Bay Colony Audiology Center

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IN THE MATTER OF BAY COLONY AUDIOLOGY CENTER, ET AL.

CONSENT ORDER, ETC., INREGARD TO ALLEGED VIOLATION OF SECS. 5 AND 12 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3436. Complaint, June 15, 1993--Decision, June 15, 1993 This consent order requires, among other things, the Massachusetts corporation and its officer to correct false and deceptive claims in Yellow Pages advertisements, prominently post corrected information about Medicare coverage in their offices or provide it to consumers prior to purchase, and prohibits them from misrepresenting the coverage provided by any medical insurance for any hearing-related device or service they offer in the future. Appearances For the Commission: Collot Guerard and Eileen Harrington. For the respondents: Robert Weinstein, Burn & Levinson, Boston, MA.

COMPLAINT The Federal Trade Commission, having reason to believe that Bay Colony Audiology Center, a corporation, and David Citron, II, individually and as an officer of Bay Colony Audiology Center, ("respondents") have violated certain provisions of the Federal Trade Commission Act, 15 U.S.C. 41 et seq., and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges:

PARAGRAPH 1. Respondent Bay Colony Audiology Center is a Massachusetts corporation with its offices and principal place of business located at 825 Main Street, South Weymouth, Massachusetts. .

PAR. 2. Respondent David Citron, III, is an audiologist who is an officer of Bay Colony Audiology Center. He formulates, directs BAY COLONY AUDIOLOGY CENTER, ET AL. 469 468 Complaint and controls the policies, acts and practices of Bay Colony Audiology Center, and his address is the same as said corporation. PAR. 3. Respondents are, and have been, selling hearing aids and offering hearing tests to the public. Hearing aids are a device within the meaning of Sections 12 and 15 of the Federal Trade Commission Act, 15 U.S.C 52 and 55.

PAR. 4. The acts and practices of respondents alleged in this complaint are, and have been, in or affecting commerce, as commerce is defined in the Federal Trade Commission Act. PAR. 5. Respondents have placed, or caused to be placed, advertising for hearing aids in various Yellow Pages directories distributed to the general public, as a means of inducing the public to buy their products and services.

PAR. 6. Respondents’ advertising includes, but is not necessarily limited to, the attached Exhibit A. This advertising contains the following statement:

Hearings 1 4 1 1 2 820 1605 58 29 97.016205 Aids 1 4 1 1 3 891 1604 192 29 96.985603 Evaluations5 1 4 1 1 4 1096 1603 57 29 96.743248 ands 1 4 1 1 5 1166 1603 84 29 92.165916 Sales5 1 4 1 1 6 1265 1626 26 5 90.883911 ...5 1 4 1 1 7 1304 1601 154 29 96.355026 Medicare5 1 4 1 1 8 1471 1599 196 38 96.826454 Assignments 1 4 1 1 9 1680 1592 167 48 85.446251 Accepted PAR. 7. Through the use of the statement contained in the advertisement referred to in paragraph six, including but not necessarily limited. to the advertisement attached as Exhibit A, respondents have represented, directly or by implication, that Medicare will pay for the costs of hearing aids purchased from respondents.

PAR. 8. In truth and fact, Medicare will not pay for the costs of hearing aids purchased from respondents. Therefore, the representation made in paragraph seven was, and is, false and misleading. PAR. 9. Through the use of the statement contained in the advertisement referred to in paragraph six, including but not necessarily limited to the advertisement attached as Exhibit A, respondents have represented, directly or by implication, that Medicare will pay for the costs of hearing tests provided by respondents.

PAR. 10. In the advertising described in paragraph six, respondents have failed to disclose that Medicare does not pay for Complaint 116 F.T.C.

the costs of the hearing tests provided by respondents unless they are performed by order of a physician for the purpose of obtaining additional information necessary for the physician's evaluation of the need for, or the appropriate type of, medical or surgical treatment for a hearing deficit or related medical problem. In light of the representation made in paragraph nine, these facts would be material to consumers in deciding whether to seek respondents’ services and the failure to disclose these facts was, and is, deceptive. PAR. 11. The dissemination by respondents of the aforesaid false and misleading representations as alleged in this complaint constituted, and now constitutes, an unfair or deceptive act or practice and the making of false advertisements in or affecting commerce in violation of Sections 5(a) and 12 of the Federal Trade Commission Act, 15 U.S.C. 45(a) and 52.

BAY COLONY AUDIOLOGY CENTER, ET AL.

Complaint EXHIBIT A err ae » South Shore (G ) Hearing Center Bay Colony Hearing Instruments David Citron, 11, Ph.D, Dir,-Lic. Audivingist (ZA Mon-Fr:

Sat ty Asst So. Weymouth an St (Rt 1g} Arrzss Fram Se. Stave Hosea | 337-6860 _j Neil's Hearing Center MIRIE ROME TE WDA TEAL HEARING AID REPAIRS - ALL MAKES cee a 479- 231 2 AMPLE PARKING » WHEELCHAIR ACCESS Otner JB.Optical Hearing idCenter ge Stephen Tobias Heoring Center FREE HEARING TEST A Tradition Dacicated to tne ; COMPLETE DISCOUNT =:

i HEARING AID SERVICE:

caress srewiel EXPERT REPAIRS ALL MAKES TsOlA WANCOCK ST, :

: QUINCY CINTIN ' 773-3505 © 773.4174 B 448 QUINCY AVE, QUINCY 770-3395 [ome — i:

MO Coaacl 10m mt amieu { Out mGwt CH DLR 0:

HEARING AID SE, RVILES COVER 34 MARKETS WITHOUT BUYING GASOLINE.

Run an ad in the NYNEX Business-to-Business Book.

Buwness lo Buseress Yellow Pages Hearing Aids (vont c) QUINCY BETTER HEARING A:

Shen 773.1 70960 Ces 1b ee 08 Dar eet Be;

bee Shore ee Gene 5 Hoe 127-080 STARKEY CUSTOM HEARING AIDS.

Tre STUN CUENED CONE 2). 2009 me aBne CIMT = 29S Y395 Toeat Sieonen P rewey cen 140 Does MDS mye VISION plus Bases te lot tee tw > Hearing Aids- Accessories Mardin Liaciromas «bee fe hero > Hearing Aids—Repairing Avcictogy Assocaien Ing 352 Crs : a tne - 890 992-6089 wees Caen FOLEY Bw CORP ce 801-1394 Granted Secor Co wre ys so 80958) . 393 Oo) Bs mses » Heating & Combustion Consultants Sepreme Fuel menace Us 779-9900 397-6889 72963995 > Hearing Aids-Whol & Mfrs ete ? Heating © Contractors RING AIDS nthe Lar meaning Act on 232-9182 P Barve we Are mol b Col nes te Pease see cer On, AMERICAN HEATING & AIR CONDITIONING CORP EMERGENCY REPLA we tenon be-— > Hearing Analysis See Aossogsts, Meaning 4.33 > Hearing Protection Equipment See Satety Exuement & Clowning 4d Payment Up To S:

No Cerowt - Bareers® VOLS >Hearing & Sound Evaluation Industrial, Services & 307:

Equipment angernon ¥ HG aee WD8S3 See kusggatt ATCANTIC HEATING BAIR ee a CONDITIONING CO INC fave » Hearing Test Equipment See mesring beds, Satety Eguement & — atiantic Cistting Tb dene ARINC >Heat Pumps pte 228-7522 Pile Sires —--- 331-1009 WT llseanra ‘ al Cerne 5 1 120 1 8 4 1457 2099 81 11 24.995316 961-07004 1 120 1 9 0 1233 2100 305 33 -1 5 1 120 1 9 1 1233 2113 47 20 32.844437 Comiont5 1 120 1 9 2 1288 2106 44 20 50.403320 Carver5 1 120 1 9 3 1334 2100 20 32 49.626450 ‘nc5 1 120 1 9 4 1361 2117 29 8 53.841499 ate,5 1 120 1 9 5 1481 2114 57 11 18.677261 337-802 1 121 0 0 0 1233 2130 221 58 -1 3 1 121 1 0 0 1233 2130 221 43 -1 4 1 121 1 1 0 1233 2130 221 13 -1 5 1 121 1 1 1 1233 2132 44 11 61.699623 CURLEY5 1 121 1 1 2 1285 2131 33 25 0.000000 Has5 1 121 1 1 3 1321 2130 52 27 0.000000 mdatiNG5 1 121 1 1 4 1381 2130 7 10 31.340027 &5 1 121 1 1 5 1397 2130 17 10 34.766037 AIR5 1 121 1 1 6 1422 2130 32 10 32.256065 COG4 1 121 1 2 0 1247 2148 63 10 -1 5 1 121 1 2 1 1247 2149 12 9 31.835266 de5 1 121 1 2 2 1267 2148 14 10 45.888489 Poss 1 121 1 2 3 1283 2148 27 9 5.655762 toe4 1 121 1 3 0 1234 2146 163 42 -1 5 1 121 1 3 1 1234 2163 16 8 50.214157 we5 1 121 1 3 2 1258 2151 65 21 0.000000 bacnana5 1 121 1 3 3 1321 2146 76 42 0.000000 Coniimies2 1 122 0 0 0 1476 2145 62 10 -1 3 1 122 1 0 0 1476 2145 62 10 -1 4 1 122 1 1 0 1476 2145 62 10 -1 5 1 122 1 1 1 1476 2145 62 10 37.444542 478-80592 1 123 0 0 0 1482 2175 56 10 -1 3 1 123 1 0 0 1482 2175 56 10 -1 4 1 123 1 1 0 1482 2175 56 10 -1 5 1 123 1 1 1 1482 2175 56 10 0.000000 ho-0d382 1 124 0 0 0 1237 2207 247 28 -1 3 1 124 1 0 0 1237 2207 247 28 -1 4 1 124 1 1 0 1237 2207 247 28 -1 5 1 124 1 1 1 1237 2209 67 21 51.062832 >Heat5 1 124 1 1 2 1315 2207 169 28 38.536087 Treating-Metal2 1 125 0 0 0 1552 1994 286 236 -1 3 1 125 1 0 0 1552 1994 286 236 -1 4 1 125 1 1 0 1552 1994 286 236 -1 5 1 125 1 1 1 1552 1994 286 236 95.000000 2 1 126 0 0 0 1555 2217 271 40 -1 3 1 126 1 0 0 1555 2217 271 40 -1 4 1 126 1 1 0 1555 2217 169 11 -1 5 1 126 1 1 1 1555 2217 52 11 0.000000 tcuee5 1 126 1 1 2 1606 2205 47 22 69.273369 Cows 1 126 1 1 3 1650 2201 6 35 0.000000 b5 1 126 1 1 4 1671 2219 26 8 25.230194 Gowns 1 126 1 1 5 1708 2217 16 10 65.384476 bs4 1 126 1 2 0 1555 2232 223 12 -1 5 1 126 1 2 1 1555 2234 52 9 14.879463 Borner5 1 126 1 2 2 1654 2235 5 9 33.003952 85 1 126 1 2 3 1669 2232 7 25 35.905624 85 1 126 1 2 4 1683 2233 5 9 50.928215 A5 1 126 1 2 5 1691 2232 87 25 0.000000 Conauionee4 1 126 1 3 0 1746 2246 80 11 -1 5 1 126 1 3 1 1746 2246 80 11 30.221390 feaevee5 1 126 1 3 2 1809 2238 20 28 24.177361 HD2 1 127 0 0 0 1553 2250 112 60 -1 3 1 127 1 0 0 1553 2250 112 60 -1 4 1 127 1 1 0 1553 2250 112 60 -1 5 1 127 1 1 1 1553 2250 112 60 95.000000 2 1 128 0 0 0 1829 2250 3 5 -1 3 1 128 1 0 0 1829 2250 3 5 -1 4 1 128 1 1 0 1829 2250 3 5 -1 5 1 128 1 1 1 1829 2250 3 5 95.000000 2 1 129 0 0 0 1484 2262 57 11 -1 3 1 129 1 0 0 1484 2262 57 11 -1 4 1 129 1 1 0 1484 2262 57 11 -1 5 1 129 1 1 1 1484 2262 57 11 68.502090 228-10192 1 130 0 0 0 1237 2269 271 86 -1 3 1 130 1 0 0 1237 2269 271 86 -1 4 1 130 1 1 0 1237 2269 265 54 -1 5 1 130 1 1 1 1237 2301 12 16 56.841438 >5 1 130 1 1 2 1258 2298 48 21 56.841438 Heat5 1 130 1 1 3 1317 2269 185 54 77.751755 Treating-Metal-4 1 130 1 2 0 1258 2325 250 30 -1 5 1 130 1 2 1 1258 2328 120 27 93.055817 Equipments 1 130 1 2 2 1390 2326 13 22 93.055817 &5 1 130 1 2 3 1415 2325 93 28 96.831978 Supplies2 1 131 0 0 0 1804 2258 32 18 -1 3 1 131 1 0 0 1804 2258 32 18 -1 4 1 131 1 1 0 1804 2258 32 18 -1 5 1 131 1 1 1 1804 2258 32 18 95.000000 2 1 132 0 0 0 1570 2295 225 28 -1 3 1 132 1 0 0 1570 2295 225 28 -1 4 1 132 1 1 0 1633 2295 162 10 -1 5 1 132 1 1 1 1633 2295 15 10 3.372726 HL5 1 132 1 1 2 1652 2295 45 10 3.372726 RANON5 1 132 1 1 3 1708 2286 47 28 38.998245 LATING5 1 132 1 1 4 1763 2295 6 10 0.000000 &5 1 132 1 1 5 1779 2295 16 9 12.554970 Oa4 1 132 1 2 0 1570 2312 186 11 -1 5 1 132 1 2 1 1570 2303 41 28 23.593620 CONDI5 1 132 1 2 2 1617 2312 36 11 0.000000 OuNG5 1 132 1 2 3 1662 2312 16 10 86.270035 CO5 1 132 1 2 4 1687 2313 45 9 49.904930 Bes5 1 132 1 2 5 1742 2314 14 7 18.508614 be2 1 133 0 0 0 1804 2310 28 11 -1 3 1 133 1 0 0 1804 2310 28 11 -1 4 1 133 1 1 0 1804 2310 28 11 -1 5 1 133 1 1 1 1804 2310 28 11 12.660912 980.2 1 134 0 0 0 1212 824 26 1556 -1 3 1 134 1 0 0 1212 824 26 1556 -1 4 1 134 1 1 0 1212 824 26 1556 -1 5 1 134 1 1 1 1212 824 26 1556 95.000000 2 1 135 0 0 0 911 1585 7 799 -1 3 1 135 1 0 0 911 1585 7 799 -1 4 1 135 1 1 0 911 1585 7 799 -1 5 1 135 1 1 1 911 1585 7 799 95.000000 2 1 136 0 0 0 890 1590 12 793 -1 3 1 136 1 0 0 890 1590 12 793 -1 4 1 136 1 1 0 890 1590 12 793 -1 5 1 136 1 1 1 890 1590 12 793 95.000000 2 1 137 0 0 0 747 2365 54 14 -1 3 1 137 1 0 0 747 2365 54 14 -1 4 1 137 1 1 0 747 2365 54 14 -1 5 1 137 1 1 1 747 2365 54 14 95.000000 2 1 138 0 0 0 584 2374 640 15 -1 3 1 138 1 0 0 584 2374 640 15 -1 4 1 138 1 1 0 584 2374 640 15 -1 5 1 138 1 1 1 584 2374 640 15 95.000000 2 1 139 0 0 0 588 841 18 1548 -1 3 1 139 1 0 0 588 841 18 1548 -1 4 1 139 1 1 0 588 841 18 1548 -1 5 1 139 1 1 1 588 841 18 1548 95.000000 2 1 140 0 0 0 540 2422 613 8 -1 3 1 140 1 0 0 540 2422 613 8 -1 4 1 140 1 1 0 540 2422 613 8 -1 5 1 140 1 1 1 540 2422 613 8 95.000000 2 1 141 0 0 0 1127 2404 132 18 -1 3 1 141 1 0 0 1127 2404 132 18 -1 4 1 141 1 1 0 1127 2404 132 18 -1 5 1 141 1 1 1 1127 2404 105 18 75.336815 APPENDIX5 1 141 1 1 2 1247 2406 12 16 92.928139 A2 1 142 0 0 0 1235 2366 307 14 -1 3 1 142 1 0 0 1235 2366 307 14 -1 4 1 142 1 1 0 1235 2366 307 14 -1 5 1 142 1 1 1 1235 2368 40 12 25.301704 Clan5 1 142 1 1 2 1273 2360 21 28 47.005123 Bw5 1 142 1 1 3 1301 2368 14 11 47.005123 Ce5 1 142 1 1 4 1324 2369 13 10 39.776970 0)5 1 142 1 1 5 1345 2369 43 9 52.716339 Nee5 1 142 1 1 6 1375 2360 17 28 47.041912 en5 1 142 1 1 7 1464 2366 78 11 47.705399 140-17032 1 143 0 0 0 1393 2373 69 3 -1 3 1 143 1 0 0 1393 2373 69 3 -1 4 1 143 1 1 0 1393 2373 69 3 -1 5 1 143 1 1 1 1393 2373 69 3 95.000000 2 1 144 0 0 0 1558 2361 189 21 -1 3 1 144 1 0 0 1558 2361 189 21 -1 4 1 144 1 1 0 1558 2361 189 21 -1 5 1 144 1 1 1 1558 2362 88 17 34.990112 Continued5 1 144 1 1 2 1657 2364 38 13 96.734642 Next5 1 144 1 1 3 1705 2361 42 21 83.765129 Pace2 1 145 0 0 0 540 2422 1297 97 -1 3 1 145 1 0 0 540 2422 1297 97 -1 4 1 145 1 1 0 540 2422 1297 97 -1 5 1 145 1 1 1 540 2422 1297 97 95.000000 2 1 146 0 0 0 1858 425 68 35 -1 3 1 146 1 0 0 1858 425 68 35 -1 4 1 146 1 1 0 1858 425 68 35 -1 5 1 146 1 1 1 1858 425 68 35 85.960373 471 Decision and Order 116 F.T.C.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of respondents named in the caption hereof, and respondents having been furnished thereafter with a copy of a draft complaint that the Bureau of Consumer Protection proposed to present to the Commission for its consideration and that, if issued by the Commission, would charge respondents with violation of the Federal Trade Commission Act; and Respondents, their attorney, and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by respondents of all the jurisdictional facts set forth in the aforesaid draft complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondents that the law has been violated as alleged in such complaint, and waivers and other provisions as required by the Commission's Rules; and The Commission having thereafter considered the matter and having determined that it had reason to believe that respondents have violated the said Act, and that the 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 sixty (60) days, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings and enters the following order: I. Respondent Bay Colony Audiology Center is a Massachusetts corporation with its office and principal place of business located at 825 Main Street, South Weymouth, Massachusetts. Respondent David Citron, III, is an audiologist who is an officer of Bay Colony Audiology Center. He formulates, directs and controls the policies, acts and practices of Bay Colony Audiology Center, and his office and principal place of business is located at the above stated address.

BAY COLONY AUDIOLOGY CENTER, ET AL. 473 468 Decision and Order Respondents are, and have been, selling hearing aids and offering hearing tests to the public.

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

ORDER I.

It is ordered, That respondents Bay Colony Audiology Center, a Massachusetts corporation, its successors and assigns, and its officers, and David Citron, II, individually and as an officer of said corporation; and respondents’ agents, representatives and employees, directly or through any corporation, subsidiary, division, affiliate, partnership, sole proprietorship, or other device, in connection with the advertising, promotion, sale, distribution or offering for sale of any hearing-related device or service in or affecting commerce, as commerce is defined in the Federal Trade Commission Act, do forthwith cease and desist from:

A. Misrepresenting, directly or by implication, in any manner that Medicare will pay for the costs of such device or service. B. Misrepresenting, directly or by implication, in any manner that other types of medical insurance, whether federal, state, or ' private, will cover the costs of such device or service. I.

It is further ordered, That respondents Bay Colony Audiology Center, a corporation, its successors and assigns, and its officers, and David Citron, ITI, individually and as an officer of said corporation, within fifteen (15) days after this order becomes final, send a certified letter to the publishers of all Yellow Pages directories that contain the representations in paragraphs seven and nine of the complaint. The letter shall state that any statements representing, Decision and Order 116 F.T.C.

directly or by implication, that Medicare will pay for the costs of hearing aids are to be eliminated from the next appearing edition in which it is possible to make changes, and in all subsequent editions. The letter shall also state that any statements representing, directly or by implication, that Medicare will pay for the costs of hearing tests are to be eliminated from the next appearing edition in which it is possible to make changes, and in all subsequent editions, unless the representation is qualified by a statement that the hearing tests must be ordered in advance by a physician for medical diagnostic purposes. Respondents shall include a copy of this order with the letter.

II. - It is further ordered, That respondents Bay Colony Audiology Center, a corporation, its successors and assigns, and its officers, and David Citron, IT, individually and as an officer of said corporation, within fifteen (15) days after this order becomes final, either: A. Post in each of the locations in which respondents do business, a prominent notice that is at least 12" by 15" in size that states clearly and conspicuously the following: MEDICARE DOES NOT COVER THE COSTS OF HEARING AIDS. MEDICARE ALSO DOES NOT COVER THE COSTS OF HEARING TESTS CONDUCTED IN THIS OFFICE UNLESS THE TESTS ARE FIRST ORDERED BY A PHYSICIAN FOR MEDICAL DIAGNOSTIC PUR- POSES.

This notice shall be clearly and conspicuously posted in the reception area so that it is visible to consumers as they enter the business location, and in each of the rooms where the hearing tests are conducted; or B. Provide each consumer prior to any discussion about the consumer's hearing problem a notice that is at least 8%" by 11" in size that states clearly and conspicuously the following: BAY COLONY AUDIOLOGY CENTER, ET AL. 475 468 Decision and Order MEDICARE DOES NOT COVER THE COSTS OF HEARING AIDS. MEDICARE ALSO DOES NOT COVER THE COSTS OF HEARING TESTS CONDUCTED IN THIS OFFICE UNLESS THE TESTS ARE FIRST ORDERED BY A PHYSICIAN FOR MEDICAL DIAGNOSTIC PUR- POSES.

Respondents shall obtain the consumer's signature on the notice. The signed notices shall be available to representatives of the Federal Trade Commission fcr inspection for a period of three (3) years from the date of service of this order.

C. The requirements described in (A) and (B) of this paragraph shall be followed for no less than two (2) years after the last date of distribution by the publisher to the general public of the Yellow Pages directories containing the representations in paragraphs seven and nine of the complaint.

IV.

It is further ordered, That respondents Bay Colony Audiology Center, a corporation, its successors and assigns, and its officers, and David Citron, IT, individually and as an officer of said corporation, shall, for three (3) years after the date of this order, maintain and upon request make available to representatives of the Federal Trade Commission for inspection and copying all records demonstrating compliance with this order, including but not necessarily limited to: (1) Communications with publishers of the Yellow Page directories regarding the representations in paragraphs seven and nine of the complaint, and (2) The notices required by paragraph III(A) and (B) above. V.

It is further ordered, That respondents shall, within thirty (30) days after service upon them of this order, distribute a copy of the order to each of their operating divisions, subsidiaries, and related Decision and Order 116 F.T.C.

offices, to each of their managerial employees, to each of their employees responsible for advertising, and to each of their officers, agents, representatives or employees selling hearing aids and/or offering hearing tests.

VI.

It is further ordered, That the corporate respondent shall notify the Commission at least thirty (30) days prior to any proposed change in respondent such as dissolution, assignment, purchase, or sale resulting in a change of ownership or business structure, or any other change in respondent that may affect compliance obligations arising out of this order.

VIL.

It is further ordered, That the individual respondent shall hereafter promptly notify the Commission in the event of the discontinuance of his present business or employment and, for a period of five (5) years from the date of service of this order, shall promptly notify the Commission of each affiliation with a new business or a new employment whose activities would or might include the sale of hearing aids, and/or the offering of hearing tests, each such notice to include the respondent's new business address and a-statement of the nature of such business or employment and a description of the respondent's expected duties and responsibilities. VO.

It is further ordered, That respondents shall, within sixty (60) days after service of this order, file with the Commission a report, in writing, setting forth in detail the manner and form in which they have complied with all requirements of this order. BROOKLYN AUDIOLOGY ASSOCS., P.C., ET AL. . 477 477 Complaint