Amoco Oil Company

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IN THE MATTER OF AMOCO OIL COMPANY CONSENT ORDER, ETC., INREGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3655. Complaint, May 7, 1996--Decision, May 7, 1996 This consent order requires, among other things, the Chicago-based corporation to possess competent and reliable scientific evidence to substantiate claims regarding the environmental benefits, engine performance, power, acceleration, or engine cleaning ability of any gasoline. Appearances For the Commission: Michael Dershowitz and Sidney N. Knight. For the respondent: Elroy H. Wolff, Sidley & Austin, Washington, D.C. and James M. Amend, Kirkland & Ellis, Chicago, IL. COMPLAINT The Federal Trade Commission, having reason to believe that Amoco Oil Company, a corporation, hereinafter sometimes referred to as respondent, has violated the provisions of 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 Amoco Oil Company is a Maryland corporation, with its offices and principal place of business located at 200 East Randolph Drive, Chicago, Illinois. PAR. 2. Respondent Amoco Oil Company has advertised, offered for sale, sold, and distributed gasoline and other petroleum products including Amoco Silver 89 octane gasoline, and Amoco Ultimate 92 and 93 octane gasolines.

PAR. 3. The acts and practices of respondent 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. Respondent has disseminated or caused to be disseminated advertisements for Amoco Silver and Amoco Ultimate Complaint 121 F.T.C.

gasolines, including but not necessarily limited to the advertisements attached hereto as Exhibits A through I. The aforesaid advertisements contain the following statements and depictions: A. A television advertisement for Amoco Ultimate: Announcer: What's clear? Crystal clear Amoco Ultimate. [Video: Depiction of clear liquid being poured] What isn't? All other premium gasolines. [Video: Depiction of colored liquids in laboratory flasks] What's clear? Amoco Ultimate is the only premium refined an extra step to remove harmful impurities. Harmful impurities you, as a premium user, don't want. {Video: Depiction of laboratory flask containing a dark colored viscous liquid] {Super #1: PNA Impurities Simulated] {Super #2: Based On Reduction In Hydrocarbon Exhaust Emissions From Extra Refining Step.] What's clear? Why we do it? For unsurpassed performance and a cleaner environment. Crystal clear. Crystal clear Amoco Ultimate.

[Exhibit A] Superscript #1 appears on the screen for approximately 1.5 seconds. Superscript #2 appears on the screen for approximately 2.5 seconds. B. A television advertisement for Amoco Ultimate: Announcer: What's clear? Crystal clear Amoco Ultimate. [Video: Depiction of clear liquid being poured] What isn't? All other premium gasolines. [Video: Depiction of colored liquids in, laboratory flasks] What's clear? Amoco Ultimate is the only premium refined an extra step to remove harmful impurities other premiums leave in. Impurities that can rob your engine of performance and pollute the air.

[Video: Depiction of laboratory flask containing a dark colored viscous liquid] [Super: Based On Reduction In Hydrocarbon Exhaust Emissions From Extra Refining Step. PNA Impurities Simulated] What's Clear? If you use premium, now you have a reason to switch. Crystal clear. Crystal Clear Amoco Ultimate.

{Exhibit B] Superscript appears on the screen for approximately 2.5 seconds. C. A television advertisement for Amoco Silver: Announcer: Hop into Amoco and take the Silver one tank test. (Video: Depiction of dirty rabbit on top of full gas gauge] Fill up with one Tankful of Amoco Silver; it'll clean up the filthiest fuel injectors. Not five tankfuls. Not three tankfuls. New and improved Amoco Silver with even more cleaning power does it in just one tankful or your money back. {Video: Depiction of dirty rabbit becoming clean as fuel gauge goes to empty] So take the Silver One Tank Test and bring back the acceleration. Bring back the power.

AMOCO OIL COMPANY 563 561 Complaint (Super: For your purchase of one tankful of Amoco Silver. Eight Gallon Minimum. See your Amoco dealer for details.] Video tagline: BRING BACK THE POWER [Exhibit C] D. A television advertisement for Amoco Ultimate: Announcer: It's your car. Your baby. Your one and only. Everything about it has to be as good as gold. And when you're runnin’ on Amoco Ultimate, you're running clean. Amoco Ultimate is refined an extra step for quality. And like all Amoco gasolines, Ultimate cleans clogged fuel injectors in one tankful. To keep your entire fuel intake system running clean. {Exhibit D] E. A radio advertisement for Amoco Silver: Bert: Can I help you sir? Guy: I'm here to take your test Bert: Oh, our Amoco Silver One-Tank-Test. * * * Eo Bert: Sir, sir, you want an empty gas tank so you can fill-up with Amoco Silver. Guy: I guess now's as good a time as any to take the test. * * * * Bert: Look, just one tankful of new and improved Amoco Silver... Guy: Yes? Bert: ... can help solve dirty-engine problems. Guy: Solve engine problems? Oh no, science. Bert: Now with even more cleaning power... Guy: Ooh.

Bert: ... Amoco Silver cleans your fuel injectors as simple as A-B-C. Guy: A-B-C! I always pick "D" -- all of the above. Bert: Amoco Silver cleans fuel injectors in one tankful, not five or three like some gasolines.

Guy: Wow.

Bert: Or Amoco pays you back for your purchase. * * * * [Exhibit E] F. A radio advertisement for Amoco Ultimate: * * * * Engine: ... I'm a dirty little engine. OK? There I admit it! Woman: And you want to clean up your act. Engine: Well that's where you come in.

Woman: Me? (TO A GUEST) Be right with you! Now, what is it? Engine: Just give me Amoco Ultimate Woman: Change gasolines? Engine: Exactly. One fill-up of Amoco Ultimate will clean up my clogged fuel injectors just like that. And I won't run as sluggish as I do now. Woman: Well, there is something to be said for clean living. Engine Then give me the good stuff! Woman: Listen to your engine. Not only does Amoco Ultimate clean clogged fuel injectors in one tankful, it keeps your entire fuel intake system running clean. * * * * {Exhibit F] Complaint 121 F.T.C.

G. A television advertisement for Amoco Silver: Announcer: Ever since Ed got his new car, Streaker the dog next door, has been racing him down the road. Regular unleaded gasoline was all Ed needed to teach this dog a few tricks.

[Video: Depiction of dog chasing a new car with the car ahead of the dog] But around 15,000 miles, a car can start to lose acceleration. ‘Cause regular unleaded gasoline may not be enough. [Video: Depiction of odometer approaching 15,000 miles as car begins to slow down and dog catches up and passes car] Now's the time to turn to Silver. Higher octane Amoco Silver can bring back the acceleration. Bring back the power [Exhibit G] H. A radio advertisement for Amoco Silver: Announcer: Remember what happened when you pressed on the accelerator when your car was new? Remember? It ran like the wind! Charged like a champ! Even on regular unleaded gasoline. But as you put on the miles, your engine's appetite for octane can grow. Your car can begin to act sluggish. Unresponsive. And sooner than you think, as early as 15,000 miles, your car can begin to lose acceleration. Regular unleaded may not be enough. That's the time to turn to Silver! Amoco Silver is a step up from pure regular unleaded gasoline. Its higher octane can bring back the power that was there when your car was brand new. Amoco Silver may be all you'll ever need to keep your car's engine running the way it was designed to run. Amoco Silver. Bring back the power.

{Exhibit H] I. A print advertisement for Amoco Silver: AROUND 15,000 MILES, YOU'RE BOUND TO LOSE SOMETHING.

FORTUNATELY, CARS DON'T HAVE HAIR.

As we rack up the miles, most of us start to feel sluggish. We slow down. Hair Starts to thin. With the exception of this last point, the same may be true of your car. In fact, after 15,000 miles or so, some cars may actually sustain a loss of power if they run on regular gasoline. At this point, you're ready for Silver. Higher octane Amoco Silver gasoline can bring back the acceleration, bring back the power. And while we can't do a thing for thinning hair, we can provide the fuel to properly blow it back.

YOU EXPECT MORE FROM A LEADER.

SILVER. BRING BACK THE POWER.

{Exhibit I] PAR. 5. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A through I, respondent has represented, directly or by implication, that:

AMOCO OIL COMPANY 565 561 Complaint A. Amoco Ultimate gasoline is superior to all other brands of premium gasoline with respect to engine performance and environmental benefits because it is refined more than all other such brands.

B. The clear color of Amoco Ultimate gasoline demonstrates the superior engine performance and environmental benefits Amoco Ultimate provides compared to other premium brands of gasolines that are not clear in color.

C. A single tankful of Amoco Silver or Amoco Ultimate gasoline will make dirty or clogged fuel injectors clean. D. Amoco Silver or Amoco Ultimate gasoline provides superior fuel injector cleaning compared to other brands of gasolines. E. Automobiles driven more than 15,000 miles with regular gasoline generally suffer from lost engine power or acceleration which will be restored by the higher octane of Amoco Silver gasoline.

PAR. 6. 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 I, respondent has represented, directly or by implication, that at the time it made the representations set forth in paragraph five, respondent possessed and relied upon a reasonable basis that substantiated such representations.

PAR. 7. In truth and in fact, at the time it made the representations set forth in paragraph five, respondent did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, the representation set forth in paragraph six was, and is, false and misleading.

PAR. 8. The acts and practices of respondent 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.

Commissioner Starek recused.

Complaint 121 F.T.C.

EXHIBIT A TITLE: "BOY FLYING KITE"

PROGRAM: WORLD NEWS 9/04/92 30 TV R REPORTS STATION: ABC [NEW YORK) 6:59PM 4) East 42nd Street, New York, NY 10017 (212) 309-1400 RADIO PRODUCT: AMOCO ULTIMATE GASOUNE EXHIBIT A All other premium gasotines. What's clear? Amoco Ultimate is the only premium to remove harmful impurities. Harmful impurities you, as a premium user, don't want.

You Esptet More From A Leah What's clear? Why do we do it? For unsurpassed performance and Crystal clear Amoco Ultimate. a cleaner environment. Crystal (MUSIC OUT) clear.

ALSO AVAILABLE IN COLOR VIDEO-TAPE CASSETTE AMOCO OIL COMPANY 567 561 Complaint EXHIBIT B RADIO PRODUCT: AMOCO ULTIMATE GASOLINE EXHIBIT B TME: "WHAT'S CLEAR?"

9/04/92 :30 TV REPORTS “STATON Ga INEWYOR —7:270m 41 East 42nd Street, New York, NY 10017 (212) 309-1400 Crystal clear Amoco Uitimate.

What isn't? What's clear? Amoco Ultimate is the only refined an extra step to remove premium harmful impurities other premiums leave in. of performance and pollute the air. What's clear? If you use premium, now you have a reason to switch. Crystal clear Amoco Ultimate. Crystal clear. {MUSIC OUT) a ALSO AVAILABLE IN COLOR VIDEO-TAPE CASSETTE Complaint 121 F.T.C.

EXHIBIT C TITLE: “TANK TEST"

TVREPORTS PROGRAM: NEWS 05/22/91 :30 STATION: | WXYZ (DETROIT) 6:36PM RADIO - PRODUCT: AMOCO SILVER GASOLINE EXHIBIT C 4} East 42nd Street Naw York, NY 10017 (212) 309-1400 SMM Le ERE (MUSIC) ANNCR: Hop into Fill up with one tankful of itl clean up the filthiest fuel Amoco and take the Silver One Amoco Silver; injectors. Tank Test.

Not five tankfuls not three New and improved Amoco Silver does it in just one tankful tankfuls. with even more cleaning power or your money back. So take the Silver One Tank Test Bring back the power. (MUSIC and bring back the acceleration. OUT) PIE PVEIE SRIF IN COLOD VIDEO.TAOF CASSETTE AMOCO OIL COMPANY 569 561 Complaint DMB&B EXHIBIT D TELEVISION CONTINUITY EXHIBIT D Awsce O31 co.

Gasoline “Runnin' Clean/East/NY"

130 SNAA 3163 3/25/92 Rev. 3 JS:mo AO2P002 AORCENY video WS BEACH W/WOMAN AT SUNSET MS WOMAN SITTING BY PONTIAC WOMAN DRIVING PONTIAC MAN WIPING STEERING WHEEL WS MAN W/PICK UP TRUCK WOMAN DRIVING CAR (& HOOD) MOM & BALLERINAS (WS) CU ULTIMATF SIGNAGE CAR ON ROAD (POREST) CU ULTIMATE SIGNAGE & PUMP (POMP DECAL: REFINED AN EXTRA STEP) WOMAN DEALER FILLING CAR CU WOMAN DEALER CU ULTIMATE SIGNAGE CU WOMAN'S FACE SMILING WS CAR DRIVING CU WOMAN DRIVING CU WOMAN SMILING POV OF ROAD ZOOM/CU ULTIMATE SIGNAGE OMAN ON BEACH W/SUPER (SUPER: YOU EXPECT MORE FROM A LEADER) CHORUS:

CHORUS:

AUDIO YOU'RE JUST AS GOOD AS GOLD Your baby.

It's your car.

Your one and only.

Everything about it has to be as good as gold. And when you're runnin' on Amoco Ultimate, you're running clean. Amoco Ultimate is refined an extra step for quality. And like all Amocc gasolines, Ultimate cleans:

clogged fuel injectors in one tankful.

entire fue] intake systen To keep your running clean.

YOU'RE JUST AS GOOD AS GOLD (FADE OUT) DMB&B AS_PRODUCED Complaint 121 F.T.C.

EXHIBIT E LAA LL one Tank Test co RA-238S-e0 = Rey oS:kG OLRI74 RADIO CONTINUITY AONOTT BERT:

SUY:

BERT:

SERT:

SUY:

SERT:

STATION DING DING I help you, sir? cake your test.

Silver Gne-Tank-Test.

live taken every test tnere is...

it's mot that kind cf test.

Got my number 2 pencils. i-ring binder is your tank empty? mommy always said have a o:¢ creakfast before a test Do ohac asn-crowns, pancakes...

gir Ou want an so AMCCS ver.

I guess now's as good a time as any to take the test. well, that's true.

“rue? It's true/false. Good. That means I got a 20/20 chance. Look, lust one tankful of new and smproved Amoco Silver... ‘fes? ..can help sclve dirty-engine crobiems. ive engine problems? ch more <Ilean even S as simple as A- AMOCO OIL COMPANY 571 Complaint EXHIBITE AS_PRODUCED c$:bd AOLR374 RADIO CONTINUITY AONOTT 3UY:

BERT:

A-Bi always pick "2D" -- aii of the above. ameco Silver cleans fuel injectors :n one tankful, not five or three Like some gasoicnes.

Wow.

Dr Amocc pays you bacx for your purchase. So, .t'§ mot TruesFaise.

Nc.

or tustic.g oneice No.

ch, not What? Essay! Let me use your pen.

That's my tire-gauge, Sir.

well, let me use 1c anyway.

take the cne-tank-test by fiiiing up with 8 gallons or more of engine-cleaning Amoco Silver.

ye) AS UCE:

Complaint 121 F.T.C.

EXHIBIT F EXHIBII Amoco Oi} Cc.

Ultimate c “The Party"

760 RA-053-60 5/9/91 Rev. 6 PB:bd AO1R378 RADIO CONTINUITY AOTP SPX:

ENGINE:

WOMAN:

PAGINE:

WOMAN:

ENGINE:

WOMAN:

ENGINE:

WOMAN:

ENGINE:

SFX:

ENGINE:

WOMAN:

ENGINE:

SMALL GATHERING, VOICES IN BACKGROUND Pardon me. Coming through.

You are one unbelievable engine! You climb out from under the hood and walk right into my party because you want to talk? That's right. But I'm not sure...oh what the heck? I'm a dirty little engine. OK? There I admit it! And you want to clean up your act.

Well that's where you come in.

Me? (TO A GUEST) Be right with you! Now, what is it? Just give me Amoco Ultimate.

Change gasolines? Exactly. One fill-up of Amoco Ultimate will clean up By cloggec fuel injectors just like that.

SNAPS FINGERS And I won't run as sluggish as I do now. Well, there is something to be said for clean living. Then give me the good stuff! Listen to your engine. Not only does Amoco Ultimate clean clogged fuel injectors in one tankful, it keeps your entire fue intake system running clean.

AMOCO OIL COMPANY 573 561 Complaint EXHIBIT F Amoco Oil Co.

Ultimate ae DMB&B "The Party"

7:60 RA-053-60 Du 4 5/9/91 Rev. 6 PB:bd AO1R378 RADIO CONTINUITY AOTP ENGINE: (To party guest) Hey, buddy. You hear the one about the fan belt and the radia...

WOMAN : Hey! I thought you wanted to clean up your act! PNGINE: Oh, right. Sorry.

BOWMAN: Amoco Ultimate. Your car knows. Complaint EXHIBIT G AS PRODUCED 7:2.

DMB&B TELEVISION CONTINUITY AMOCO Uli US EXHIBIT G Siver Gasoune “Odometer:Streaker/Long Copy Rev."

130 AOQ2T516 7122/92 SNAA 3323 AOOSLCR VIDEO MAN DRIVING CAR - DOG CHASING CAR ANNCR: CAR WAY AHEAD OF DOG DOG CATCHES UP TO CAR AND PASSES C.

ODOMETER TURNS TO SILVER LETTERS CUT TO CU OF AMOCO SILVER PUMP CAR ACCELERATES WITH DOG IN CAR SFX:

SUPSR: YOU EXPECT MORE FROM A LEADER AUDIO Ever since Ed got his new car, Streaker the dog next door, has be tracing him down the road. Regular unleaded gasoline was all Ed neeck to teach this dog a few tricks. But around 15,000 miles, a car can star to lose acceleration. ‘Cause reguia unleaded gasoline may not be enough. Now's the time to tum to Silver. Higher Octane Amoco Silver can bring back the acceieration.

Bring back the power.

ROG BARK AMOCO OIL COMPANY 575 561 Complaint EXHIBIT H EAHIBIT H silver “Silver Syrphenyv/Non-New"

AOSR254 RA $56-60 REVISED 3/14/91 3/14/91 RADIO CONTINUITY the accelerator when ANNCR: Remember what happened when you pressed on your car was new? Remember? MUSIC: POWERFUL SYMPHONY {TCHAIKOVSKY It ran like the wind! Charged like a champ! Even cn regular unleaded gasoline.

MUSIC: SEGUES...

But as you »ut on the miies, your engine's appetite for octane can grow.

MUSIC: TSA OND SYMPHONY SLOWER iti PACE Your car can tegin to act sluggish.

Vnresponsive.

MUSII: = ang sconer than you think, MSSIC: To & ORD SYMPHONY, GLOOM AND DoOM as early as 15,000 miles, your car can begin to lose acceleration. Regular unleaded may not be enough. MUSIC: SEGUES..

Tnat's the time...

MESic It WILLIAM TELL OVEPTUPE Tao tern tc lliver! Complaint 121 F.T.C.

EXHIBIT I “"S:lver Symphony/Non kew"

aaKnten 3/12/90 160 3/14/91 AOR254 RA 956-60 RADIO CONTINUITY Amoco Silver is a step up from pure regular unleaded gasoline. ANNCR:

Its higher octane can bring back the power that was there when your car was brand new.

Amoco Silver may be all you'll ever need to keep your car's engine running the way it was designed to run. MUSic: W AM TELL REACHES CLIMAX Amoco Silver. Bring back the power.

AMOCO OIL COMPANY 577 561 Complaint EXHIBIT I EXHIBIT 1 CORY a ene VROU NEY bo NEEDS YOU CRE BOW NEY POE Ost SOONTE PELENG.

POREE NAEEEY © OVERS PONTE EE WE EE NEEDS As we rack up the miles. most of us start 19 feel sluggish We slow down Hair starts to thin With the exception of this last point. the same mav be true of vour car (n fact. alter 15.000 miles or so some cars may actually sustain a toss of power if they run on regular gasoline Ar this point. vou re teadv for Silver. Higher octane Amoco Sulver® gasoline can bning back the acceleranon. bnng back the power And while we cant do a thing for thinning hair. we can provide the fuel to properly blow it hack. & You Expect More From A Leader 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 respondent named in the caption hereof, and the respondent 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 the respondent with violation of the Federal Trade Commission Act; and The respondent, its attorney, 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 complaint, a statement that the signing of the agreement is for settlement purposes only and does not constitute an admission by respondent 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 respondent has violated the Act, 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 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: 1. Respondent Amoco Oil Company, Inc. is a corporation organized, existing, and doing business under and by virtue of the laws of the State of Maryland with its offices and principal place of business located at 200 East Randolph Drive, Chicago, Illinois. 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is in the public interest.

AMOCO OIL COMPANY 579 561 Decision and Order ORDER It is ordered, That respondent Amoco Oil Company, a corporation, its successors and assigns, and its officers, representatives, agents and employees, directly or through any corporation, subsidiary, division or other device, in connection with the advertising, labeling, offering for sale, sale or distribution of Amoco Silver 89 octane gasoline, Amoco Ultimate 92 or 93 octane gasoline, or any other gasoline 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: (A) Amoco Ultimate gasoline is superior to all other brands of premium gasoline with respect to engine performance or environmental benefits because it is refined more than all other such brands;

(B) The clear color of Amoco Ultimate gasoline demonstrates the superior engine performance or environmental benefits Amoco Ultimate provides compared to other premium brands of gasolines that are not clear in color;

(C) A single tankful of Amoco Silver or Ultimate gasoline will make dirty or clogged fuel injectors clean; (D) Amoco Silver or Ultimate gasoline provides superior fuel injector cleaning compared to other brands of gasoline; (E) Automobiles driven more than 15,000 miles with regular gasoline generally suffer from lost engine power or acceleration which will be restored by the higher octane of Amoco Silver gasoline; or (F) Concerns the relative or absolute attributes of any gasoline with respect to environmental benefits or with respect to engine performance, power, acceleration, or engine cleaning ability, unless, at the time of making such representation, respondent possesses and relies upon competent and reliable scientific evidence that substantiates the representation. For purposes of this order, “competent and reliable scientific evidence" shall mean tests, analyses, research, studies, or other evidence based upon the 580 ‘ FEDERAL TRADE COMMISSION DECISIONS Decision and Order 121 F.T.C.

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.

For purposes of this Part, any representation, directly or by implication, that any gasoline will clean or clean up fuel injectors to a level that engine performance is not adversely affected will be deemed to be substantiated if respondent possesses and relies upon competent and reliable testing demonstrating that the flow rate of each fuel injector was returned to at least 95 percent of its original value.

Provided that, nothing in this order shall prohibit respondent from truthfully representing the numerical octane rating of any gasoline. II.

It is further ordered, That respondent Amoco Oil Company, shall within thirty (30) days after service distribute a copy of this order to all operating divisions, subsidiaries, officers, managerial employees, and all of its employees or agents engaged in the preparation and placement of advertisements or promotional sales materials covered by this order and shall obtain from each such employee a signed statement acknowledging receipt of the order. TI.

It is further ordered, That for three (3) years after the last date of dissemination of any representation covered by this order, respondent Amoco Oil Company or its successors or 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 to substantiate any representation covered by this order; and B. All tests, reports, studies or surveys, in respondent's possession or control that contradict any representation covered by this order. AMOCO OIL COMPANY 581 561 Decision and Order IV.

It is further ordered, That respondent Amoco Oil Company shall notify the Commission at least thirty (30) days prior to the effective date of any proposed change in the corporation that may affect compliance obligations under this order such as a dissolution, assignment or sale resulting in the emergence of a successor corporation(s), the creation or dissolution of subsidiaries or any other change in the corporation.

V.

It is further ordered, That this order will terminate on May 7, 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, then 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.

VI.

It is further ordered, That respondent Amoco Oil Company shall, within sixty (60) days after service of this order upon it, and at such other times as the Commission may require, file with the Commission Decision and Order 121 F.T.C.

a report, in writing, setting forth in detail the manner and form in which it has complied with this order.

Commissioner Starek recused.

LITTON INDUSTRIES, INC. 583 583 Complaint