945190 a5 1 8 1 19 6 1280 1921 21 16 72.964394 a5 1 8 1 19 7 1270 2108 41 18 2.309845 A)5 1 8 1 19 8 1284 2244 2 2 0.000000 .5 1 8 1 19 9 1279 2301 21 17 45.219345 @5 1 8 1 19 10 1279 2436 21 15 61.480431 v4 1 8 1 20 0 1245 432 32 1121 -1 5 1 8 1 20 1 1253 432 24 47 0.000000 !5 1 8 1 20 2 1255 1147 14 70 25.993279 espn)5 1 8 1 20 3 1250 1258 3 2 32.045303 i5 1 8 1 20 4 1267 1398 1 3 75.761246 :5 1 8 1 20 5 1245 1539 22 14 0.000000 &4 1 8 1 21 0 1204 429 48 1469 -1 5 1 8 1 21 1 1204 429 48 66 25.262184 i5 1 8 1 21 2 1226 913 3 2 9.265129 .5 1 8 1 21 3 1211 1143 30 117 0.000000 eo5 1 8 1 21 4 1215 1544 29 220 0.000000 *SXOZTTTQeqys5 1 8 1 21 5 1216 1788 22 52 22.915733 aug5 1 8 1 21 6 1216 1863 22 35 86.900879 go4 1 8 1 22 0 1178 468 34 1432 -1 5 1 8 1 22 1 1181 468 2 2 4.620277 ;5 1 8 1 22 2 1183 947 6 2 52.256084 _5 1 8 1 22 3 1178 1008 34 150 0.000000 AgtUpyoTa5 1 8 1 22 4 1179 1180 28 53 33.929749 ayy5 1 8 1 22 5 1181 1255 25 35 88.448555 UF5 1 8 1 22 6 1183 1313 23 128 0.000000 payeooT5 1 8 1 22 7 1187 1465 18 74 40.258026 adams 1 8 1 22 8 1181 1560 24 262 19.376823 SdaqauouataooR5 1 8 1 22 9 1182 1845 23 55 39.328175 auy,4 1 8 1 23 0 1135 437 45 1462 -1 5 1 8 1 23 1 1135 437 45 50 27.402962 is5 1 8 1 23 2 1165 928 10 21 31.080864 we5 1 8 1 23 3 1155 1130 22 88 46.650082 “os5 1 8 1 23 4 1138 1257 31 3 79.436760 i5 1 8 1 23 5 1150 1337 22 107 2.368225 ‘SLSGL5 1 8 1 23 6 1149 1464 23 187 41.932693 WAZITIGVLS5 1 8 1 23 7 1149 1674 27 225 36.452087 CALNAWNULSNI4 1 8 1 24 0 1085 438 48 822 -1 5 1 8 1 24 1 1085 438 48 24 0.000000 |5 1 8 1 24 2 1109 485 3 2 0.000000 ,5 1 8 1 24 3 1096 794 8 24 5.256851 a5 1 8 1 24 4 1111 1030 22 6 36.156635 :5 1 8 1 24 5 1104 1256 25 4 65.122940 :4 1 8 1 25 0 1036 438 54 2033 -1 5 1 8 1 25 1 1036 438 54 49 30.661301 a5 1 8 1 25 2 1055 793 24 22 0.000000 o5 1 8 1 25 3 1055 1122 29 68 29.334831 Bl.5 1 8 1 25 4 1055 1257 26 3 65.592850 :5 1 8 1 25 5 1048 1886 27 50 0.000000 oS5 1 8 1 25 6 1051 1959 29 208 0.000000 aanqeroduay,5 1 8 1 25 7 1051 2284 28 55 64.811989 faq5 1 8 1 25 8 1051 2364 28 107 10.200714 *aeato4 1 8 1 26 0 978 437 59 2033 -1 5 1 8 1 26 1 1013 437 24 24 0.000000 m5 1 8 1 26 2 996 937 23 71 31.730659 urd O€:S vet: 0L4-02-0T ; SUSHL YAZITIGVLS GINS-ILNV VILYANI ~ ere By Sooo o s8a MEL SAI Foe ag boss A STAVE ae PEP FY PIG: 0 “ave ayy Uy > SPAT ON yqiyes Nageadeae “FN 900 NOISSH Nive oo Hib. Th BV RIG APPENBEX—¥ DAVIS: FELT--AND CARPET ‘COMPANY. .- 767.

TAB 2 ns Complaint. .

Dxcrston OF THE Commission AND ORDER TO a Rurorr< OF’ - COMPLIANCE. Longer val ines This matter having been heard: by the Commission upon briefs arid’ oral argument in support of and in opposition to the appeal of: respondents from the initial decision finding a violation of Section 5 of ‘the Federal Trade Commission Act; and the Commission for the reasons stated in the accompanying opinion, having concluded that the appeal should be denied: “ It ts. ordered, That the initial decision, a as supplemented by the Commission’s opinion | in this ‘matter, and the order: to cease and’ desist contained in said initial decision, be, and’ ‘they, hereby are, adopted: as the decision and order of the Commission, and ° pee ° form in “which ey have complied with’ the order to cease and ‘oat sist. Commissioner MacIntyre concurring in 1 the result. “In tee Marrer or So vee ee DAVIS5 1 10 1 1 2 1009 1665 126 31 94.862740 FELTS 1 10 1 1 3 1156 1664 103 43 94.862740 ANDS 1 10 1 1 4 1282 1665 193 33 96.614616 CARPETS 1 10 1 1 5 1499 1629 258 105 72.460678 COMPANY2 1 11 0 0 0 697 1755 1204 81 -1 3 1 11 1 0 0 697 1755 1204 81 -1 4 1 11 1 1 0 697 1755 1204 33 -1 5 1 11 1 1 1 697 1755 135 24 96.269402 CONSENTS 1 11 1 1 2 865 1757 115 31 93.201141 ORDER,5 1 11 1 1 3 988 1758 83 30 91.976166 ETC.,5 1 11 1 1 4 1081 1758 42 22 96.220657 IN5 1 11 1 1 5 1133 1755 177 27 96.012505 REGARDS 1 11 1 1 6 1274 1751 39 42 96.012505 TO5 1 11 1 1 7 1318 1759 74 22 96.113907 THES 1 11 1 1 8 1399 1760 151 22 96.656929 ALLEGED5 1 11 1 1 9 1558 1760 184 22 96.026642 VIOLATIONS 1 11 1 1 10 1752 1761 42 21 96.026642 OF5 1 11 1 1 11 1801 1755 76 28 76.338203 THES 1 11 1 1 12 1899 1764 2 2 0.000000 -4 1 11 1 2 0 726 1806 1126 30 -1 5 1 11 1 2 1 726 1807 150 21 95.237762 FEDERAL5 1 11 1 2 2 884 1807 107 23 95.112068 TRADES 1 11 1 2 3 1002 1809 219 22 95.009193 COMMISSIONS 1 11 1 2 4 1231 1809 73 22 96.634109 ANDS 1 11 1 2 5 1312 1810 72 21 95.418388 THES 1 11 1 2 6 1393 1806 216 30 95.418388 FLAMMABLE5 1 11 1 2 7 1618 1809 138 23 95.376251 FABRICS5 1 11 1 2 8 1765 1810 87 22 95.376251 ACTS:2 1 12 0 0 0 785 1884 1003 32 -1 3 1 12 1 0 0 785 1884 1003 32 -1 4 1 12 1 1 0 785 1884 1003 32 -1 5 1 12 1 1 1 785 1884 113 24 93.034492 Dockets 1 12 1 1 2 910 1884 117 30 74.298187 C-2313,5 1 12 1 1 3 1040 1885 172 31 96.171928 Complaint,5 1 12 1 1 4 1224 1885 70 26 95.810295 Nov.5 1 12 1 1 5 1303 1887 25 29 93.258995 6,5 1 12 1 1 6 1339 1887 253 29 90.264679 1972—Decision,5 1 12 1 1 7 1603 1887 70 24 95.441673 Nov.5 1 12 1 1 8 1681 1887 28 29 95.441673 6,5 1 12 1 1 9 1718 1887 70 25 94.184967 19722 1 13 0 0 0 626 1957 1325 158 -1 3 1 13 1 0 0 626 1957 1325 158 -1 4 1 13 1 1 0 626 1957 1325 41 -1 5 1 13 1 1 1 626 1957 127 27 96.190727 Consents 1 13 1 1 2 775 1961 86 23 96.425278 orders 1 13 1 1 3 883 1962 151 29 96.300087 requiring5 1 13 1 1 4 1055 1968 18 18 96.562515 a5 1 13 1 1 5 1096 1962 213 31 94.365303 Philadelphia,5 1 13 1 1 6 1333 1964 224 34 95.829300 Pennsylvania,5 1 13 1 1 7 1582 1964 223 24 96.193443 manufacturers 1 13 1 1 8 1827 1963 59 24 89.859756 ands 1 13 1 1 9 1909 1962 42 25 89.859756 re-4 1 13 1 2 0 698 2002 1252 33 -1 5 1 13 1 2 1 698 2002 87 25 91.400215 tailers 1 13 1 2 2 803 2003 32 24 96.366211 of5 1 13 1 2 3 853 2004 115 29 96.436401 carpets5 1 13 1 2 4 985 2004 61 25 96.768250 ands 1 13 1 2 5 1063 2010 78 25 96.125130 rugs,5 1 13 1 2 6 1159 2010 106 25 96.355408 among5 1 13 1 2 7 1282 2006 85 24 96.064545 others 1 13 1 2 8 1384 2006 99 29 96.064545 things5 1 13 1 2 9 1501 2007 31 24 96.678795 to5 1 13 1 2 10 1550 2013 84 18 96.089424 ceases 1 13 1 2 11 1652 2006 105 29 96.177467 selling5 1 13 1 2 12 1774 2006 59 25 92.828354 ands 1 13 1 2 13 1849 2012 101 18 92.059540 manu-4 1 13 1 3 0 696 2044 1255 62 -1 5 1 13 1 3 1 696 2044 152 30 95.820206 facturing5 1 13 1 3 2 859 2045 152 31 95.820206 carpeting5 1 13 1 3 3 1023 2046 96 25 96.799614 which5 1 13 1 3 4 1130 2048 69 24 96.831001 does5 1 13 1 3 5 1210 2048 53 25 96.932060 not5 1 13 1 3 6 1274 2049 79 35 95.415878 meets 1 13 1 3 7 1363 2049 50 24 96.718834 thes 1 13 1 3 8 1426 2049 166 29 96.097481 acceptable5 1 13 1 3 9 1605 2048 119 50 76.806595 criteria5 1 13 1 3 10 1737 2049 49 24 96.158981 for5 1 13 1 3 11 1798 2048 153 58 92.984657 carpeting4 1 13 1 4 0 696 2087 548 28 -1 5 1 13 1 4 1 696 2087 92 24 95.386566 under5 1 13 1 4 2 798 2087 50 26 95.386566 thes 1 13 1 4 3 859 2088 180 26 95.866600 Flammable5 1 13 1 4 4 1049 2089 121 25 96.265915 Fabrics5 1 13 1 4 5 1180 2090 64 25 96.532852 Act.2 1 14 0 0 0 1179 2172 211 34 -1 3 1 14 1 0 0 1179 2172 211 34 -1 4 1 14 1 1 0 1179 2172 211 34 -1 5 1 14 1 1 1 1179 2172 211 34 46.079224 Complaint2 1 15 0 0 0 619 2254 1330 499 -1 3 1 15 1 0 0 619 2254 1330 499 -1 4 1 15 1 1 0 664 2254 1285 43 -1 5 1 15 1 1 1 664 2254 177 33 96.534103 Pursuant5 1 15 1 1 2 857 2258 36 29 96.802902 to5 1 15 1 1 3 911 2254 60 33 96.776024 thes 1 15 1 1 4 989 2255 193 42 96.309235 provisions5 1 15 1 1 5 1201 2256 40 32 96.781807 of5 1 15 1 1 6 1258 2256 58 32 96.533981 thes 1 15 1 1 7 1334 2257 147 32 96.836166 Federal5 1 15 1 1 8 1501 2257 114 33 96.558929 Trades 1 15 1 1 9 1635 2256 226 35 95.681694 Commissions 1 15 1 1 10 1878 2256 71 33 96.806114 Acta 1 15 1 2 0 622 2305 1326 45 -1 5 1 15 1 2 1 622 2305 69 33 96.586464 ands 1 15 1 2 2 712 2305 58 32 96.293671 thes 1 15 1 2 3 790 2305 214 33 96.336563 Flammable5 1 15 1 2 4 1024 2306 142 33 96.781166 Fabrics5 1 15 1 2 5 1186 2307 79 42 96.882683 Act,5 1 15 1 2 6 1286 2318 37 22 96.772087 as5 1 15 1 2 7 1344 2308 176 42 95.894485 amended,5 1 15 1 2 8 1542 2308 68 33 95.894485 ands 1 15 1 2 9 1630 2308 46 42 96.199677 by5 1 15 1 2 10 1697 2307 113 33 96.360481 virtues 1 15 1 2 11 1829 2307 39 32 96.860191 of5 1 15 1 2 12 1888 2307 60 33 96.860191 thea 1 15 1 3 0 622 2355 1324 45 -1 5 1 15 1 3 1 622 2355 178 43 96.661140 authority5 1 15 1 3 2 820 2357 115 32 96.769218 vested5 1 15 1 3 3 954 2357 38 32 96.982529 in5 1 15 1 3 4 1011 2357 39 32 20.082596 it.5 1 15 1 3 5 1058 2358 47 42 20.082596 by5 1 15 1 3 6 1123 2358 76 32 96.681366 said5 1 15 1 3 7 1218 2358 95 42 96.737488 Acts,5 1 15 1 3 8 1331 2358 60 33 96.162415 thes 1 15 1 3 9 1409 2359 147 33 95.870087 Federal5 1 15 1 3 10 1576 2359 114 32 96.141174 Trades 1 15 1 3 11 1710 2358 236 42 96.590157 Commission,4 1 15 1 4 0 622 2406 1324 46 -1 5 1 15 1 4 1 622 2406 131 42 96.428673 having5 1 15 1 4 2 766 2418 121 22 96.428673 reasons 1 15 1 4 3 902 2411 35 29 96.853790 to5 1 15 1 4 4 952 2407 130 33 96.827759 believes 1 15 1 4 5 1095 2408 78 32 96.268929 that5 1 15 1 4 6 1187 2409 109 33 96.576897 Davis5 1 15 1 4 7 1309 2409 79 33 96.540657 Felts 1 15 1 4 8 1403 2409 69 33 96.355675 ands 1 15 1 4 9 1489 2409 129 43 95.837608 Carpets 1 15 1 4 10 1634 2409 189 42 95.837608 Company,5 1 15 1 4 11 1839 2420 20 21 92.922066 a5 1 15 1 4 12 1873 2420 73 22 92.229973 cor-4 1 15 1 5 0 623 2457 1324 45 -1 5 1 15 1 5 1 623 2457 171 40 96.374214 poration,5 1 15 1 5 2 823 2457 212 33 96.201340 hereinafter5 1 15 1 5 3 1063 2458 154 33 96.508926 referred5 1 15 1 5 4 1246 2459 35 32 96.623062 to5 1 15 1 5 5 1309 2470 37 21 95.871162 as5 1 15 1 5 6 1375 2460 217 42 96.631844 respondent,5 1 15 1 5 7 1620 2460 63 32 96.510468 has5 1 15 1 5 8 1710 2460 151 32 96.512718 violated5 1 15 1 5 9 1887 2459 60 33 96.623505 thea 1 15 1 6 0 621 2507 1326 46 -1 5 1 15 1 6 1 621 2507 193 41 96.529053 provisions5 1 15 1 6 2 826 2509 40 32 96.995323 of5 1 15 1 6 3 877 2509 60 32 97.011024 thes 1 15 1 6 4 949 2509 76 32 96.484344 said5 1 15 1 6 5 1038 2509 86 33 96.725563 Acts5 1 15 1 6 6 1138 2510 68 32 96.908234 ands 1 15 1 6 7 1219 2510 58 32 96.881241 thes 1 15 1 6 8 1292 2510 91 33 96.791199 rules5 1 15 1 6 9 1396 2511 69 32 96.223778 ands 1 15 1 6 10 1479 2511 212 42 96.016388 regulations5 1 15 1 6 11 1704 2511 243 41 96.700531 promulgated4 1 15 1 7 0 620 2558 1326 46 -1 5 1 15 1 7 1 620 2558 109 32 96.323036 under5 1 15 1 7 2 747 2559 59 31 96.295380 thes 1 15 1 7 3 823 2559 216 33 96.620277 Flammable5 1 15 1 7 4 1057 2560 141 33 96.686478 Fabrics5 1 15 1 7 5 1214 2560 80 42 94.936630 Act,5 1 15 1 7 6 1312 2572 38 21 94.936630 as5 1 15 1 7 7 1369 2562 177 40 96.272957 amended,5 1 15 1 7 8 1564 2561 70 33 96.765648 ands 1 15 1 7 9 1652 2561 30 32 95.919342 it5 1 15 1 7 10 1699 2561 192 43 96.810928 appearing5 1 15 1 7 11 1909 2566 37 28 97.020287 to4 1 15 1 8 0 620 2609 1327 59 -1 5 1 15 1 8 1 620 2609 59 32 96.514832 thes 1 15 1 8 2 699 2609 227 33 94.604706 Commissions 1 15 1 8 3 943 2610 78 32 96.500114 that5 1 15 1 8 4 1039 2622 20 20 96.942818 a5 1 15 1 8 5 1078 2611 206 57 96.632919 proceedings 1 15 1 8 6 1301 2611 46 43 95.847404 by5 1 15 1 8 7 1366 2612 29 32 95.847404 it5 1 15 1 8 8 1413 2612 37 32 95.987373 in5 1 15 1 8 9 1468 2616 132 39 95.421051 respects 1 15 1 8 10 1617 2612 137 32 95.421051 thereof5 1 15 1 8 11 1773 2613 113 32 96.126991 would5 1 15 1 8 12 1906 2613 41 33 96.954659 be4 1 15 1 9 0 620 2659 1326 48 -1 5 1 15 1 9 1 620 2659 37 32 96.952713 in5 1 15 1 9 2 674 2659 60 33 96.952713 thes 1 15 1 9 3 751 2660 118 41 96.952644 public5 1 15 1 9 4 886 2654 151 48 96.946121 interest,5 1 15 1 9 5 1055 2662 153 42 96.968658 hereby5 1 15 1 9 6 1198 2673 107 22 96.318260 issues5 1 15 1 9 7 1322 2663 45 32 96.920845 its5 1 15 1 9 8 1385 2663 189 41 96.848686 complaints 1 15 1 9 9 1591 2662 132 43 96.565552 stating5 1 15 1 9 10 1739 2663 48 32 96.807869 its5 1 15 1 9 11 1804 2664 142 43 96.969002 charges4 1 15 1 10 0 619 2687 475 66 -1 5 1 15 1 10 1 619 2710 37 32 96.874084 in5 1 15 1 10 2 666 2711 77 32 96.449883 that5 1 15 1 10 3 752 2714 132 39 96.513603 respects 1 15 1 10 4 892 2722 38 22 96.765335 as5 1 15 1 10 5 940 2687 154 57 96.711563 follows:5 1 15 1 10 6 1085 2737 9 7 74.298058 : 768: FEDERAL “TRADE COMMISSION: “DECISIONS _ Complaint: — 81 EVEC.

Paracrary 1 Respondent’ Davis Felt and Carpet Company is a corporation organized, existing’ and: doing business under and by virtue of the laws of the State of Pennsylvania... Respondent i is engaged i in the, manufacture, and. sale of carpets, and rugs, with its principal place of business located at Casmir and Miller — Streets, Philadelphia, Pennsylvania.

- Par. 2. Respondent is now and for some time last past | has been engaged in the manufacturing for sale, sale and offering: for sale, in. . commerce, and has introduced, delivered for introduction, transported . and caused to be transported i in conameree, and has sold or delivered after sale or shipment in commerce, products, as the terms “commerce” and “product,” are defined in the Flammable Fabrics Act, as amended, which products 1 fail to conform to an applicable standard or. regulation continued. in. effect, issued or amended under the provisions of the. Flammable Fabrics Act,as amended. . Lo Among, such products mentioned hereinabove were carpets and rugs in style “Needletone, Color 201,” subject to Department of Commerce Standard For the Surface Flammability of Carpets and Rugs (DOG FF 1-70).

Pan. 3. The aforesaid acts and practices of respondent were and are - in violation of the Flammable Fabrics Act, as amended, and the rules and regulations promulgated thereunder, and as such constituted, and now constitute unfair methods of competition and unfair and deceptive acts and practices in commerce, within the intent and meaning of the Federal Trade Commission Act.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondent named in the caption hereof, and the respondent having been furnished thereafter with a copy of a draft of complaint which the Division of Textiles and Furs proposed to present to the Commission for its consideration and. which, if issued by the Commission, would charge respondent with violation of the Federal Trade Commission Act, and the Flammable Fabrics Act, as amended; and The respondent and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondent of all the jurisdictional facts set forth in the aforesaid draft of complaint, 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 alleged in such com- ‘DAVIS. FELT AND. CARPET. COMPANY :769 767: . Decision:.and Order plaint, and waivers and other provisions as required byt the Commission’s rules; and .

- The Commission having thereafter considered the matter and having determined that it had reason to believe that the respondent has violated the said Acts, and that complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record: for a period of thirty (30) days, now in further conformity with the ‘procedure. prescribed in Section, 2.34(b) of its rules, the Commission hereby i issues its complaint, makes the following jurisdictional: find ings, and enters the following order: ; ao : 1. Respondent Davis Felt and Carpet Company, is a corporation organized, existing and doing business under and by virtue of the laws of the State of Pennsylvania.

Respondent is engaged in the manufacture. and sale of carpets and -rugs, with its office and principal place of business. located: at Casmir and Miller Streets, Philadelphia,’ Pennsylvania. . 2. The Federal Trade Commission has jurisdiction o of the subject matter of this Proceeding and of the respondent, and the. proceeding is in. the public interest. - ORDER It is ordered, That respondent Davis Felt and Carpet Company, a corporation, its successors and assigns, and its officers and respondent’s agents, representatives and employees directly or through any, corporation, subsidiary, division, or other device, do forthwith cease and desist from manufacturing for sale, selling, offering for sale, in commerce, or importing into the United States, or introducing, delivering for introduction, transporting or causing to be transported in commerce or selling or delivering after sale or shipment in commerce, any product, fabric, or related material; or manufacturing for sale, selling, or offering for sale, any product made of fabric or related material which has been shipped or received in commerce, as “commerce,” “product,” “fabric” and “related material” are defined in the Flammable Fabrics Act, as amended, which product, fabric or related material fails to conform to any applicable standard or regulation continued in effect, issued or amended under the provisions of the aforesaid Act.

It is further ordered, That respondent notify all of its customers who: have purchased or to whom have been delivered the products which gave rise to this complaint, of the flammable nature of said products and effect the recall of said products from such customers. “770 FEDERAL TRADE. COMMISSION DECISIONS:

“Decision: and: Order 81 FTC.

_.: It is further ordered, That:the respondent herein either process the products which gave rise to the complaint so as to bring'them into ‘conformance with the applicable standard: of flammability under the ‘Flammable Fabrics: Act, as amended, or destroy said products. It is further ordered, That the provisions’ of this order with: ré- ‘spect to customer notification, recall. and processing or destruction shall be ‘applicable to carpets: and rugs in style “Needletone, Color 201” as designated in subparagraph one of Paragraph Two of the complaint giving rise to this order, and any other colors determined to be in violation of the Flammable Fabrics Act, as amended, prior . to the date of acceptance by the Commission of ‘the final compliance report. “obavee. re .

It is further ordered, That respondent herein shall, within ten (10) days after service upon it of this order, file with the Commission a special report in writing setting forth the respondent’s intentions as ~ .to compliance with this order. ‘This special report shall also advise the Commission fully and specifically concerning (1) the identity of the products. which gave rise to the complaint, (2) the identity of ‘the purchasers of said products, (8) the amount of said products on hand and in the channels of commerce, (4) any action taken and any further actions proposed to be taken to notify customers of the flammability of said products and effect the recall of said products from — customers, and the results thereof, (5) any disposition of said products since March 29, 1972, and (6) any action taken or proposed to be taken to bring said products into conformance with the applicable standard of flammability under the Flammable Fabrics Act, as amended, or to destroy said products, and the results of such action. Respondent will submit with its report, a complete description of each style of carpet or rug currently in inventory or production. Upon request, respondent will forward to the Commission for testing a sample of any such carpet or rug.

It is further ordered, That respondent notify the Commission at least 30 days prior to any proposed change in the corporate respondent such as dissolution, assignment or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries or any other change in the corporation which may affect compliance obligations arising out of the order.

It is further ordered, That the respondent corporation shall forthwith distribute a copy of this order to each of its operating divisions. It is further ordered, That the respondent herein shall, within sixty (60) days after service upon it of this order, file with the Commission a report, in writing, setting forth in detail the manner and form in which it has complied with this order.

“TUPTEX INC. ET aL. 71 Complaint .