Wlar Co

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IN THE MATTER OF WLAR CO., ET AL.

CONSENT ORDER, ETC., INREGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3641. Complaint, Feb. 21, 1996--Decision, Feb. 21, 1996 This consent order prohibits, among other things, a Virginia-based corporation and its officer from making unsubstantiated representations for their weight-loss booklets, products or program. The consent order requires the respondents to provide, in future advertisements, a disclosure statement that the products consist solely of a booklet or pamphlet containing information and advice on weight-loss.

Appearances For the Commission: Richard Cleland and C. Lee Peeler. For the respondents: Randall Shaheen, Arnold & Porter, Washington, D.C.

COMPLAINT The Federal Trade Commission, having reason to believe that WLAR Co., a corporation, and Michael K. Craig, individually and as an officer of said corporation ("respondents"), have violated the Federal Trade Commission Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges:

PARAGRAPH 1. Respondent. WLAR Co. is a corporation organized, existing, and doing business under and by virtue of the laws of the State of Delaware. Its principal place of business is located at 5622 Columbia Pike #106, Falls Church, VA. Respondent Michael K. Craig is or was at relevant times herein the sole owner, officer, and employee of the corporate respondent. Individually, or in concert with others, he participated in and/or formulated, directed, and controlled the acts and practices of the corporate respondent, including the acts and practices alleged in this complaint. His address is the same as that of the corporate respondent.

WLAR CO., ET AL. 99 98 Complaint PAR. 2. Respondents have advertised, offered for sale, sold, and distributed weight-loss and body-shaping products, consisting of booklets containing advice on dieting and exercise, to the public. Respondents have marketed these products under various names, including "Swedish 19," "Body Maker," "BM Program," "New Shape," and "Swedish System."

PAR. 3. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act. PAR. 4. Respondents have disseminated or have caused to be disseminated advertisements for their products, including but not necessarily limited to the attached Exhibits A through E. These advertisements contain the following statements: A. Swedish 19:

Get the look that boys really notice! You can have a cute body! Now you, too can have the cute, foxy body you've always wanted -- the kind of body that really gets you noticed. And it can happen faster than you think! You can have a narrower waist, thinner hips, legs and thighs, and a firmer behind. That's right -- no matter what you look like right now, just a few short weeks from today you could have a body that's thinner, firmer and cuter than you ever thought possible! JUST FOLLOW THE EASY INSTRUCTIONS IN THE SWEDISH 19 GUIDE! No matter how many times you've tried and failed before, this time you really can do it. Finally, here's something that really works! How Swedish 19 works Swedish 19 will quickly show you how to lose weight while eating the foods you like -- including those snacks you love so much. It's not a diet -- so there's no list of things you have to eat. No list of things you can't eat, either. But when you use Swedish 19, you'll end up eating less (but still enough to keep you healthy.) Pretty soon, all those extra pounds will be gone for good. Swedish 19 will help you control your appetite before meals and avoid overeating -- even when you're dying to have a snack! And before you know it, you'll have a whole new set of eating habits, be thin, and stay thin -- with nothing more to buy. This is not like those diet pills you have to keep buying over and over again! And -- if you're too skinny and just dying to get some curves -- you can make your body cuter and foxier -- adding shape and curves in all the right places! Made for a teenage girl's body Swedish 19 was designed especially for a teenage girl's body. It's the safest, most natural way to lose weight we could find for you. It's a safe, healthy way to lose weight. And it works. Show it to your doctor -- we're sure he'll agree! Complaint 121 FLT.C.

Here's more good news. You never have to do any long boring exercises -- and you won't need to! When you use Swedish 19 you'll just feel like being more active all the time. You'll burn up calories while you're having fun! It works! Just days after you get Swedish 19, you can be eating less, feeling more active, and really happy about the changes starting to take place. * * * * Try to imagine how gorgeous you'll look. How your body can be really slim, trim and firm. Really picture it in your mind. It can happen to you! You can do it! The best part is -- you'll be sooo. . . proud of yourself when you find out you really can have a cute body. It's not your fault you haven't lost weight -- it's those worthless diets that don't work! * * * * Get a totally cute body - - or your money back! Swedish 19 has worked for thousands of girls. And we're so sure it'll work for you, too, that we want you to try it for a whole month at no risk. Go ahead -- really use it as much as you want. Let it help you slim down, shape up and beautify your body. * * * * Here's all you've got to do. Fill out the coupon and send it in with $12 right away. We'll send you Swedish 19 fast. (The package won't say who it's from or what's inside.) * * * * (Exhibit A) B. Swedish System:

New! How you can...

Get the shape that boys really notice! You can have a cute body! Now you, too can have the cute, foxy body you've always wanted - the kind of body that really gets you noticed. And it can happen faster than you think! Swedish girls are famous for their beautiful bodies. And the awesome Swedish System will quickly and easily show you how to get rid of excess, flabby fat - while adding shape and curves in all the right places! You can have a narrower waist, thinner hips, legs and thighs, and a firmer behind. Yes - just a few short weeks from today you could have a body that's thinner, firmer and cuter than you ever thought possible! No matter how many times you've tried and failed before, this time you really can do it. Finally, here's something that really works! How the Swedish System works When you use the Swedish System, you still get to eat the same foods you've been eating - including those snacks you love so much. It's not a diet - so there's no list of things you have to eat. No list of things you can't eat, either. But when you use the Swedish System, you'll end up eating less (but still enough to keep you healthy.) Pretty soon, all those extra pounds will be gone for good. If you're overweight, the Swedish System will help you control your appetite before meals and avoid over-eating - even when you're dying to have a snack! And before you know it, you'll have a whole new set of eating habits, be thin, and stay WLAR CO., ET AL. 101 98 Complaint thin - with nothing more to buy. This is not like those diet pills you have to keep buying over and over again! Or - if you're too skinny and just dying to get some curves - you can make your body shapelier and foxier - adding shape and curves in all the right places! Made for a teenage girl's body The Swedish System was designed especially for a teenage girl's body. It's the safest, most natural weight loss product we could find for you. . .. Here's more good news. You never have to do any long boring exercises - and you won't need to! When you use the Swedish System you'll just feel like being more active all the time. You'll burn up calories while you're having fun! It works! Just days after you start using the Swedish System, you can be eating less, feeling more active, and really happy about the changes starting to take place. Just follow the easy directions in the Swedish System guide. * * * * Can you see it? Try to imagine how gorgeous you'll look. How every part of your body can be slim, trim and firm. Really picture it in your mind. It can happen to you! You can do it! The best part is - you'll be sooo. . . proud of yourself when you find out you really can have a cute body. It's not your fault you haven't lost weight - it's those worthless diets that don’t work! Now you really can make your dreams come true. Definitely! * * * * Try it fora whole month! This system has worked for thousands of girls. And now we've made it even better! We're so sure it'll work for you, too, that we want you try it for a whole month at no risk.

* * FF (Exhibit B) C. BM Program:

Get the body that gets the boys How to lose weight fast and look great You can have the cute, thin body you've always wanted -- the kind of body that really gets boys’ attention. And lose weight fast from your waist, butt, hips and thighs -- so you're thin everywhere. You can do it without going on the usual kind of diet -- thanks to a special new discovery called the BM Program. A great new body You'll lose fat from every part of your body. Want a narrow waist? No problem. Firm behind? You got it. Slim hips? Sure. Thin legs? Of course. The BM Program's extra fast action will work on every part of your body. So -- no matter what parts of your body are too big right now -- you'll have the great body you want fast and easy.

It doesn't matter whether you need to lose ten, twenty, even forty pounds or more. You can get them off and keep them off for good. . . . Every square inch of your body can be trim and firm... . Complaint 121 F.T.C.

At last, here's something that really works. No matter how many times you've tried and failed to lose weight before, now you can do it. Just follow the easy directions in the BM Program guide. Why diets don't work You know what all those diets are like. You're supposed to have half a grapefruit for lunch and nothing else. But if you had the willpower to eat just that, you wouldn't have a weight problem now, would you? * * * * But it's not your fault. The big problem with diets is that they leave you hungry, and you can only hold out for so long. Heavy exercise just makes you tired and hungry. And diet pills can be dangerous. It's new The BM Program is totally different from anything you've ever tried before. Don't confuse this program with any other one. Here's why it's different. It helps you fight hunger and change your eating habits so you eat less -- without getting hungry. There's no "diet" or list of things you have to eat. No forbidden foods, either. No calorie-counting. You can keep on eating your favorite foods -- even snacks. But you'll end up eating less. You just won't feel like pigging out. And, best of all, those extra pounds that make you look ugly will go away fast! It works Even if you've tried everything else and failed, the BM Program is the last weight loss solution you'll ever need. It really works. BM can help you to 1) stop gaining weight, 2) lose weight by getting rid of body fat and best of all 3) help you stay slim and trim. BM works fast, too. You'll start changing your eating habits the first day -giving you results you can start to notice in just a couple of weeks. And although not everyone loses weight at the same speed, the results will be absolutely amazing. This program is so powerful that you have to be careful not to lose weight too fast. If that happens, just stop using it for a day or two. BM is safe and natural. There are no drugs or anything artificial. * * * * Here's proof How well does the BM Program work? We had 100 girls try it. Desperate girls who had tried almost everything else, and who had given up hope. And -guess what? Only two of them asked for their money back. Just two out of 100. So we're 98% sure that it'll work for you. ... Hard to believe it could be so easy? Of course it is. That's what those other girls thought before they tried it. Boy, were they surprised! It's the best We've checked out over a dozen weight loss systems and this one's the best one we found. Just give it a try and we know you'll agree. * * * * (Exhibit C) D. New Shape:

New! How you can...

Get the cute shape that boys like and girls envy! k oe * & WLAR CO., ET AL. 103 98 Complaint The perfect bod Now you, too, can have the kind of body that boys like and girls envy; thin, shapely legs and thighs, firm behind, narrow waist, and foxy, exciting curves in all the right places. ...

No matter how many times you've tried and failed before, now you can really do it -- thanks to an excellent new discovery that can really work for you.... Extra help for special areas New Shape™ does more than just help you get rid of excess fat. It helps you add shape and firmness too. It's a total shape-up system that you can customize to your own special needs .... Whether you're too fat or too skinny, New Shape can help you get the kind of body you've always wanted. It really works. This system was designed especially for teenage girls and is made to fit your lifestyle. So you can still have snacks and go out for hamburgers with your friends. Works twice as fast The New Shape System works twice as well -- and twice as fast -- because it combines two powerful factors. Yet it's completely natural and safe for girls of all ages. With no dangerous crash diets, no drugs, and no special foods. It's easy and safe (no drugs!) You won't find a faster, easier, safer way to slim down and shape up your body. We know -- because we've tried pretty much everything there is. Don't confuse New Shape with any other product or company. * *¥ * * Order the New Shape System. You'll get it fast -- in a plain, unmarked package .... Use it as much as you need to get the body you want... . We've helped thousands of girls just like you -- and we know we can help you, too. * * * * (Exhibit D) E. Body Maker:

HOW YOU CAN HAVE A FIRM, FOXY, THINNER BODY - in just a few weeks! THE BODY YOU'VE ALWAYS WANTED! You can have the cute, foxy body you've always wanted -- the kind of body that really gets guy's attention. And you can look that way sooner than you think! Just a few short weeks from today you could have a body that's thinner, firmer and cuter than you ever imagined -- thanks to an awesome new discovery. Body Maker™ helps you lose weight from every part of your body. You can have a narrower waist, thinner hips, legs and thighs, and a firmer behind -- and add shape, firmness and curves in all the right places! No matter how many times you've tried and failed before, now the awesome new Body Maker can quickly and easily show you how to get a body that's cuter and foxier than you ever thought possible! Finally, here's something that really works! HOW BODY MAKER WORKS With Body Maker, you still get to eat the foods you like -- including those snacks you love so much. It's not a diet -- so there's no list of things you have to eat. No list of things you can't eat, either. But when you follow the Body Maker program, you'll end up eating less (but still enough to keep you healthy.) You just Complaint 121 E.T.C.

won't feel like pigging out! And pretty soon, all those extra pounds will be gone for good.

Body Maker will help you cut down on you appetite before meals and avoid over-eating -- even when you're dying to have a snack! And before you know it, you'll have a whole new set of eating habits, be thin, and stay thin -- with nothing more to buy. This is not like those diet pills you have to keep buying over and over again! MADE ESPECIALLY FOR TEENAGE GIRLS Body Maker was created especially for a teenage girl's body. It's the safest, healthiest way to lose weight we've ever seen. And it works! ... Here's more good news. You never have to do any exercises -- and you won't need to! With Body Maker you'll just feel like being more active all the time! IT WORKS! Just days after you get Body Maker, you can be eating less, feeling more active, and really happy about the changes starting to take place. *x* * ok Ok It's not your fault you haven't lost weight -- it's those worthless diets that don't work! * * * * Body Maker has worked for thousands of girls... . Go ahead -- really use it as much as you want. Let it help you slim down, shape up and beautify your body. * * # & (The Package won't say who it's from or what's inside.) * * * * (Exhibit E) PAR. 5. Through the use of the statements contained in the advertisements referred to in paragraph four, including, but not necessarily limited to the advertisements attached as Exhibits A through E, respondents have represented, directly or by implication, that:

A. BM Program, New Shape, and Body Maker are new weightloss discoveries; and B. Users of Swedish 19, Swedish System, BM Program, New Shape, and Body Maker are not required to consciously diet to lose weight.

PAR. 6. In truth and in fact:

A. BM Program, New Shape, and Body Maker are not new weight-loss discoveries; and WLAR CO., ET AL. 105 98 Complaint B. Users of Swedish 19, Swedish System, BM Program, New Shape, and Body Maker are required to consciously diet to lose weight. These products are booklets containing advice for reducing caloric intake and require conscious dieting to lose weight. Therefore, the representations set forth in paragraph five were, and are, false and misleading.

PAR. 7. Through the use of the statements contained in the advertisements referred to in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A through E, respondents have represented, directly or by implication, that:

A. Swedish 19, Swedish System, BM Program, New Shape, and Body Maker cause fast and easy weight loss; B. Swedish 19, Swedish System, BM Program, New Shape, and Body Maker are more effective than other products or programs in controlling appetite and causing weight loss; C. Purchasers of Swedish 19, Swedish System, BM Program, New Shape, and Body Maker are successful in controlling appetite, losing weight, and reducing body fat; D. Swedish 19, Swedish System, BM Program, and Body Maker cause users to develop a new set of eating habits, thereby reducing caloric intake and causing significant and long-term or permanent weight loss; and E. Thousands of girls have successfully lost weight by using Swedish 19, Swedish System, New Shape, and Body Maker. PAR. 8. Through the use of statements contained in the advertisements referred to in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A through E, respondents have represented, directly or by implication, that at the time they made the representations set forth in paragraph seven, respondents possessed and relied upon a reasonable basis that substantiated such representations. PAR. 9. In truth and in fact, at the time they made the representations set forth in paragraph seven, respondents did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, the representation set forth in paragraph eight was, and is, false and misleading. Complaint 121 E.T.C.

PAR. 10. In their advertising and sale of Swedish 19, Swedish System, BM Program, New Shape, and Body Maker, respondents have represented that these products will reduce appetite and result in significant weight loss. Respondents have failed to disclose adequately that these products consist only of booklets or pamphlets containing advice concerning techniques for reducing caloric intake and/or exercise, and that reducing caloric intake and/or increasing exercise is required to lose weight. These facts would be material to consumers in their purchase or use decisions regarding the products. The failure to disclose these facts, in light of the representations made, was, and is, a deceptive practice. PAR. 11. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

Chairman Pitofsky recused.

WLAR CO., ET AL.

Complaint EXHIBIT A Get the look that boys Now vou, too can have the cute. foxy body you've always wanted -- the kind of body that really gets you nouced. And tt can happen faster than you think! You can have a narrower waist, thinner hips. legs and thighs, and a firmer behind. That's nght -- no matter what you took like ght now. just a few short weeks from today you could have a-body that’s thinner, firmer and cuter than you ever thought possible! JUST FOLLOW THE EASY INSTRUC.

TIONS IN THE SWEDISH 19 GUIDE! No matter how many umes you've tned and failed before, this ume you feally can do 1L Finaily, here’s something that teally works? How Swedish 19 works Swedish 19 will quickly show vou how to lose weight while eaung the foods you like s+ including those snacks you love so much. It's not a diet -- so there's no list of things you have (o eat. No Itst of things you cant eat, either. But when you use Swedish 19, your end up eating less (but sull enough to keep you healthy.) Pretty soon, all those extra pounds wull be gone for good.

Swedish 19 will help you control your appetite before meals and avoid over-eaung -even when you're dying to have a snack! And before you know i, voulll have a whole new set of eating habitus, be thin, and stay thin -with nothing more to buy. This ts pot tke those diet pills you have to keep buying over and over again! And -- if you're too skinny and just dying (0 get some curves -- you can make your body cuter and foxier = adding shape and Curves in al! the nght places! Made for a teenage girl's body Swedish 19 was designed especially for 2 teenage girl's body. It's the safest. most natural way to lose weight we could find for you. It's a safe, healthy way to lose weight And it works, Show 1t to your doctor -- we're sure he'll agree! Here's more good news. You never have to do any long bonng exercises -- and you won't need to! When you use Swedish 19 you'll just feel uke being more active all the ume. You'll bum up calones while you're having fun! It works! Just days after you get Swedish 19, you can be eating less. feeling more active, and really happy about the changes staring to take place Before you know it, you'll be going to the mall to get that cute bikins you always wished you could wear. And when vou look tn the mirror, you won't believe how good vou look! Can you see 11? Try to imagine how gorgeous you'll look. How your body can be really slim, tnm and firm. Really picture itin your mind. it ¢an happen to you! You can do it! The best part 15 +- you'll be sooo... proud of yourself when vou find out vou really can have a cute body. It’s not your fault you haven't lost weight «- t's those worthless diets that don't work! Now you really can make Your dreams come true. Definitely! Your high schoo! years are supposed to be the happiest ume of your life. Make sure you don't miss out on all those special moments -- the beach, parues, school dances, the prom.

Sure -- once you look so good, all those Buys that never nouced you before might stant asking you out But don't yust do tus for the guys. Do it for yourself. You deserve it! Get a totally cute body -- or your money back! Swedish 19 has worked for thousands of girls, And we'te so sure it'll work for you, (Oo, that we want you fo in it for a whole Month at no nsk.

Go ahead + really use it as much as sou want. Letit help you siim down, shape up and Dbeauufy your body.

Then -- af you feel you havent changed enough «+ if you don't have the awesome body you've always wanted -- just send everything back to us and we'll give you your money back. We don't want your money unless you et the body vou want! o it now! Here's all you've got to do. Fill out the coupon and send it in with $12 nght away. We'll send you Swedish 19 fast. (The package won't say who it's from or what's inside.) So don’t wait. If you put it off you might forget, and miss out on the cute body you want, and all the good umes you deserve. Dott now. You'll be so glad you did. P.S.: Wanna get a cute body even faster? We've put together some really easy, fun exercises you can do in just }5 minutes a day. Use them with Swedish 19 and you'll get temfic results super-fast! They're vours for just $3 extra when you get Swedish 19. Good deal! Plus -- we'll even throw in 3 FREE Gift! You'll also get a chart to keep track oF your weight foss absolutely FREE, just tor ordenng Swedish 19 Hurry up and be the first one at your school to get that cute body' Make this the best year of your fife’ T1993 Swedin ty Coupon gone? Seng $12 wath your name and aigress Swaaisn 19. P.O Bor 2245. Kensingion, MD 20891 EXHIBIT A really notice! ve ee ee era aT j FREE 30-DAY TRIAL! Swedish 19 +s Nichotson Lane PP.0 Box 2245 t Kensington, MD 20891-2245 Coool' | want a totally cute bods Send me I Swedish 19 fast! Money back guarantee. Here's 1 $12 for yust Swedish 19 i D $15 for Swedish 19 plus exercises | PRINT Name.

Sure Zip.

BODY GOALS SURVEY FORM (Answer only if you want 1o) I © Im overwerght and want a thinner body... or 9 ico skinny and want more shape & curves [want to change’ (Check as many as you want) O arms D Want Z Thighs i] I 2 Stomach TZ Bun & Legs 1 & Chest © Hips 2 Otner, ! beewaeewe eee wee el Complaint 121 F.T.c.

EXHIBIT B New! How you can...

Get the shape that boys really notice! You can have a cute body! Now you, too can have the cute, foxy body you've always wanted — the kind of body that feally gets you noceed. And it can happen faster than you think! Swedish girls are famous for their beautiful bodies. And the awesome Swedish System will quickly and easily show you how to get rid of excess, flabby fat — while adding shape and curves in all the right places! You can have & narrower waist, thinner hips, legs and thighs, and a firmer behind Yes = just a few shon weeks from today you could have a body that's thinner, firmer and cuter than you ever thought possible! No maner how Many times you've ried and failed before, this tine you really can do it Finally, here's something that really works! How the Swedish System works When you use the Swedish System, you still get to eat the same foods you've been eaung = including those snacks you love so much. Irs not a diet = so there's no list of things you have to eat. No list of things you can't eat, either. But when you use the Swedish System, you'll end up cating less (but still enough to keep you healthy.) Precy soon. all those exera pounds will be yune for good If you're overweight, the Swedish System will help you control your appente before meals and avoid over-eating — even when you're dying to have a snack! And before you know it, you'll have a whole new set of caung habits, be thin, and stay thin + with nothing more to buy. This is nay like those diet pills you have to keep Duying over and Over again! Or — if you're too skinny and just dying to gt! some curves — you can make your body shapelier and foxier — adding shape and curves in ail the right places! Made for a teenage girl's body The Swedish System was designed especially for a teenage girl's body. It's the safest, most natural weight loss product we could find for you. 1: won't hunt or harm your body in any way. Everything in the Swedish System is healthy for you. Show it to your doctor — we're sure he'll agree! Here's more, good news. You never have to do any long boring exercises — and you won’ need to! When you use the Swedish System youll just feel like being more active all the me. You'll bum up calones while you're having fun! It works! Just days after you sian using the Swedish System, you can be eating less, feeling more active, and teally happy about the changes staming to take place. Just follow the easy duecuons in the Swedish System guide. Before you know it, you'll be going to the mal! to get that cure bikini you always wished you could wear. And when you look in the murtor. you won't believe how good you look! Can you see it?) Try to imagine how . asking you ovt But don't just do this for the guys. Do it for yourself. You deserve it! Try it for a whole month! This system has worked for thousands of girls. And now we've made it even better! We're so sure itl) work for you, too, that we want you to try it for a whole month af no risk, Go ahead = really use it as much as you want Let it help you slim down, shape up and beauty your bady.

Then = if you feel you haven’ changed enough — if you don’t have the awesome body you've always wanted — just send back the Swedish System and wel-give you your money back. We don't want your money unless you get the body you want! Do it now! Here's ell you've got to do. Fil} out the coupon and send it in with $12 right away. We'll send you the Swedish System fas, (The package won't say who it's from or what's inside.) .

So dont wait Lf you put it off you might forget, and miss out on the cute body you want, and al] the good times you deserve. Do it now. You'll be so glad you did. P.S.: Wanna get a cute body even faster? We've put together some really easy, fun exercises you cas do in just 15 minutes a day. Use them with the Swedish System and you'll get terrific results super-fast! They're yours for just $3 extra when you get the Swedish System. Good deal! Plus — we'll even throw ina...

FREE Gift! ‘You'll also get a chart to keep rack of your weight loss absolutely FREE, just for ordering the Swedish System.

Hurry up and be the first one at your school to get that cure body! Make this the best year of your Life! 0199) Souben Syme fans Hany Sn SO Oy ONE Hea GE SS Kas OE GU ON I 30-Day Trial Coupon i i Swedish Sysiem is I Nicholson Lane I I r.0. Bor 25 | 20891-2245 | I TB toully cuse body. Sond me the : : ; 1 Swedish Sysiem fast! Money ba panniechord orgeous you'll Jook. How every part of your # $12 for just ihe Se yBem Body can be slim, tim and firm. Really picture it C515 for the Swedish Sysiem plus exercises 1 in your mind. Ji gan happen to you! j Paint 1 You can do it! ~~ i The best part is - youll be sooo... proud 4 Address j of yourself when you find out you really can I 1 have acute body. It’s nor your (aulr you haven't l Gay. _Suse___Zip. r lost weight ~ it’s those worthless cicts that don't work! Now you really can make sour dreams Body Goals Survey Form 4 come tue. Definitely! (Answer only if you want to) The new school year is just siaming Your J © Tm overwerghy and want a thinner body... oF i high school years are supposed 10 be the happiest: | O Tm too skinny and wants more shape & curves | lume of your Ife Make sure you gon (muss Out ff fwancto change: (Check as many 43 you want) 1 on all those special moments - tne beach, 12 Ams. © Was ( Thighs I Parues, school dances. the prom © Stomach CO Butt © Legs Sure = once you look su caw. all those PE Gea CG) Hips = C) Oter___! guys that never nouced you before might stan Oe comes ome wwe ee ew os ee we ed EXHIBIT p | that the How to lose weight fast and look great Ou Can have the cute, thin body you've Y sens wines ean of body feally gets boys’ antention. And lose weight fast from your waist, bua. hips and thighs ~ so you're thin everywhere. You can do it without goung on the usual kind of dier — thanks to a special new discovery called the BM Program.

A great new body You'll lose fat from every part of your body. ‘Want a narrow waist? No problem. Firm behind? You gocit Slim hips? Sure. Thin legs? Of course. The BM Program's ex fast acton will work on every pan of your body. So ~ Ro maner wha pans of your body are too big Tight now - you'll have the great body you want fast and easy.

It doesn't matter whether you need to lose len, twenry, even forty pounds or more. You Can get them off and keep them off for good. And get the look thar really gets you nouced Every square inch of your body can be cim and firm. Your body wil) have a great new shape. You'll look great in shorts, a miniskin, or a bikini You'll be able to wear the lands of clothes that show off your new thin body — instead of trying to find clouhes to hide it. Even your face , will look premer ss you lose extra weight: At last, here's something that really works. No matter how many umes you've med and failed to lose weight before, now you can do it Just follow the easy directions in the BM Program guide. Why diets don't work You know what all those diets are like. You're suppased to have half a grapefruit for luneh and nothing else. But if you had the willpower to eat just tha, you wouldn't have a weight problem now, would you? So you cheat on your diet. And end up feeling fat and guilty.

But it's not your fault The big problem with diets is that they leave you hungry, and you can only hold out for so long. Heavy exercise just makes you ored and hungry. And diet pills can be dangerous.

It's new The BM Program is totally different from anything you ve ever tied before. Don't confuse this program with any other one. Here's why its different. It helps you fight hunger and Change your eanng habit so you eat less — without genung hungry. There's no “diet® or List of Uungs you have to eat No forbidden foods, WLAR CO., ET AL.

Complaint EXHIBIT C Get the bod gets either. No calorie-counting. You can keepon eating your favonte foods - even snacks. But you'll end up eating less. You just won't feel like pigging out And, best of all, those extra pounds that make you look ugly will go away fas It works Even if you've tried everything else and failed, une BM Program is the last weight loss solution you'll ever need. It really works. BM can help you to 1) stop gaining weight, 2) lose weight by getting rid of body far and best of all 3) help you stay slim and rim. BM works fast, too. You'll san changing your eating habits the first day — giving you Tesults you can star to nocce in just s couple of weeks. And although not everyone loses weight at the same speed. the results will be absolutely amazing.

‘This program is so powerful that you have to be careful not to lose weight too fast If that happens, just stop using it for a day or two. BM is safe and natural. There are no drugs or anything artificial.

What makes BM exc special is that it was Originally developed especially for actresses and models. They need tw get and keep a greatlooking body fast But you doo’ have to be an actress or model to have a slim body chat gets you noceed. Very soon all the cute boys will stan paying lors of smenton to you ~ instead of the other girts.

Here's proof How well does the BM Program work? We had 100 girls wy it. Desperate girls who had ied almost everything else. and who had given up hope. And — guess what? Only two of them asked for their money back. Just two out of 100. So we're 98% sure that if ll work for you. And if for any reason it doesn't, youll get your money back. So you've got nothing to lose by Biving it acy, Hard to believe it could be so easy? Of Course it is. That's what those other girls thought before they med it Boy, were they surpnsed! It's the best We've checked out over a dozen weight loss Systems and this one's the best one we found. Just give ita try and we know your agree. You know what it’s like being ignored ata school dance. Or being too embarrassed to be Seen in a bikini, You deserve better than that Now it’s your tum to look great. Your tum 10 get all the cute boys’ antennon. Your rum to F EXHIBIT y ‘. ratio have some fun.

You can't get the BM Program in stores. ‘They don't have it yet. But you don't have to wait, You can get it by mail right now. Send in the coupon with $12 now and you'll get itright away, in a plain package. And Pretty soon your have the great-looking body you've ways wanted Give yourself a chance. You'll be glad you did Do it now — before some other girl does and Bets all the boys’ attention.

FREE bonus gift P.S.: Order now and you'll also get & Special chan to keep track of your weight loss, absolutely FREE. orn a ee ne re ee ey BM I Twinbroot Center 2. ] P.O. Box 727 ! Rockville, MD. 20848-0727 I ! Hey! | know what kind of body I want. Send me 1 we BM Program ina plain package nghisway, I 1 Here's $12. Money back guarantee. ! [prmtname_ | se jon State, Zip. —_——]} be coe es oe coe oe ee ee oe ee oe oe ed Complaint 121 F.T.C.

EXHIBIT D New! How you can...

Get the cute shape that boys like and.

SIFTS ENVY! or reeenene notice you in school (and hopefully ask you out!) You can have all the fun you've been missing out on -- and you deserve it! You can do it. You really can make your dream come true, Here's all you have to do:

Order the New Shape System. You'll get it fast -- in a plain, unmarked package. Try it out for a week, a month, even two months. Use it as much as you need to get the body you want. Then take a look in the ~ mirror. You'll look sooo... cute and foxy you won’ believe your eyes! And you can Stay that way, too, with nothing more to buy.

We guarantee it But if you feel you haven't changed enough = if you don’t think you look like a total babe - just send everything back to us and you'll get your money back right away. We guarantee New Shape because it really works. We've helped thousands of girls just nike you — sng we knew we enn help you, too.

Do it now! So don't just think about having a beautiful body. Don't just dream about what it would be like. Uf you put it off until tomorrow, you might never do it. Do something about it now -- and make your dream come true. Don’t wait until some other girl starts going out with that guy you've got your eye on. Do it now. Just send in the coupon with $12 today, and get the kind of body you really want. Your be $0 glad you did.

FREE bonus gift You'll also get an extra free bonus -- a Special surprise gift that can help you get a Th 's a girl in every school who is Tr beautiful — so foxy ++ that all the boys just can't keep their eyes off her. A girl who's surrounded by cute guys wherever she goes. A girl that can have any guy she wants. Very soon, that girl could be you! The perfect body Now you, too, can have the kind of body that boys like and girls envy: thin, shapely legs and thighs, firm behind, narrow waist, and foxy, exciting curves in all the right places. With THAT kind of body you'll look great in shorts or a miniskirt, and totally awesome in that cute little two-piece swimsuit that you always wished you could wear, No matter how many times you've tried and. failed before, now you can really do it +» Uianks to an excellent new discovery that can reatiy. work for you. Just think -- only 3 few shon weeks from today you could have a whole new look! Extra help for special areas New Shape™ does more than just help you get rid of excess fat. It helps you add shape and firmness too. It's a total shapeup System that you can customize to your own special needs. So you can work on your legs, waist, butt, hips, thighs and other problem pants of your body to make them shapelier, firmer, tighter and more beautiful. You can change your flabby, embarrassing features -- but keep your good parts. Whether you're too fat or too skinny, New Shape can help you get the kind of body you've always wanted. It teally works.

This system was designed especiall: ‘ou! j more beautiful body even faster. This free for teenage girls and is made to fh your. youll dove bane handsome hunks gift is available only while supplies las. lifestyle. So you can still have snacks and ee ares rurmnaseaenetegmmm, Get it before we run out! ~ wn 80 out for hamburgers with your friends. New Shape with any other product or Sarita New Ships P.O. Bos 2u0s, Kunonga. MD 50M. Works twice as fast company. preteen The New Shape System works twice as And. best of all, you'll stan working J Hiced Soap on | well -- and twice as fast -- because it on your own special problem areas right 1 icrotas combines (wo powerful factors. Yet it's away -- to give them the special attention inpron: MDDIO891 2245 4 yest bacfinitety « Yes! | definitely want to look like @ babe. Send me | completely natural and safe for girls of all they need and help you get the cute, foxy i ages. With no dangerous crash diets. no shape you really want. } use NewShape System in a plain package nght away. drugs. and no special foods. You know what it’s like being laughed | Heres $12. Money back guaraniec, I It's easy and safe (no drugs!) 3t in gym class or being ignored at a pany. | print Name. J You won't find a faster, easier, safer Why pul up with it when you don't have to? J Adaress I way to slim down and shape up your body. Ht really works 1 { We know -- because we've tried pretly You'can look beautiful un that special ff Gay. | much everything there is. Don't confuse — party dress. You can look awesome 1 2 eee eee eae can enamam anal Siate, Zip.

EXHIBIT.

D HUW YUU LAN HAVE A FIRM THINNER BODY THE BODY YOU'VE ALWAYS WANTED! You can have the cute, foxy body you've always wanted -- the kind of body that really gels guys’ attention. And you can look that way sooner than you think! Just a few short weeks from today you Could have a body that's thinner, firmer and cuter than you ever imagined -thanks to an awesome new discovery. Body Maker™ helps you lose weight from every part of your body. You can have a narrower waist, thinner hips, legs and thighs, and a firmer behind -and add shape, firmness and curves in all the right places! No matter how many times you've tried and failed before, now the awesome new Body Maker can quickly and easily show you how to get a body that’s cuter and foxier than you ever thougnt Possible! Finally, here's something that really works! HOW BODY MAKER WORKS With Body Maker, you still get to eat the foods you like -- including those snacks you love so much. It's not a diet *- SO there's no list of things you have to “eat. No fist of things you cant eat, either. But when you follow the Body Maker Program, you'll end up eating less (but Still enough to keep you healthy.) You just won’ fee! like Pigging out! And pretty SOON, all those extra pounds will be gone for good.

Body Maker will help you cut down on your appetite before meals and avoid Over-eating -- even when you're dying to have a snack! Ang before you know it, you'll have a whole new set of eating habits, be thin, and stay thin -- with nothing more to buy. This is not like those diet pills you have to keep buying over and over again! MADE ESPECIALLY FOR TEENAGE GIRLS Body Maker was created especially for a teenage girl's body. It's the safest. healthiest way to lose weight we've ever seen. And it works! Show it to your Goctor -- we're sure hell agree! Here’s more good news. You never have to do any exercises -- and you won't need to! With Body Maker you'll just feel like being more acuve all the time! IT WORKS! Just days after you get Body Maker, you can be eating less, feeling more active, and really happy about the changes staring to lake piace.

WLAR CO., ET AL.

Complaint EXHIBIT E “t tried your product, and it worked," -- Anna, age 16, Calitornia (That's her picture, above!) Before you know it, you'll be going to the mall to get that cute bikini you always wished you coulc wear. And when you look in the mirror. you won't believe how GOOd you look! Can you see 1:7 Try to imagine how gorgeous you'll look. How every pan of your body can be simmer, trimmer and cuter than you ever thought possibie. Really picture it ix your mind. It can happen to you! YOU'LL FEEL GOOD ABOUT YOURSELF! The best parties -- you'll be so proud of yourself when you find out you really can lose weight It's not your fault you haven’ lost weight -- it's those worthless diets that dont work' Now you really can make your dreams come true.

Absolutely! Your high school years are Supposed to be the happiest time of your lle. Make sure you don't miss out on ail those special moments -- the beach, pool Panties, the prom Sure -- once you look so good, all those guys that never noticed you before will Stam asking you out But dont just do ints tor the guys Do it tor yourself You Way if EXHIBIT } , FOXY, — in just a few weeks! deserve it! TRY IT FOR 30 DAYS Body Maker has worked for thousands of girls. And we're so sure it'll work for you, too, that we want you to try it for a whole month at no risk. Go ahead -- really use it as much as you want. Let it help you slim down, shape up and beautily your body. Then - if you fee! you haven't changed enough -- if you don't have the awesome body you've always wanted - + just send back Body Maker and we'll give you your money back. We don't want your money unless you get the body you want! DO IT NOW! Here's all you've got to do. Fill out the Coupon and send it in with $12 right away. We'll send you Body Maker fast, (The package won't say who it’s from or what's inside.) So don’ wait. If you put it off you might forget, and miss out on the cute body you want, and all the good times you deserve.

Do it now. You'll be so glad you cid.

P.S.: Want a cute body even faster? We've put together some teally easy, fun exercises that you can co in just 15 minutes a day. Use them with Body Maker tor exira-last results! They're just $3 extra when you get Body Maker. Good deal! Plus -- we'll even throw ina... FREE GIFT! You'll also get a chant to keep track of your weight loss absolutely free, just tor ordering Body Maker.

Hurry up and be the first one at your school to get that cute body! : Coupon gone? No problem! Just send $12 10 Body Maker, P.O. Bor 727, Rockville, MO. 20848 Peers FREE 30-DAY TRIAL COUPON 4 J Socy Mane: ce | J Vittt Ma Roaa | P.O. Box 727 | Rocnvite, MO. 20848-0727 1 J Yes: twamt a totaty cute bogy. Seng me Bory i Maker nght sway! Money back guaranies. Hi I t $12 for Bocy Maker and tree Donus 1 i i q i q i Bei, State 20, I i PERSONAL BODY GOALS FORM ff [[ Answer only it you want to} | wangn Pounds, I WANT Io weigh, a I These are Ine Gans of my body | want lochange = 2 H (Check as many as you want) ca | I O Face DD Arms O Hs g 2 © Neck O Wan © Trgns a HO cress © Bun O tegs g I Decision and Order 121 F.T.C.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents having been furnished thereafter with a copy of a draft of complaint which the Bureau of Consumer Protection proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondents with violation of the Federal Trade Commission Act; and The respondents, their attorney, and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondents 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 respondents that the law has been violated as alleged in such complaint, or that the facts as alleged in such complaint, other than jurisdictional facts, are true 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 the respondents have violated the said Act, and that a 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, and having duly considered the comments received, 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:

1. Respondent WLAR Co. is a corporation organized, existing, and doing business under and by virtue of the laws of the State of Delaware, with its office and principal place of business located at 5622 Columbia Pike #106, in the City of Falls Church, State of Virginia.

Respondent Michael K. Craig is or was at relevant times herein the sole owner, officer, and employee of said corporation. Individually or in concert with others, he participated in and/or formulated, directed, and controlled the acts and practices of said corporation and his address is the same as that of said corporation. WLAR CO., ET AL. 113 98 Decision and Order 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

ORDER For purposes of this order:

1. "Clearly and prominently" shall mean as follows: (a) In a television or videotape advertisement, the disclosure shall be presented simultaneously in both the audio and video portions of the advertisement. The audio disclosure shall be delivered in a volume and cadence and for a duration sufficient for an ordinary consumer to hear and comprehend it. The video disclosure shall be of a size and shade, and shall appear on the screen for a duration, sufficient for an ordinary consumer to read and comprehend it. (b) In a print advertisement, the disclosure shall be in close proximity to the representation that triggers the disclosure and given in at least twelve (12) point type. (c) In a radio advertisement, the disclosure shall be delivered in a volume and cadence sufficient for an ordinary consumer to hear and comprehend it.

2. "Competent and reliable scientific evidence" shall mean tests, analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area, that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.

3. "Weight-loss product" shall mean any product or program designed or used to prevent weight gain or to produce weight loss, reduction or elimination of fat, slimming, or caloric deficit in a user of the product or program.

It is ordered, That respondents, WLAR Co., a corporation, its successors and assigns, and its officers; and Michael K. Craig, individually and as an officer of WLAR Co.; and respondents’ agents, Decision and Order 121 F.T.C.

representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the manufacturing, advertising, packaging, labeling, promotion, offering for sale, sale, or distribution of Swedish 19, Swedish System, BM Program, New Shape, Body Maker, or any substantially similar product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication, that: A. Such product is new or is a new weight-loss discovery; or B. Such product does not require dieting. IL.

It is further ordered, That respondents, WLAR Co., a corporation, its successors and assigns, and its officers; and Michael K. Craig, individually and as an officer of WLAR Co.; and respondents’ agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the manufacturing, advertising, packaging, labeling, promotion, offering for sale, sale, or distribution of any weight-loss product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication, that: A. Such product causes fast or easy weight loss; B. Such product is more effective than other products or programs in controlling appetite or causing weight loss; C. Purchasers of such products are successful in controlling appetite, losing weight, or reducing body fat; D. Such product causes users to develop a new set of eating habits, thereby reducing caloric intake and causing significant and long-term or permanent weight loss; or E. Such product has any effect on users' weight, body size or shape, body measurements, or appetite, unless, at the time of making such representation, respondents possess and rely upon competent and reliable scientific evidence that substantiates the representation. WLAR CO., ET AL. 115 98 Decision and Order OY.

It is further ordered, That respondents, WLAR Co., a corporation, its successors and assigns, and its officers; and Michael K. Craig, individually and as an officer of WLAR Co.; and respondents’ agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the manufacturing, advertising, packaging, labeling, promotion, offering for sale, sale, or distribution of any weight-loss product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication, that such product has been used successfully by any number of persons unless, at the time of making such representation, respondents possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates the representation.

IV.

Nothing in Parts I through III of this order shall prohibit respondents from making representations which promote the sale of books and other publications, provided that, the advertising only purports to express the opinion of the author or to quote the contents of the publication; the advertising discloses the source of the statements quoted or derived from the contents of the publication; and the advertising discloses the author to be the source of the opinions expressed about the publication. This Part shall not apply, however, if the publication or its advertising is used to promote the sale of some other product as part of a commercial scheme. V.

It is further ordered, That respondents, WLAR Co., a corporation, its successors and assigns, and its officers; and Michael K. Craig, individually and as an officer of WLAR Co.; and respondents' agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the manufacturing, advertising, packaging, labeling, promotion, offering for sale, sale, or distribution of Swedish 19, Swedish System, Decision and Order 121 F.T.C.

BM Program, New Shape, Body Maker, or any substantially similar product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from making any representation, in any manner, directly or by implication, that any such product has any effect on weight or body size, unless respondents disclose, clearly and prominently, and in close proximity to such representation, that such product consists solely of a booklet or pamphlet containing information and advice on weight loss. VI.

It is further ordered, That respondents, WLAR Co., a corporation, its successors and assigns, and its officers; and Michael K. Craig, individually and as an officer of WLAR Co.; and respondents’ agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the manufacturing, advertising, packaging, labeling, promotion, offering for sale, sale, or distribution of any weight-loss product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from making any representation, in any manner, directly or by implication, that any such weight-loss product has any effect on weight or body size, unless they disclose, clearly and prominently, and in close proximity to such representation, that diet and/or increasing exercise is required to lose weight; provided however, that this disclosure shall not be required if respondents possess and rely upon competent and reliable scientific evidence demonstrating that the weight-loss product is effective without either dieting or increasing exercise. VIL.

It is further ordered, That respondent, WLAR Co., shall: A. Within thirty (30) days after service of this order, provide a copy of this order to each of respondent's current principals, officers, directors, and managers, and to all personnel, agents, and representatives having sales, advertising, or policy responsibility with respect to the subject matter of this order; and B. For a period of five (5) years from the date of issuance of this order, provide a copy of this order to each of respondent's future WLAR CO., ET AL. 117 98 Decision and Order principals, officers, directors, and managers, and to all personnel, agents, and representatives having sales, advertising, or policy responsibility with respect to the subject matter of this order who are associated with respondent or any subsidiary, successor, or assign, within three (3) days after the person assumes his or her responsibilities.

VIII.

It is further ordered, That for five (5) years after the last date of dissemination of any representation covered by this order, respondents, or their successors and assigns, shall maintain and upon request make available to the Federal Trade Commission or its staff for inspection and copying:

A. All materials that were relied upon in disseminating such representation; and B. All tests, reports, studies, surveys, demonstrations or other evidence in their possession or control that contradict, qualify, or call into question such representation, or the basis relied upon for such representation, including complaints from consumers. IX.

It is further ordered, That respondent, WLAR Co., shall notify the Federal Trade Commission at least thirty (30) days prior to any proposed change in its corporate structure, including but not limited to dissolution, assignment, or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries or affiliates, the planned filing of a bankruptcy petition, or any other corporate change that may affect compliance obligations arising out of this order.

X.

It is further ordered, That respondent, Michael K. Craig, shall, for a period of three (3) years from the date of issuance of this order, notify the Commission within thirty (30) days of the discontinuance of his present business or employment and of his affiliation with any new business or employment involving the advertising, offering for Decision and Order 121 F.T.C.

sale, sale, or distribution of any weight-loss product. Each notice of affiliation with any new business or employment shall include respondent's new business address and telephone number, current home address, and a statement describing the nature of the business or employment and his duties and responsibilities. XI.

This order will terminate on February 21, 2016, or twenty years from the most recent date that the United States or the Federal Trade Commission files a complaint (with or without an accompanying consent decree) in federal court alleging any violation of the order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of: A. Any paragraph in this order that terminates in less than twenty years; .

B. This order's application to any respondent that is not named as a defendant in such complaint; and C. This order if such complaint is filed after the order has terminated pursuant to this paragraph. Provided further, that if such complaint is dismissed or-a federal court rules that the respondent did not violate any provision of the order, and the dismissal or ruling is either not appealed or upheld on appeal, than the order will terminate according to this paragraph as though the complaint was never filed, except that the order will not terminate between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

XII.

It is further ordered, That respondents shall, within sixty (60) days after service of this order, and at such other times as the Federal Trade Commission may require, file with the Commission a report, in writing, setting forth in detail the manner and form in which they have complied with this order.

Chairman Pitofsky recused.

GOOD NEWS PRODUCTS, INC. 119 119 Complaint