1554 Corporation

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

Complaint 123 F.T.C.

IN THE MATTER OF

1554 CORPORATION, ET AL.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT

Docket C-3733. Complaint, April 14, 1997--Decision, April 14, 1997

This consent order prohibits, among other things, the California company, doing business as The Mellinger Company, and its president from making any unsubstantiated success, profitability, performance, benefits, efficacy or success rate claims with regard to a business opportunity product or service. The consent order also prohibits the respondents from using testimonials or endorsements that make deceptive or unsubstantiated representations.

Appearances

For the Commission: Justin Dingfelder, Lemuel Dowdy and Jonathan Cowen.

For the respondents: Shirley Johnson, Washington, D.C.

COMPLAINT

The Federal Trade Commission, having reason to believe that 1554 Corporation, a corporation, and Brainerd L. Mellinger, III, individually as an officer of 1554 Corporation ("respondents"), have 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 1554 Corporation is a California corporation, with its office and principal place of business located at 6100 Variel Ave., Woodland Hills, CA. Respondent 1554 Corporation has traded and done business as The Mellinger Company.

Respondent Brainerd L. Mellinger, III, is president of the corporate respondent. Individually, or in concert with others, he formulates, directs and controls the acts and practices of the corporate respondent, including the acts and practices alleged in this complaint. His principal office or place of business is the same as that of the corporate respondent.

PAR. 2. Respondents have, individually or in concert with others, created and disseminated advertisements for the Mellinger World Trade Mail Order Plan ("Mellinger Plan"), and have offered for sale

1554 CORPORATION, ET AL. 1109

1108 Complaint

and sold the Mellinger Plan to consumers who respond to their advertisements.

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' advertisements for the Mellinger World Trade Mail Order Plan include, but are not necessarily limited to, the attached Exhibits A-D. These advertisements contain the following statements:

A. A program-length television advertisement for the Mellinger Plan, identified as "Mellinger's Secret Treasures" (Exhibit A):

(1) Announcer: "How would you like to earn substantial income right from the comfort of your own home? . . . Living a luxurious lifestyle with long-term security for you and your family." (P. A1)

(2) Endorser: "Doesn't matter what age, what your background is, what your education is. The sooner you get started, the sooner you start making money." (P. A2)

(3) Host: "His name is Brainerd Mellinger III, and he makes it easier than ever for people to make riches they've only dreamed of." (P. A3)

(4) Endorser: "On my first customer my first day with the World Traders I made twelve thousand dollar profit." (P. A4)

(5) Host: "Brainerd, these folks are making a lot of money, and enjoying every minute of it." (P. A13)

(6) Brainerd Mellinger, III: "If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now." (P. A17)

(7) Endorser: "You will be successful. It's been proven time and time again." (P. A17)

(8) Endorser: "I started off with $250 that my husband gave me, and last year I earned over $35,000, and I did it all with the help of the Mellinger Company." (P. A21)

(9) Endorser: "Get involved with Mellinger, and if you stick with them they have the support team there for you, they can make something like this possible for you." (P. A23)

(10) Endorser: "Anybody today that really wants to work, and has the initiative to get out and try something new, this plan definitely makes it about as easy as pie." (P. A25)

(11) Announcer: "Kirk may not be a rocket scientist, but with the help of the Mellinger World Trade Plan he has launched a company with sky-rocketing profits. Today is a typical business day, and Kirk is shipping out more than 400 hats. The profits are all his." (P. A36)

(12) Endorser: "[A]nyone that gets involved with this is gonna really find [it] exciting, interesting, and create an income for themselves. It's fantastic." (P. A38)

(13) Host: "The Mellinger Plan makes it so easy to achieve financial independence. Why isn't everyone doing it?" (P. A42) Brainerd Mellinger, III: "Good question. Well -- it's just that they don't know about the Mellinger Plan yet. They aren't aware that this fabulous opportunity for success

Complaint 123 F.T.C.

and riches is waiting for them. And that's why I'm here today. I want to tell everyone that they can make money, like some of the folks you've seen on our show. The Mellinger company shows you how, step by step. And we make it simple and fun . . . ." (P. A43) B. A magazine advertisement for the Mellinger Plan (Exhibit B): 2 valuable New Reports Can Make You Rich! I'll send both to you FREE! You've seen me on T.V.! Now I'm ready to help you get a fast start! Discover How to Be Independent -- Be Your Own Boss -- Make Big Money in your own IMPORT/EXPORT MAIL ORDER BUSINESS! . . . Enjoy earnings probably far greater than you ever dreamed any job could pay. * * * Join these successful Men and Women! . . . "Mellinger has the answers! I'm looking at $25,000. year's income -- just 2 hours a day part-time." [endorser] "Just one world trade transaction paid me $5,000 profit! Yes...follow the Mellinger Plan!" [endorser] C. Mellinger Internet site (http://www.tradezone.com) (Exhibit C): SUCCESSFUL INTERNATIONAL TRADERS MEMBERS[.] HOW PLAN BROUGHT SUCCESS TO THEM! . . . Having trouble sleeping one night, [endorser] turned on his TV and became enthralled by a Mellinger infomercial. A phone call brought him full details about the Mellinger Plan. "I was so impressed with what I saw, I immediately began following the Mellinger Plan and became a Member of International Traders. I began putting the Plan into practice and started showing Import products. In less than two months, I had generated well over $2,000 in business." . . . The Mellinger Plan provided exactly what [endorser] needed. . . ."I would tell you this works for you. It's very good for beginners like myself." She reported sales of $1200. right away and with her early momentum she says she is looking now at earnings of $6000. a month! D. A pamphlet mailed to consumers who request information about the Mellinger Plan (Exhibit D):

START AT HOME...make money your very first day! * * * MEN & WOMEN--Welcome to your exciting, high-income, full-or part-time future in Import/Export/Mail Order. Follow the Mellinger Plan as it guides your every step. Nothing has been left to chance. Each easily followed step is based 100% upon many years of successful business experience! * * * SUCCESS STORIES in World Trade! Read these ACTUAL REPORTS of MONEY-MAKING . . . .

Concentrating on imported sports equipment, [endorser] took in $35,000.00 the first year, devoting only a few hours a day.

PAR. 5. Through the use of the statements contained in the advertisements and promotional materials referred to in paragraph four, including but not limited to the advertisements attached as Exhibits A-D, respondents have represented, directly or by implication, that:

1554 CORPORATION, ET AL. 1111

1108 Complaint

A. Consumers who use the Mellinger Plan typically succeed in readily starting and operating profitable businesses; B. Consumers who use the Mellinger Plan typically earn substantial income; and C. Endorsements appearing in Exhibits A-D reflect the typical or ordinary experience of members of the public who have used the Mellinger Plan.

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-D, respondents have represented, directly or by implication, that at the time they made the representations set forth in paragraph five, respondents possessed and relied upon a reasonable basis that substantiated such representations.

PAR. 7. In truth and in fact, at the time they made the representations set forth in paragraph five, respondents 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 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.

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A1 Final On Air Script

DISCLAIMER GRAPHIC

FONT: TESTIMONIALS USED IN THIS PROGRAM REPRESENT BEST CASE RESULTS. RESULTS WILL VARY DEPENDING ON INDIVIDUAL EFFORTS AND PRODUCT SELECTION.

Narrator:

The following program is a paid

advertisement for the Mellinger World

Trade Mail Order Plan, by The Mellinger

Company.

TEASE:

COVER:

CU WOMAN COUNTING MONEY

COUPLE, WORKING AT TABLE IN THEIR KITCHEN

YACHT

Narrator:

How would you like to earn substantial

income right from the comfort of your

own home? Working the hours you

want--part time or full time. Enjoying

the freedom of not having to answer to

a boss.

Living a luxurious lifestyle with

long-term security for you and your

family.

Well, you don't have to discover a

secret treasure to make your dreams

come true. Stay tuned because

we're going to reveal a modern day

treasure...that can put you on the road

to success and happiness. It's a

time-tested formula that's been used by

hundreds of thousands of people all

over the world.

We'll also tell you how you can receive

an exciting potential import absolutely

free just for watching [illegible]

DREAM SHOTS:

MAN TAKING GOLF SWING

FAMILY & DOG IN POOL

ZOOM OUT FROM CU:

SHOT OF TREASURE CHEST OVERFLOWING WITH JEWELS, PEARLS AND GOLD.

DISS. TO SHOT OF TREASURE CHEST OVERFLOWING WITH MELLINGER IMPORTS.

ZOOM IN TO CU.

CU PAN ACROSS CHEST OF IMPORTS.

GRAPHIC

FONT: GET A FREE [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Ex A2 Final On Air Script

Flash FREE TESTIMONIAL Carolyn Kaplan:

FONT:

CAROLYN KAPLAN Doesn't matter what age, what your INTERNATIONAL TRADER background is, what your education is. The sooner you get started, the sooner you start making money.

TESTIMONIAL Roy Hanson:

FONT:

ROY HANSON The Mellinger Company has a plan set INTERNATIONAL TRADER up. Step one, two, three, four, it's, it's so simple.

SHOW TITLE SEQUENCE: Narrator: CU TREASURE CHEST OF It's all next on "Mellinger's Secret IMPORTS Treasures."

INTRO

PAN ACROSS EURASIA MAP Richard V/O: 700 years ago, a brave young merchant, SUPERIMPOSE VARIOUS named Marco Polo PICTURES OF MARCO POLO OVER MAP traveled 15,000 miles to discover the riches of the orient.

PICTURE OF MARCO He came home with exotic treasures and RETURNED HOME W. opened up trade routes that helped TREASURE merchants build untold fortunes.

RICHARD ANDERSON IN Richard: KOWLOON LOCATION Hello I'm Richard Anderson, here in FONT:

RICHARD ANDERSON the famed city of Hong Kong to FILM AND TELEVISION introduce to you a modern day Marco STAR Polo

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 : A3 Final On Air Script

PAN ACROSS HONG KONG SKYLINE

BRAINERD WALKS DOWN A Richard V.O.: LANE OF STANLEY MARKET His name is Brainerd Mellinger the III, and he

COVER OF BRAINERD IN makes it easier than ever for people to STANLEY MARKET STORE, LOOKING AT CLOTHES make riches they've only dreamed of. HANGERS

BRAINERD W/ FAN He goes on global product tours

FONT: searching the world over for sources of HONG KONG STANLEY MARKET exciting, low priced imports.

FONT: Then shows you how to market them from ALL PRICES QUOTED ARE BASED ON QUANTITY your home, at selling prices up to 11 FROM AN OVERSEAS SUPPLIER AND ARE times their cost and more! SUBJECT TO CHANGE AND AVAILABILITY.

BRAINERD AT STANLEY Richard V/O: MARKET FINDING MAGIC RAZOR. Look at what Brainerd's already found!

CU ON MAGIC RAZOR First - a really handy item: The Magic

FONT: Razor. It's great for travel or at BUY FOR....... $1 SELL FOR...... $13 home and sells in leading catalogs for GROSS PROFIT $12 as much as thirteen dollars, but you- FONT: PROFIT MAY VARY DUE TO OPERATING COSTS. pay only a dollar. That's a 12-1

markup.

BRAINERD IN STANLEY Richard V/O: MARKET W/ POTPOURRI SACHETS Then look at these lovely potpourri

CU IN POTPOURRI SACHETS sachets. International Traders members

CU FROM DIFFERENT ANGLE buy these scented closet hangers for

FONT: only sixty five cents per set of two BUY FOR [illegible] RETAIL ?? [illegible] We sell them for $10 a set.

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 P. A4 Final On Air Script GROSS PROFIT $211.95 That's an 18 to 1 markup! FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

TESTIMONIAL Prince Ogunbanwo: FONT:

PRINCE ADEMOLA OGUNBANWO INTERNATIONAL TRADER On my first customer my first day with the World Traders I made twelve thousand dollar profit.

BRAINERD W/ SAMURAI Richard V/O: SWORDS FONT: And finally these detailed replicas of BUY FOR...... $40 SELL ancient Samurai swords. Intriguing FOR...... $175 GROSS PROFIT $135 conversation pieces that people will FONT: PROFIT MAY VARY gladly pay $175 for. But Mr. DUE TO OPERATING COSTS. Mellinger's International Traders members buy these for only $40. That's a $135 gross profit on each set! END OF OPENING MELLINGER SIX - SEGMENT ONE RICHARD IN CHAIRMAN'S Richard: SUITE, GRAND HYATT HONG KONG. You know, we all dream of being wealthy, and I'm here today with Brainerd Mellinger the third, to show you just how to make that dream come true in your own import export mail order business.

PULL OUT TO TWO SHOT Richard to Brainerd FONT:

Complaint 123 F.T.C.

EXHIBIT A

'Mellinger's Buried Treasures' MST-1 Final On Air Script P A5

HONG KONG Well Brainerd, everyone assumes that starting a business is a big risk. What's different about the Mellinger World Trade Mail Order Plan? And why do so many people do so well? Brainerd:

BRAINERD FONT:

BRAINERD L. MELLINGER III, PRESIDENT/C.E.O.

THE MELLINGER COMPANY SHOTS OF 4 GENERATIONS OF MELLINGERS FONT: THE MELLINGERS The main thing is that my family's company has developed and perfected this formula over four generations. And we show you how to start with very little, just like my grandfather did, and make money right from the start. So there's virtually no down side.

BRAINERD & RICHARD You don't need any special business experience or education. We make it simple and fun.

RICHARD Richard:

Okay. So, let's get started. What's the first secret of your Business Success Formula? BRAINERD Brainerd:

FONT: MELLINGER BUSINESS SUCCESS SECRET #1:

SELL PRODUCTS AT HIGH MARKUPS. YOU KEEP ALL THE PROFITS Well, number one is finding really hot products you can mark up for profits You know markup is the key.

RICHARD AND BRAINERD ON STANLEY MARKET

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

'Wallinger's Hidden Treasures' MST-1 p A6 Final On Air Script

Richard:

Which is why we're here in Hong Kong right.

Brainerd:

Exactly.

Hong Kong is just one of the many international markets where my global product scouts find fascinating, low cost products.

Brainerd:

Like this lifelike, plush puppy. Puppy Barks Richard:

It barks when you pet it! Brainerd:

This retails for as much as twenty four dollars, and you only pay $6.50 That's an easy $17.50 profit.

Richard:

That's incredible! Brainerd:

It is incredible! We offer you over 24,000 hand picked, easy-to-sell, quality products to choose from! All this without having to leave your home Plus step by step guidance

ARIEL OF HONG KONG IMPORTS ON TABLE

CU ON PUPPY

RICHARD AND BRAINERD W.

PUPPY FONT:

BUY FOR........$6.50 SELL FOR......$24.00 GROSS PROFIT $17.50 FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

RICHARD

BRAINERD FONT: OVER 24,000 QUALITY PRODUCTS CRAWLING COMMANDO CAROUSEL AQUA SHOES

Complaint 123 F.T.C.

EXHIBIT A

'Mellinger's Secret Treasures' MST-1 E AT Final On Air Script

RICHARD Richard:

So you can do everything in the comforts of your own home.

RICHARD & BRAINERD Brainerd: Precisely! And many people prefer working from home without any travel. But if you've ever dreamed of world travel, this is a golden opportunity. With your own import/export mail order EXOTIC TRAVEL COVER business you can explore exotic markets SHOTS:

RIVER AT SUNSET around the world. And, in many cases, INTERNATIONAL TRADERS your travel is tax deductible as a IN STANLEY MARKET LOOKING AT SCARVES business expense.

INTERNATIONAL TRADERS IN STANLEY MARKET LOOKING AT BIRD CAGES FONT: CONSULT YOUR ACCOUNTANT FOR ALLOWABLE DEDUCTIONS.

RICHARD Richard:

Brainerd, aren't some Mellinger World Trade members here with us in Hong Kong?

IT MEMBERS W SUPPLIERS Brainerd V.O.: & PRODUCTS Yes, and they're learning first hand from my global product source how to find the very DIFFERENT SHOT OF IT best deals on beautiful oriental MEMBERS W SUPPLIERS imports

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Final On Air Script P A3

BRAINERD SHAKING HANDS WITH ALBERT CHAN

And meeting with some of our leading Asian suppliers.

RICHARD & BRAINERD

Richard:

You know, Brainerd, this is such an exciting, glamorous business. Do you have to invest a lot of money to get started?

BRAINERD

Brainerd:

Not at all, Richard.

RICHARD

Richard:

How's that possible?

BRAINERD

Brainerd:

MELLINGER EMPLOYEE SORTING PRODUCT INTO BOXES

Well, it's secret number 2 of the Mellinger Business Success Formula,

FONT:

MELLINGER BUSINESS SUCCESS SECRET #2:

DROP SHIPPING. NO NEED TO STOCK PRODUCTS.

called Drop Shipping.

RICHARD & BRAINERD

Richard:

Drop shipping?

Brainerd:

Yes, that's how my father started, in a garage with less than $100 and went on to make millions.

RICHARD

Richard:

Well, how does this drop shipping work?

RICHARD & BRAINERD

Brainerd:

CU ON CAMERA

Well for example take this 35mm Sports Camera from the Orient

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 : A9 Final On Air Script

It automatically takes four quick shots in a row.

Richard:

Boy, this would be great for capturing any action like sports or the kids at play.

BRAINERD Brainerd:

RICHARD & BRAINERD W/ Yes, and it costs only two dollars, but CAMERA you don't pay a cent until after you CU ON CAMERA sell it. You simply run an ad offering FONT: it for $15. Then when the checks come BUY FOR......$ 2.00 SELL FOR......$15.00 pouring in you put the $13 gross profit GROSS PROFIT.$13.00 right in your pocket--send the orders FONT: and the $2 cost per camera to the $2 COST DOES NOT INCLUDE SHIPPING AND supplier. Then the supplier sends the DUTY CHARGES. cameras directly to your customers for you.

RICHARD Richard:

That's amazing! So you don't pay for anything until it is sold? BRAINERD Brainerd:

That's right. No inventory to buy, no employees to pay. Before you know it your business is expanding beyond your wildest dreams.

BRAINERD & RICHARD Richard:

Like successful International Traders Frances Reed and Jacquie Ward.

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A10 Final On Air Script

Brainerd:

Exactly.

FEATURE #1: FRED AND JACQUIE WENZ

WIDE SHOT, FRED AND JACQUIE WALKING ON THE BEACH FACING CAMERA.

FONT: MELLINGER SUCCESS PROFILE

Narrator:

For over 30 years, 52 year old Fred Wenz was on the road. His business kept him away from home and his wife Jacquie.

Jacquie Wenz:

Besides the financial rewards that we've gained from the Mellinger Plan, and using it, I have my husband home again.

DISSOLVE TO TWO SHOT OF FRED AND JACQUIE

FONT:

FRED AND JACQUIE WENZ INTERNATIONAL TRADERS

Fred Wenz:

It's really great being at home, but, you know, all the travelling I used to do puts a lot of wear and tear on the body, and now I'm now able to spend more quality time with my wife. Narrator:

From his home in Marshfield, Massachusetts, Fred has taken the Mellinger Plan and has added his own special twist that has been quite successful.

FRED AND JACQUIE WORKING TOGETHER AT DESK

Fred Wenz:

Several years ago when we first started

FRED IS BY HIMSELF MCU

exhibiting at the Mellinger show in Las

COVER OF LAS VEGAS TRADE SHOW

[illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P All Final On Air Script

FRED AND JACQUIE DISPLAYING JEWELRY AT TRADE SHOW BOOTH

Vegas, was where we noticed that a lot of customers were asking how they can get started in buying merchandise without capital expenditure of large inventories. We said, lets take the Mellinger Plan and couple it with our Product group.

FRED AND JACQUIE WORKING AT DESK TOGETHER

Narrator:

Well, it worked. In fact, it was so successful that they decided to come up with a sure fire system to ensure success for their distributors.

CU ON PERFECT STARTER KIT, PAN DOWN

Fred Wenz:

We then developed what we call the Perfect Starter Kit, for lack of a better name. The Starter Kit, there are two types. There's one that's got 40 pieces of jewelry. Another one's got 70 pieces of jewelry. And everything in there has been a proven factor that for mail order or distributors, party plans, you name it.

FRED, JACQUIE AND DAUGHTER W/ DISPLAY AT TRADE SHOW BOOTH

CU PAN ACROSS KITS

ECU PAN ACROSS JEWELRY

Narrator:

Fred and Jacquie's success grew to the point where they joined into partnership with Henry Baliser. Together they now own an efficient assembly plant and a successful showroom where they display their

FRED AND JACQUIE PACKING PRODUCT

FRED AND HENRY LOOKING AT MAP ON OFFICE WALL

PAN OVER WORKERS IN PLANT

PAN ACROSS SHOWROOM

1554 CORPORATION, ET AL.

Complaint EXHIBIT A 'Mellinger's Secret Treasures' MST-1 P- A12 Final On Air Script

CU ON JEWELRY spinning jewelry. What's really convenient, Fred and Jacquie actually FRED AND JACQUIE run the business right out of their WORKING TOGETHER AT DESK home.

FRED AND JACQUIE ON Fred Wenz: COUCH TOGETHER One of the beauties about running a business out of your home is that you can do what you want, when you want, where you want, and how you want. CU ON CALCULATOR The profit margins are absolutely CU TAKING PRODUCT OUT fantastic, especially if you're OF BOX directly importing. You can expect profits of up to 10:1, which is FRED O/C absolutely phenomenal. One of the best FONT: FRED WENZ things about the Mellinger World Trade INTERNATIONAL TRADER Plan is that you do not have to have any experience whatsoever. There is no formal education required. You can do FRED RECEIVING FAX it in the privacy of your own home, either full time or part time. And FRED O/C then the amazing part is, is that by putting all of this effort in, you can then go to your post office box or mail box, and get all sorts of checks coming in.

FRED AND JACQUIE Jacquie Wenz: WALKING ON BEACH FRED AND JACQUIE ON COUCH I'm really thrilled at the fact that I TOGETHER have my husband home now and we're FONT: JACQUIE WENZ

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A13 Final On Air Script

INTERNATIONAL TRADER working together at home, and I don't have to wait every night for a telephone call in order to communicate with him. If I have a question or a problem I can now turn to him and just ask it.

RICHARD & BRAINERD Richard:

Brainerd, these folks are making a lot of money, and enjoying every minute of it.

BRAINERD Brainerd:

FONT: The Mellinger World Trade Mail Order BRAINERD L. MELLINGER III, PRESIDENT/C.E.O., Plan shows you how, every single step THE MELLINGER COMPANY of the way.

TESTIMONIAL Carolyn Kaplan:

FONT: CAROLYN KAPLAN This has given me life. It's made me, INTERNATIONAL TRADER happy and I feel good, and I'm making money.

TESTIMONIAL Kathy Land:

FONT: KATHY LAND See my smile? I'm just really excited INTERNATIONAL TRADER about it, cause I know that there's nothing but money ahead.

TEASE:

RICHARD Richard: Stay tuned for Mellinger's FONT: THIS PROGRAM IS third moneymaking secret and learn how A PAID ADVERTISEMENT FOR THE MELLINGER you can buy fascinating products at COMPANY below wholesale prices

ARIEL OF HAVE MORE [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT A 'Mellinger's Secret Treasures' MST-1 p. A14 Final On Air Script FONT: STAY TUNED FOR MELLINGER'S BIG MONEY MAKING SECRET! END OF SEGMENT 1 COMMERCIAL #1 (2:30):

800# DISPLAYED OVER ANIMATED GRAPHIC.

DISSOLVE IN FLASHING FONT:

CALL NOW FOR YOUR FREE INFORMATION! Narrator:

Call this toll free number right now and we'll send you CUE IN DISPLAY SHOT OF MATERIAL FROM MAILING "A"

FONT: CALL FREE everything you need to know about how to get started with the Mellinger World Trade Mail Order Plan.

SHOT OF "IMPORT/EXPORT MAIL ORDER BUSINESS"

BOOKLET Including, absolutely free, this fascinating guide on the import/export mail order business...

SHOT OF "HOW TO START IN MAIL ORDER" BOOKLET"

a special, condensed mini mail order course...

FONT:

CALL NOW FOR YOUR FREE SAMPLE IMPORT! Plus, your exciting free sample import.

DISPLAY SHOT OF MATERIAL FLASHING FONT:

FREE!!! You get all three of these absolutely free, with no obligation, if you call now! TESTIMONIAL CUE BOX WITH CLOSE FONT:

MELLINGER FONT:

1-800-300-0003 Fred Wenz:

To be very honest with you, I swear by the Mellinger Plan, really. It has given us everything that we wanted. PRODUCT SHOT Narrator:

FONT:

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F A15 Final On Air Script

CALL FOR COMPLETE Once you receive the complete Mellinger DETAILS ON COST OF THE World Trade Mail Order Plan, you MELLINGER PLAN automatically become a member

IT LOGO FLIES IN of International Traders with immediate access to

CATALOG SHOTS over 24,000 products FONT:

OVER 24,000 QUALITY PRODUCTS

from around the world.

CUE IN SHOTS OF Unique and exciting products that you IMPORTS.

FONTS: can market at substantial profits. UNIQUE! EXCITING! INCREDIBLE PROFIT MAKERS!

WENZ'S WORKING TOGETHER Be your own boss. Working in the AT DESK comfort of your own home. Making extra FONT:

BE YOUR OWN BOSS! income -- spare time or full time. CAROLYN KAPLAN COUNTING MONEY

FONT:

MAKE EXTRA INCOME!

CURRENT FOOTAGE OF Mr. Mellinger's talented, dedicated MELLINGER BUILDING WITH team of experts brings you PEOPLE WAVING.

FONT:

OVER 45 YEARS OF EXPERIENCE

MELLINGER PEOPLE AT over 45 years of experience in the WORK import export mail order business.

MELLINGER PEOPLE They'll give you the personal step by WORKING WITH IT MEMBERS step guidance you need to succeed. IN PERSON AND OVER PHONE

FONT:

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p A16 Final On Air Script HELP YOU EVERY STEP OF THE WAY.

PAN OVER PRODUCT FILLED help you select hot new products that CHEST can generate substantial profits... FONT: HELP YOU SELECT NEW PRODUCTS PAN ACROSS ADS IN BOOK show you how to advertise at little or FONT: ADVERTISE AT no cost... LITTLE OR NO COST ANSCN W/ PRODUCT and how to market your products FONT: effectively.

AND MARKET YOUR PRODUCTS EFFECTIVELY MELLINGER PRINTING They'll even print your business cards PRESS TURNING OUT STATIONARY & BUSINESS and stationary. CARDS. FONT:

PRINT BUSINESS CARDS BRAINERD MEETING IT And gladly answer any questions you may MEMBER IN OFFICE have, in person or over the phone. IT MEMBER ON PHONE FONT:

ANSWER ANY QUESTIONS YOU HAVE! SHORT CUTS OF IT People all over the United States and MEMBERS FROM FEATURES Canada have used the plan successfully, FONT: CALL NOW FOR starting with very little, with no YOUR FREE SAMPLE IMPORT FONT: special education or background. 1-800-000-0000 MAN OR WOMAN WALKS TO Get started now, learn how to cut out MAIL BOX, OPENS IT, AND THUMBS THROUGH PILE OF the middleman... ENVELOPES SMILING.

FONT:

CUT OUT THE MIDDLEMAN! IT'S LOOKING AT CATALOG deal direct with the source... FONT: DEAL DIRECT WITH THE SOURCE

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F. A17 Final On Air Script

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS ON and make money right from the start... CALCULATOR

FONT: MAKE MONEY RIGHT FROM THE START

IT'S ON COUCH READING part time or full time. BROCHURES

BRAINERD FROM VICTORIA Brainerd: PEAK.

If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE: Narrator:

GET YOUR FREE SAMPLE IMPORT! Call the toll free number on your CALL OR WRITE: screen now.

Or write to us at: The Mellinger THE MELLINGER CO. Company, 6100 Variel Avenue, Woodland 6100 VARIEL AVE. DEPT 3 WOODLAND HILLS, Hills, California. CA 91367 There's no obligation.

No salesman will call.

Take advantage of this incredible IF PHONE LINES ARE opportunity, NOW! BUSY, KEEP TRYING.

1-800-000-0000 Roy Hansen:

TESTIMONIAL You will be successful. It's been OVE BOX W/ GLOBE proven time and time again.

FONT:

1-800-000-0000

SEGMENT 3:

RICHARD & BRAINERD Richard:

FONT:

1554 CORPORATION, ET AL. 1129

1108 Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P A18 Final On Air Script

HONG KONG Oh, we've learned two secrets of the Mellinger success formula. What's the third?

FONT: Brainerd:

MELLINGER BUSINESS SUCCESS SECRET #3: Well, the third secret--and listen CUT OUT MIDDLE MEN.

BUY DIRECTLY FROM carefully, this is really important-- SOURCE. you've got to cut out all the middle

men.

FONT: PRICE Richard:

COMPARISONS ARE BASED ON COMPARABLE Middle men.

QUANTITIES.

Brainerd:

They can easily eat up most of your profits. So we show you how to buy directly from the source at below wholesale prices.

RICHARD Richard:

How can you find the source? RICHARD & BRAINERD Brainerd:

We do it for you by searching the world over for new product ideas. When you receive the Mellinger Plan and join International Traders you immediately have access to over 24,000 exciting products.

Richard:

24,000 products? BRAINERD Brainerd:

All carefully chosen for their

[illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p.A19 Final On Air Script

CU WONDER KNIFE quality, FONT: QUALITY

CU TOY JEEP easy salability, FONT: SALABILITY

CU PUPPY mark-up FONT: MARK UP

CU AQUA SHOES and profit.

FONT: PROFIT

BRAINERD And every month you'll receive information on many new product opportunities.

DROP SHIP DIRECTORY Plus, International Traders Members FONT: DIRECTORY OF also receive a confidential directory FOREIGN SUPPLIERS listing hundreds of foreign suppliers.

BRAINERD You easily contact them direct. There FONT: are no middle men. And we collect no BRAINERD L. MELLINGER commission. III, PRESIDENT/C.E.O., THE MELLINGER COMPANY

RICHARD Richard:

FONT: RICHARD Now, wait a minute, the Mellinger ANDERSON, FILM AND Company gets nothing? TELEVISION STAR

BRAINERD Brainerd:

FONT: FURTHER No commission to us. You get the INFORMATION ON THE COST suppliers' below wholesale prices OF THE MELLINGER PLAN Nobody takes a cut. IS AVAILABLE WHEN YOU CALL.

RICHARD & BRAINERD Richard:

O.K. So now you have your product. How do you turn this into a quick profit?

FONT: Brainerd:

MELLINGER BUSINESS Well SUCCESS SECRET #4:

FREE ADVERTISING

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A20 Final On Air Script

that brings us to Success Secret Number 4. Free advertising.

We show you how to advertise your product at little or no cost.

LISA IN OFFICE Lisa Garcia:

FONT: LISA GARCIA For example, the International Trader ADVERTISING MANAGER THE MELLINGER CO.

member received a

CU ARTICLE ON FREE free ad worth over $2,000 in a national ADVERTISING magazine.

LISA GARCIA As an International Trader, I may be able to do the same for you.

RICHARD & BRAINERD Richard: (to camera) Talking to people who have used the Mellinger Plan has shown me over and over again that dreams do come true, and almost anything is possible. Watch this...

FEATURE #2: CAROLYN KAPLAN

CAROLYN WALKING THROUGH Carolyn:

GIFT SHOP This is African Gift shops. This is my baby.

CAROLYN WALKING ONTO Narrator:

HER BALCONY Not long ago, 40 year old Carolyn

FONT: MELLINGER Kaplan of Atlanta Georgia had her SUCCESS PROFILE entire life turned upside down when she was diagnosed with severe recurring migraine headaches and officially rendered disabled

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A21 Final On Air Script

CAROLYN Carolyn:

FONT: CAROLYN KAPLAN I was unemployable with the migraine INTERNATIONAL TRADER headaches because I wasn't dependable. I didn't know when they were going to strike or how long they were going to last, so it put me in a situation where no employer would employ me, and I had to do something.

CU PERFUME BOTTLES IN I started off with $250 that my husband STORE gave me, and last year I earned over CU CHESS SET IN STORE $35,000, and I did it all with the help of the Mellinger Company. I'm real proud of that.

CLIFFORD Clifford:

FONT: CLIFFORD HUGHES Once we found out she had learned about INTERNATIONAL TRADER the Mellinger program, we saw how quickly she, her spirit picked up and CAROLYN WORKING IN how she just became, she had a zest for STORE CLIFFORD life. I think that one of the best programs out today is the Mellinger Program through what it has done for her, my aunt, as brought her morale back up.

COVER OF AFRICAN GIFT Narrator: STORE Carolyn started with one gift shop in Atlanta, but her business grew so CAROLYN IN STORE WITH rapidly that she needed to open up CUSTOMER another shop in a different part of town.

[illegible]

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A22 Final On Air Script

COVER OF INTERNATIONAL Carolyn: GALLERIES STORE This is my newest shop, International Galleries, which is just recently CAROLYN opened.

It's amazing to me how all this has CAROLYN COUNTING MONEY come together in such a short time. I make money. I sell. No matter what the economy is like, I sell. Narrator:

CU ARTICLES: "US FAMILIES DRIFTING Keeping families together in such APART" "UNEMPLOYMENT ON THE RISE" uncertain times is not an easy task. But Carolyn, with help from the CAROLYN WITH PRODUCT FROM STORE Mellinger company, has been able to do just that by bringing her nephew CLIFFORD WORKING Clifford and her son Patrick into her CLIFFORD AND PATRICK thriving business.

Clifford:

CLIFFORD HUGHES I don't think people really understand, actually, how easy the Mellinger Plan has been to learn about basic business functions. Since I started working here I learned, I've been learning a lot about just the import/export business a lot. My aunt showed me the plan and I just have, just really kind of fallen in love with it. It's taught me a lot

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A23 Final On Air Script

CU ON JEWELRY ON DISPLAY, TILT UP TO CAROLYN

Carolyn:

I would advise anyone who's sitting there thinking well, I have a job or you know, I'm disabled or I'm confined to a wheelchair, or whatever reason. I'm a single mother. Listen. Get involved with Mellinger, and if you stick with them they have the support team there for you, they can make something like this possible for you.

FONT: YOUR RESULTS MAY VARY.

RICHARD & BRAINERD

Richard:

Carolyn Kaplan demonstrates just what we're attempting to say today. Brainerd, your company's doing something very special. Allowing people to do things that they've dreamed of doing all their life.

BRAINERD

FONT: BRAINERD L.

MELLINGER III PRESIDENT/C.E.O., THE MELLINGER COMPANY

Brainerd:

Yes, and it's the wonderful freedom that comes from being your own boss, the master of your own destiny. And we show you exactly how to do it, step by step.

MELLINGER CO. WAVE OUTSIDE HEADQUARTERS

Brainerd (voice over):

With The Mellinger Mail Order Plan you're never alone.

You automatically become a member of International Traders--"

BRAINERD

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 F- A24 Final On Air Script WORLD MAP W TRADE ROUTES IT LOGO our huge world wide organization of importers, exporters, and direct FONT: ORGANIZATION OF IMPORTERS, EXPORTERS AND DIRECT MARKETERS.

marketers.

BRAINERD Once you've joined this exclusive BRAINERD AND STAFF IN OFFICE group, top notch experts help you in every phase of your business. CHRIS HARDENBROCK AND CO-WORKER FONT: WE HELP YOU EVERY STEP OF THE WAY LISA ON PHONE Brainerd:

FONT: WE HELP YOU EVERY STEP OF THE WAY You can call, write, or visit. BRAINERD WITH CLIENT IN OFFICE And we'll give you prompt, personalized assistance.

ANSON IN OFFICE Anson Jackson:

FONT:

ANSON JACKSON WORLD TRADE CONSULTANT THE MELLINGER COMPANY Any member of International Traders can pick up the phone and call me. I'm here to work with them and help them find the big money making products and market them effectively and inexpensively.

RICHARD & BRAINERD Richard:

And how much time and effort does it take to be a success at this? Brainerd:

It's up to you. You can work full time or start off in your spare time. TESTIMONIAL Jim Bleakley:

[illegible] The Mellinger Plan has enabled me to

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A29 Final On Air Script

FONT: JIM ZEIGLER INTERNATIONAL TRADER

move in a total career change from working for a large corporation to being my own boss.

TESTIMONIAL Mark Miller:

DVE IN BOX W/ GLOBE FONT: MARK MILLER INTERNATIONAL TRADER

Anybody today that really wants to work, and has the initiative to get out

FONT: RESULTS VARY DEPENDING ON HOW MUCH TIME INVESTED AND OTHER FACTORS.

and try something new, this plan definitely makes it about as easy as pie.

TEASE:

RICHARD Richard:

FONT: THIS PROGRAM IS A PAID ADVERTISEMENT FOR THE MELLINGER COMPANY

Don't go away. When we come back Brainerd will reveal one of the most important moneymaking secrets.

ARIEL SHOT OVER HONG KONG SKYLINE

FONT: STAY TUNED FOR MORE MONEY MAKING SECRETS.

END OF SEGMENT 2 COMMERCIAL TWO

800# DISPLAYED OVER ANIMATED GRAPHIC DISSOLVE IN FLASHING FONT:

CALL NOW FOR YOUR FREE INFORMATION!

Narrator:

Call this toll free number right now and we'll send you

DVE IN DISPLAY SHOT OF MATERIAL FROM MAILING "A"

FONT: CALL FREE

everything you need to know about how to get started with the Mellinger World Trade Mail Order Plan.

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A26 Final On Air Script SHOT OF "IMPORT/EXPORT MAIL ORDER BUSINESS"

BOOKLET including, absolutely free, this fascinating guide on the import/export mail order business...

SHOT OF "HOW TO START IN MAIL ORDER" BOOKLET"

a special, condensed mini mail order course...

FONT:

CALL NOW FOR YOUR FREE SAMPLE IMPORT! Plus your exciting free sample import.

DISPLAY SHOT OF MATERIAL FLASHING FONT:

FREE!!! You get all three of these absolutely free, with no obligation, if you call now! TESTIMONIAL CUE BOX WITH GLOBE FONT:

MELLINGER FONT:

1-800-000-0000 Ron Barki I'm creating my own job security. That's what this is all about. This is a way that you can control your own destiny.

PRODUCT SHOT FONT: CALL FOR COMPLETE DETAILS ON COST OF THE MELLINGER PLAN Narrator:

Once you receive the complete Mellinger World Trade Mail Order Plan, you automatically become a member IT LOGO FLIES IN.

of International Traders with immediate access to CATALOG SHOTS over 24,000 products FONT: OVER 24,000 QUALITY PRODUCTS from around the world.

CUE IN SHOTS OF IMPORTS FONTS:

UNUSUAL EXCITING Unique and exciting products that you can market at substantial profits

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 = A27 Final On Air Script

INCREDIBLE PROFIT MAKERS!

TESTIMONIAL Toni Mahon:

IVE BOX W CLOSE I'm having a delightful time. I have FONT: MELLINGER learned, I have learned so much more than I could had I gone to college for 4 years.

WENZ'S WORKING TOGETHER Narrator: AT DESK FONT: Be your own boss. Working in the BE YOUR OWN BOSS! comfort of your own home. Making extra CAROLYN KAPLAN COUNTING income -- spare time or full time. MONEY

FONT:

MAKE EXTRA INCOME!

CURRENT FOOTAGE OF Mr. Mellinger's talented, dedicated MELLINGER BUILDING WITH team of experts brings you PEOPLE WAVING.

FONT:

OVER 45 YEARS OF EXPERIENCE

MELLINGER PEOPLE AT over 45 years of experience in the WORK. import/export mail order business.

MELLINGER PEOPLE They'll give you the personal, step by WORKING WITH IT MEMBERS step guidance you need to succeed... IN PERSON AND OVER PHONE.

FONT:

HELP YOU EVERY STEP OF THE WAY,

PAN OVER PRODUCT FILLED help you select hot new products that CHEST can generate substantial profits...

FONT: HELP YOU SELECT NEW PRODUCTS

PAN ACROSS ADS IN BOOK show you how to advertise at little or FONT: ADVERTISE AT no cost LITTLE OR NO COST

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P- A28 Final On Air Script

ANSON W: PRODUCT and how to market your products FONT: effectively.

AND MARKET YOUR PRODUCTS EFFECTIVELY

MELLINGER PRINTING They'll even print your business cards PRESS TURNING OUT STATIONARY & BUSINESS and stationary. CARDS.

FONT:

PRINT BUSINESS CARDS

BRAINERD MEETING IT And gladly answer any questions you may MEMBER IN OFFICE have, in person or over the phone. IT MEMBER ON PHONE

FONT:

ANSWER ANY QUESTIONS YOU HAVE!

SHORT CUTS OF IT People all over the United States and MEMBERS FROM FEATURES Canada have used the plan successfully, FONT: CALL NOW FOR YOUR FREE SAMPLE IMPORT starting with very little, with no FONT:

1-800-000-0000 special education or background.

MAN OR WOMAN WALKS TO Get started now. Learn how to cut out MAIL BOX, OPENS IT, AND THUMBS THROUGH PILE OF the middleman... ENVELOPES SMILING.

FONT:

CUT OUT THE MIDDLEMAN!

IT'S LOOKING AT CATALOG deal direct with the source...

FONT: DEAL DIRECT WITH THE SOURCE

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS ON and make money right from the start... CALCULATOR

FONT: MAKE MONEY RIGHT FROM THE START

IT'S IN TOUCH READING part time or full time BROCHURES

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 3 A29 Final On Air Script

BRAINERD FROM VICTORIA PEAK.

Brainerd:

If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE:

GET YOUR FREE SAMPLE IMPORT! CALL OR WRITE:

Narrator:

Call the toll free number on your screen now.

THE MELLINGER CO.

6100 VARIEL AVE. DEPT 5 WOODLAND HILLS, CA 91367

Or write to us at: The Mellinger Company, 6100 Variel Avenue, Woodland Hills, California.

There's no obligation, No salesman will call.

Take advantage of this incredible opportunity, NOW!

IF PHONE LINES ARE BUSY, KEEP TRYING.

1-800-000-0000

SEGMENT 3

RICHARD AND BRAINERD

Richard:

Welcome back to Mellinger's Secret Treasures. I'm here in Hong Kong with Brainerd Mellinger the Third, our modern day Marco Polo, on one of his global product tours.

RICHARD & BRAINERD

And he's revealing

CU PAN ACROSS DISPLAY OF PLAN BOOKS

his secret formula in the import export mail order business.

RICHARD AND BRAINERD

Now Brainerd, let's talk about products. How do you know what's going to sell and what's not?

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 P-A30 Final On Air Script BRAINERD Brainerd:

FONT: Well, Richard, that's very important. MELLINGER BUSINESS SUCCESS SECRET #5 The fifth secret of the Mellinger FINDING PRODUCTS THAT SELL EASILY AND Success Formula is finding really hot QUICKLY. products.

RICHARD & BRAINERD Brainerd V/O: CU ON HAND AND GOLD We look for quality products that are SNAKE BRACELET unique, CU CAROLYN HOLDING VASE novel, CU HANDS HOLDING GOLD and appealing to many people. CLOCK BRAINERD Brainerd:

CU ON AQUA SHOE Like these aqua shoes. They're one of the hottest new items.

FONT: Richard:

BUY FOR...... $3 SELL FOR..... $25 You know, I've seen shoes like these in GROSS PROFIT $22 stores and they sell up to $40. FONT: Brainerd:

PROFIT MAY VARY DUE TO But International Traders can sell them OPERATING COSTS. for $25 because they get them for only $3.

RICHARD Richard:

FONT: Tell me, how do you find products like RICHARD ANDERSON that? FILM AND TELEVISION STAR BRAINERD Brainerd:

FONT: BRAINERD L. All you have to do is follow the MELLINGER PRESIDENT, C.E.O. Mellinger World Trade Mail Order Plan. THE MELLINGER COMPANY We give you everything you need to get FONT: started fast

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F A31 Final On Air Script

RESULTS MAY VARY DEPENDING ON TIME INVESTED AND OTHER FACTORS

CHRIS AT SUPPLIER'S LUNCHEON, HONG KONG

FONT:

CHRIS HARDENBROCK IMPORT MANAGER THE MELLINGER CO.

BRAINERD LOOKING AT JEWELRY IN STANLEY MARKET

BRAINERD LOOKING AT MAGIC RAZOR IN STANLEY MARKET

RICHARD

FONT: LAS VEGAS

ESTABLISHING SHOT DOWN BRIGHT LIGHTS OF VEGAS STREET

WIDE SHOT OF TRADE SHOW

The products, and step by step guidance.

Chris Hardenbrock:

Hong Kong is just one of the great international trade centers we travel to in our search for reputable suppliers of new moneymaking products. We check it out for you - make sure the supplier is reliable, has readily available product, it's of the highest quality, and is easily sellable.

Richard: (To Camera)

Now, we're going to jump from Hong Kong to the United States because I want to show you success in action.

Richard V/O:

At this annual trade show/convention, the Mellinger Company puts the whole world of exciting products under one roof.

LAS VEGAS FEATURE: BRAINERD & RICHARD ROAM THE FLOOR LOOKING AT PRODUCTS, SPEAKING TO VENDORS. IT MEMBERS COMMENT ON THEIR SUCCESSES

RICHARD

GRAPHIC OF TURNING GLOBE W OVER'D NAMES OF COUNTRIES FLYING OUT FROM BEHIND OF

Richard V.O.:

International Traders can pick up exotic new money makers from

Asia Africa Europe Bali, South America Ireland Egypt

[illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST- [illegible] A32 Final On Air Script

BRAINERD & RICHARD AT LAS VEGAS TRADE SHOW AT EGYPTIAN PAPYRUS DISPLAY

CU ON PAPYRUS

FONT:

BUY FOR....... $4 SELL FOR...... $50 GROSS PROFIT $46 FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

BRAINERD AND RICHARD AT TRADE SHOW DISPLAY FOR CALYPSO CUP

CU SPILLBUSTER

Brainerd:

Richard, look at this. Beautiful Egyptian papyrus! Richard:

Oh! That's beautiful! That's King Tut and his wife on a hunting party. Brainerd:

That's right. You can buy this for three dollars and ninety cents and sell it for as much as fifty dollars. Richard:

Well that's a thirteen to one mark-up! Richard:

Brainerd, What in the world is this? Brainerd:

Spill Buster.

Richard:

Spill...? Brainerd:

Buster.

Richard:

Buster.

Brainerd:

That's right. It's the best mobile beverage holder on the market. Richard:

This is amazing!

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P Final On Air Script A33

Brainerd:

Yeah. It keeps beverages from spilling in mobile homes, BRAINERD AND RICHARD AT cars and boats. TRADE SHOW DISPLAY FOR CALYPSO CUP

Richard:

Is it easy to install? Brainerd:

A child could install it.

Richard:

Cost? FONT:

BUY FOR...... $ 9.00 SELL FOR.... $20.00 GROSS PROFIT $11.00 FONT: PROFIT MAY VARY Brainerd: DUE TO OPERATING COST. $9.00 Richard:

And, well, what do you sell it for? Brainerd:

$20.00 RICHARD AND BRAINERD Richard: Obviously, the Mellinger Trade Show in Las Vegas was hugely successful and fun. But you don't have to travel beyond your mail box if you don't want to. Isn't that right Brainerd? BRAINERD Brainerd:

FONT: BRAINERD C. Right! You can do absolutely MELLINGER, PRESIDENT, C.E.O. everything in the comfort of your own THE MELLINGER COMPANY home ... DOUBLE ON SOFA W/ PLAN Brainerd V.O.:

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A34 Final On Air Script

CU ON CATALOG - HAND TURNING PAGES

The Mellinger Company puts the treasures of the world right at your finger tips.

FONT: OVER 24,000 QUALITY PRODUCTS

Every member of International Traders has access to over 24,000 profit making products.

PAN UP PAGE OF NEW PRODUCTS

And we continually give you new ones each month.

BRAINERD & RICHARD RICHARD PICKS UP A COPY OF "TRADE OPPORTUNITIES"

MAGAZINE.

Richard:

Plus, International Trader Members also receive "Trade Opportunities Magazine".

FAN SPREAD OF T.C.

MAGAZINES

Brainerd:

That's right Richard. You find out about the hottest new products every

CU PAGE OF T.C.

MAGAZINE

month in our magazine. And you won't find this on any newsstand. It's an

FONT: AN EXCLUSIVE PUBLICATION FOR MEMBERS ONLY

exclusive publication with all kinds of money making information, for members only.

RICHARD

Richard:

So you simply pick a product, run an ad if you choose mail order, and you're on your way.

And anyone can do it?

BRAINERD

Brainerd:

Anyone who is willing to follow our simple step by step plan.

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A35 Final On Air Script

FONT:

MELLINGER BUSINESS SUCCESS SECRET #6:

LEARN FROM THE EXPERTS.

SAVE TIME AND MONEY.

And that's our 6th secret of the Mellinger Success Formula. Learn from the experts, not from your own mistakes.

BRAINERD & RICHARD

Richard:

Well, mistakes can be expensive and time consuming.

FONT:

1-800-000-0000

Brainerd:

They sure can. And with our plan you don't need to start from scratch. All you have to do is pick up the phone and call us right now.

We'll show you how to make money right from the start.

FEATURE #3: KIRK YAGER

JAG LEAVING DRIVEWAY

Rodney Benn V/O:

So, Kirk, you started your business at the age of nineteen. Now, let's be honest. Were you some kind of a whiz kid or something in school?

FONT: MELLINGER SUCCESS PROFILE

INTERIOR SHOT - KIRK AND RODNEY DRIVING IN JAG

Kirk Yager:

No, not really. I played sports and had a good time, and nothing, just went to school

FONT: RODNEY BENN

Rodney:

Now be honest. How were your grades like?

Kirk:

Average. Average grades

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A36 Final On Air Script Rodney:

Amazing. What made you start the business in the first place? Kirk:

Well, I was looking for a good business program, and I ran across the Mellinger program with imported items, and mailed off for it, and was able to get into some real easy businesses with imported items.

Rodney:

Let's talk about the Mellinger Plan itself. So, what was it like? Did you think it was easy, that something just about anybody could follow? Kirk:

Oh, definitely.

JAG TURNING INTO DRIVEWAY You know, I have one year of college and I'm no genius.

Rodney:

No rocket scientist.

Kirk:

No, no rocket scientist.

Narrator:

Kirk may not be a rocket scientist, but with the help of the Mellinger World Trade Plan he has launched a company with sky-rocketing profits Today is a typical business day and Appx A36A-

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F- A37 Final On Air Script

FONT: YOUR RESULTS MAY VARY

RODNEY AND KIRK GOING TO BOXES OF HATS

RODNEY AND KIRK BY BOXES OF PRODUCT

ZOOM INTO CU ON HAT

RODNEY AND KIRK

CU HAT

CU RODNEY

Kirk is shipping out more than 400 hats. The profits are all his.

Rodney:

Well, this must be the product.

Kirk:

Yeah, we have the pitch on the solar fan hat has a solar voltic cell on top.

Rodney:

So this is a solar cell that collects the sun's rays and turns it into electricity?

Kirk:

Yeah, exactly. Or you have a battery backup for shade or night time. Yeah, and what it does is with a moistened sponge here, it works just like an induct cold system on your head. It's fantastic.

Rodney:

Ah ha. It's a great idea.

Kirk:

Oh yeah.

It's one of the best items I've found, I've found, you know, just basically through one of the Mellinger programs.

Rodney:

Really? What was it like when the first big money started to roll in?

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 A38 Final On Air Script

RODNEY AND KIRK BY POOL Kirk:

FONT: THIS PROGRAM IS Oh, it was fantastic. You know, I'm A PAID ADVERTISEMENT able to spend a lot more time with my FOR THE MELLINGER COMPANY family, and go on vacations...

KIRK AND FAMILY and enjoy outings, and dinners, and SWIMMING IN POOL swimming, and boating, you know...

Rodney:

Having a fuller life.

Kirk:

Exactly. Enjoying a lot of, you know, activities.

CU KIRK Brainerd Mellinger's World Trade FONT: KIRK YAGER Program has been very beneficial to INTERNATIONAL TRADER myself and my family, and I think that anyone that gets involved with this is gonna really find exciting, interesting, and create an income for themselves. It's fantastic. So, my advice would be to give it a try. You know. That's all I can say is give it a try.

END OF SEGMENT 3

COMMERCIAL THREE

800# DISPLAYED OVER Narrator: ANIMATED GRAPHIC DISSOLVE IN FLASHING Call this toll free number right now FONT:

CALL NOW FOR YOUR FREE and we'll send you INFORMATION!

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 5 A39 Final On Air Script

DVE IN DISPLAY SHOT OF everything you need to know about how MATERIAL FROM MAILING "A" to get started with the Mellinger World FONT: CALL FREE Trade Mail Order Plan.

SHOT OF "IMPORT/EXPORT Including, absolutely free, this MAIL ORDER BUSINESS"

BOOKLET fascinating guide on the import export mail order business...

SHOT OF "HOW TO START a special, condensed mini mail order IN MAIL ORDER" BOOKLET" course...

FONT: Plus, your exciting free sample CALL NOW FOR YOUR FREE SAMPLE IMPORT! import.

DISPLAY SHOT OF You get all three of these absolutely MATERIAL FLASHING FONT: free, with no obligation, if you call FREE!!! now!

TESTIMONIAL Bernard Alexander: DVE BOX WITH CLOSE FONT: It's very easy, everything is spelled MELLINGER FONT: 1-800-000-0000 out from A to Z. You just follow the information and direction they give you.

PRODUCT SHOT Narrator:

FONT: CALL FOR Once you receive the complete Mellinger COMPLETE DETAILS ON COST OF THE MELLINGER World Trade Mail Order Plan, you PLAN automatically become a member

IT LOGO FLIES IN. of International Traders with immediate access to

CATALOG SHOTS over 24,000 products

FONT:

OVER 24,000 QUALITY PRODUCTS

from around the world

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A40 Final On Air Script DVE IN SHOTS OF Unique and exciting products that you IMPORTS FONTS: can market at substantial profits. UNIQUE! EXCITING! INCREDIBLE PROFIT MAKERS! TESTIMONIAL Nabil Assad:

DVE BOX W. GLOBE The Mellinger Program, it changed my FONT: MELLINGER life. It made a professional out of me. It taught me one thing, to work smart, don't work hard.

WENZ'S WORKING TOGETHER Narrator: AT DESK FONT:

BE YOUR OWN BOSS! Be your own boss. Working in the CAROLYN KAPLAN COUNTING comfort of your own home. Making extra MONEY income -- spare time or full time. FONT:

MAKE EXTRA INCOME! CURRENT FOOTAGE OF Mr. Mellinger's talented, dedicated MELLINGER BUILDING WITH team of experts brings you PEOPLE WAVING.

FONT:

OVER 45 YEARS OF EXPERIENCE MELLINGER PEOPLE AT over 45 years of experience in the WORK. import/export mail order business. MELLINGER PEOPLE They'll give you the personal, step by WORKING WITH IT MEMBERS step guidance you need to succeed... IN PERSON AND OVER PHONE.

FONT:

HELP YOU EVERY STEP OF THE WAY.

PAN OVER PRODUCT FILLED help you select hot new products that CHEST can generate substantial profits... FONT: HELP YOU SELECT NEW PRODUCTS PAN ACROSS ADS IN BOOK show you how to advertise as little or as much

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 A41 Final On Air Script

FONT: ADVERTISE AT LITTLE OR NO COST

ANSON W/ PRODUCT and how to market your products

FONT: effectively.

AND MARKET YOUR PRODUCTS EFFECTIVELY

MELLINGER PRINTING They'll even print your business cards PRESS TURNING OUT STATIONARY & BUSINESS and stationary. CARDS.

FONT:

PRINT BUSINESS CARDS

BRAINERD MEETING IT And gladly answer any questions you may MEMBER IN OFFICE have, in person or over the phone. IT MEMBER ON PHONE

FONT:

ANSWER ANY QUESTIONS YOU HAVE!

SHORT CUTS OF IT People all over the United States and MEMBERS FROM FEATURES Canada have used the plan successfully, FONT: CALL NOW FOR YOUR FREE SAMPLE IMPORT starting with very little, with no FONT:

1-800-00C-C000 special education or background.

MAN OR WOMAN WALKS TO Get started now, learn how to cut out MAIL BOX, OPENS IT, AND THUMBS THROUGH PILE OF the middleman... ENVELOPES SMILING.

FONT:

CUT OUT THE MIDDLEMAN!

IT'S LOOKING AT CATALOG deal direct with the source...

FONT: DEAL DIRECT WITH THE SOURCE

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS ON and make money right from the start CALCULATOR

FONT:

[illegible]

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A42 Final On Air Script

MAKE MONEY RIGHT FROM THE START

IT'S ON COUCH READING part time or full time. BROCHURES

BRAINERD FROM VICTORIA Brainerd: PEAK: If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE: Narrator:

GET YOUR FREE SAMPLE Call the toll free number on your IMPORT! screen now.

CALL OR WRITE:

THE MELLINGER CO. Or write to us at: The Mellinger 6100 VARIEL AVE. DEPT B Company, 6100 Variel Avenue, Woodland WOODLAND HILLS, Hills, California. CA 91367 There's no obligation. No salesman will call.

IF PHONE LINES ARE BUSY, KEEP TRYING.

1-800-000-0000

CLOSE

RICHARD AND BRAINERD AT Richard: KOWLOON LOCATION You know, this is an exciting opportunity. Now Brainerd, you have told us the six secret treasures of the Mellinger Business Success Formula. I've got just one last question for you. The Mellinger Plan makes it so easy to achieve financial independence.

[illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A43 Final On Air Script

Why isn't everyone doing it? Brainerd:

Good question.

Well... it's just that they don't know about the Mellinger Plan yet. They aren't aware that this fabulous opportunity for success and riches is waiting for them. And that's why I'm here today.

BRAINERD I want to tell everyone that they can make money, CAROLYN AND CLIFFORD IN like some of the folks you've seen on STORE our show. The Mellinger Company shows you how, step by step.

JACQUIE AND FRED ON And we make it simple and fun, but the BEACH first step is up to you. FONT: Pick up the phone and dial the toll 1-800-000-0000 free number on your screen now. There's absolutely no obligation. As soon as you call, the Mellinger Company is behind you every step of the way. And we'll get you started on the roads to riches--fast. Our operators are standing by 24 hours a day for your convenience. So call now! TESTIMONIAL Roy Hansen:

FONT: If you want medical advice you go to a 1-800-000-0000 doctor. If you want legal advice you go to an attorney

[illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A44 Final On Air Script

If you want mail order advice you go to the Mellinger Company.

TESTIMONIAL Carolyn Kaplan:

FONT: The Mellinger Company really has opened 1-800-000-0000 up many new avenues of my life. My family is the world, and it's just great.

TESTIMONIAL Kirk Yager:

FONT: Anyone that gets involved with this is 1-800-000-0000 gonna really find it exciting, interesting and create an income for themselves that's fantastic, so, my advice would be to give it a try.

DISCLAIMER GRAPHIC Narrator:

The preceding program was a paid advertisement for The Mellinger World Trade Mail Order Plan by The Mellinger Company.

Complaint 123 F.T.C.

EXHIBIT B

2 valuable New Reports Can Make You Rich! I'll send both to you FREE!

Discover How to Be Independent — Be Your Own Boss — Make Big Money in your own IMPORT/EXPORT MAIL ORDER BUSINESS!..

Deal Direct with leading suppliers and keep ALL profits! Buy Below Wholesale Rock-bottom prices pay fantastic markups! Profit big with exciting import products!

BRAINERD L. MELLINGER III President/CEO, The Mellinger Co. Fourth generation of internationally respected World Trade/Mail Order family. The Mellinger Co. started by our founder in a rented garage with barely $100. Our 45 years of successful World Trade/Mail Order experience is your time-proven guide to profits. Follow Mellinger methods, global contacts, and profit secrets to a prosperous business of your own. Mail coupon for all facts...discover how to start quickly, surely!

MEN-WOMEN...you'll never get rich working for somebody else! Your answer is being your own boss in your own business! World Trade/Mail Order is the one business you can still "start on shoestring"! Enjoy earnings probably far greater than you ever dreamed any job could pay. The Mellinger World Trade/Mail Order home business plan guides you step by step. Plan based and backed by four generations of Mellinger family global success! We travel the world, discovering dazzling new import product and handicraft values you'll turn into quick, steady profits. Start with choice of 24,221 of today's hottest import moneymakers. Always deal direct—no middlemen—keep all profits!

Join these successful Men and Women! "My biggest day's sales has been $1,535.50 and the largest single sale was $1,122! This Plan has made a change in my life."

Ana M. Mineley "Mellinger has the answers! I'm looking at $25,000 year's income —just 2 hours a day part-time." Alad Pessarore "Just one world trade transaction paid me $3,000. Thank You...follow the Mellinger Plan!"

Glen Campbell "Following the Mellinger Plan I opened my own gift shop. Plus, made $12,000 Mail Order profits!" Mamie Gibson [illegible]

START WITH CHOICE OF 24,221 HIGH PROFIT IMPORTS!

START FAST FROM HOME...Full-Time or Part-Time! No employees! No rent! Almost no overhead! Actually make first import transaction 10 minutes after Plan arrives. Can operate without product investment. Plan reveals exactly how to sell by Mail Order or many other high profit ways. Receive free membership in International Traders organization...immediately puts you in direct contact with suppliers overseas. Age, past experience not important. Ideal for husband and wife team or retirement!

FIND OUT! I'll send 2 reports, Free Sample Import and Condensed Mail Order Course—all free! Discover how to turn imports we find into really big money. Read my 2 complete reports. Marvel at free sample import I'll send! No obligation. No salesman will call. Mail certificate today!

Personal Guidance You're never alone! Mellinger Personal Consultants help at every step. Be invited to regional Mellinger Seminars...an extra intensive [illegible]

ADDED EARNINGS Now make even more money with Mellinger Plan. Deal direct in U.S. made products at lowest rock-bottom prices. Keep all profits! No "buying fees"!

This Certificate Good for ONE SAMPLE IMPORT—FREE B. L. MELLINGER III, THE MELLINGER CO. 6100 VARIEL AVE., Dept. Q2069 WOODLAND HILLS, CA 91367-3779 Send FREE Sample Import, FREE Report and FREE condensed Mail Order Course. Show me how I can start a profitable home-based business. No obligation.

THE MELLINGER CO. Dept. Q2069 6100 Variel Ave., Woodland Hills, CA 91367-3779

1554 CORPORATION, ET AL. 1157

1108 Complaint

EXHIBIT C Mellinger Company http://www.noboss.com/mellingr.html

PRIME-CATEGORY: Consumer Services CATEGORY: Import/Export

SOURCE: The Mellinger Company OFFER: become a member of International Traders, gain introduction and access to hundreds of carefully screened foreign suppliers carrying over 20,000 imports plus gain information regarding profit potential as export agent for domestic manufacturers. COST: $198 or payments of $15 to start. $18.90 for 12 months. THE PACKAGE: Receive 20 Section Mellinger World Trade/Mail Order Plan, Supplement and 11-piece Visualizer Kit. When paid in full, receive 3 Year International Traders Membership, Free sample Imports, Trade Agreements, Drop Ship Directory, Trade Opportunities Magazine for 3 years (published bimonthly) and sample portfolio of business forms. Free personal telephone consultation available to members. Visa/Mastercard payment accepted. In addition, the Platinum Profession Training includes round-trip air fare transportation and hotel accommodations at a 4-star hotel while attending 3 days of factory training and Master Certificate as a Professional Glass Repair Technician. Bonus Book "How To Run Mail Order Advertising" for orders within 14 days of receipt of information. MARKETING TECHNIQUE: sell imports by mail. Members-only Drop-Ship Plan enables you to start without product investment. MISCELLANEOUS: Mellinger family active in world trade and mail order for over 90 years. You deal directly with overseas suppliers, cut out middlemen and keep all profits. International Traders Trade Show Convention in Las Vegas held annually for International Traders members. TYPICAL EARNINGS: Examples of earnings of individual members (1) borrowed $500 to start, made $45,000 after 6 months, (2) first year brought $30,000: recently had sales of $41,920 in a single day, (3) first year sales of $55,000; now serve 250 customers are 'trying for a million'. GEOGRAPHIC AVAILABILITY: USA ADDITIONAL INFORMATION: For full details on this Business Opportunity simply.

REQUEST TO BE SENT DETAILED INFORMATION

or you can write :

The Mellinger Company 6100 Variel Avenue, Dept NOBOSS Woodland Hills, CA 91367 6100 Variel Avenue, Dept NOBOSS Woodland Hills, CA 91367

NOTE: this "Listing" has NOT been reviewed-for-accuracy by the Source

TO TOP

Complaint 123 F.T.C.

EXHIBIT D

THE MELLINGER WORLD TRADE/ MAIL ORDER BUSINESS PLAN START AT HOME...

[illegible] International Traders

4 Generations of Mellinger experience guide you to Success and Fortune!

The Mellinger family has been directly active in World Trade/Mail Order for nearly 60 years! Starting with Great Grandfather Louis Mellinger, our family has directed the flow of millions upon millions of dollars of goods to buyers through the mails. The Mellinger family plays a key role in making World Trade/Mail Order a profitable career for ambitious men and women! You enjoy the full benefit of this vast experience as you follow Mellinger guidance. As you begin following the Mellinger Plan and become a Member of International Traders, we put you at once in direct contact with leading suppliers overseas offering you thousands of fast-selling imports below wholesale. We show how to cut out middlemen so you keep all profits. And we guide you step-by-step in marketing your imports for big profits in Mail Order and many other ways. This is the International Traders way to business success!

B.L. Mellinger III President/CEO, The Mellinger Co.

In the pages of this book, I invite you to discover how the Mellinger World Trade/Mail Order Business Plan can help bring you independence, security and probably more money that you ever dreamed. Proudly, I can tell you how the global Mellinger Organization I direct has made this dream a reality for so many ambitious men and women of all ages and backgrounds! I look forward to helping you get your fast, profitable start in World Trade/Mail Order!

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

The most respected Mail Order business family in the world leads you to security and Independence

B.L. MELLINGER JR.

Founder, the Mellinger Plan. Marketing import product discoveries by Mail Order, he quietly built a multimilliondollar business. You will profit big with guidance established by this World Trade/Mail Order pioneer.

B.L. MELLINGER SR.

In the 20s and 30s, Mr. Mellinger built and operated one of America's most prosperous Mail Order/Direct Selling firms. Retiring wealthy, he left a priceless legacy of experience from which newcomers benefit greatly today.

LOUIS G. MELLINGER Early in the century, he foresaw a boundless future in World Trade/Mail Order. He guided his son into a career where the Mellinger family became globally respected leaders of trade expansion and international business.

Start fast in your own profitable HOME IMPORT/EXPORT MAIL ORDER BUSINESS

GOLD CHAINS FOR PROFITS

MEN & WOMEN—Welcome to your exciting, high-income, full or parttime future in Import/Export/Mail Order! Follow the Mellinger Plan as it guides your every step. Nothing has been left to chance. Each easily followed step is based 100% upon many years of successful experience! Your Import/Export/Mail Order business is ideal for one person, family or retirement operation. Age, location, past experience doesn't matter! Unlike most new enterprises, your World Trade/Mail Order business can be started at home in spare hours with almost no overhead... and with tiny capital. The Mellinger Plan opens this exceptional opportunity to you... now!

DOLLS FROM MANY COUNTRIES

Start with choice of 24,221 fantastic import bargains!

MAXIMUM PROFITS WITH MULTI-PURPOSE RADIO LIGHT

BUY BELOW WHOLESALE Always deal direct -- keep ALL profits!

WATCHES —LOW IMPORT PRICES— ALL STYLES

MELLINGER PRODUCT SCOUTS across the world open doors to hundreds of carefully screened foreign suppliers. Members of International Traders (Membership is free when you follow the Mellinger Plan) immediately have access to over 20,000 of today's most startling import values. The Mellinger Plan guides you in marketing your import selections by Mail Order as well as many other ways for quick, easy profits! Deal in one import or many. Even buy one at a time. You always buy below wholesale. You always deal direct cutting out all middlemen... so you keep all profits!

KING TUT PAPYRUS SCROLL "A timeless art treasure of the ancients"

Now you may share personally in this remarkable discovery! An exact likeness of the treasured King Tut Golden Mask. This limited edition of handpainted scrolls is a fabulous import to be enjoyed for all time!

Start without product investment! The Mellinger family developed and refined a unique drop shipment plan in wide use by today's International Traders Members. Ideal for the newcomer with limited capital. The Mellinger Plan shows exactly how to do it, starting the very day you receive the Mellinger Plan! [illegible] Ship, suppliers are revealed [illegible]

EXHIBIT D Complaint 1554 CORPORATION, ET AL.

Complaint EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

Priceless Mellinger worldwide supplier contacts help you CASH IN FAST!

Men and women enjoying greatest success in World Trade/Mail Order...are those offering new products FIRST! A valuable benefit of the Mellinger Plan is free Membership in International Traders. This exclusive worldwide organization immediately puts you in direct touch with leading innovative suppliers abroad ready to do business with you!

Mellinger Executives and Scouts travel widely, visiting suppliers, factories and handcraft centers, negotiating best below-wholesale prices! I.T. Members get news of product discoveries quickly! You turn over the job of product searching to the experts!

Membership starts you at once with free import samples plus everything needed to turn your samples into profitable orders. Next, you get exclusive Trade Agreements with top overseas suppliers, offering hundreds of fast-moving imports you can deal in right away.

You receive Trade Opportunities magazine (published bi-monthly)...available only to I.T. Members. Each issue reveals brand-new product discoveries. You contact suppliers directly. Every penny of profit is yours to keep!

Fantastic bargains to be turned at once into big profits! With this global organization working night and day, International Traders Members have almost unlimited sources of dazzling new imports.

[illegible]

The Woman's Role

In World Trade/Mail Order

Import/Export offers success and profit to anyone with ambition and ability to make good. Women have a very special "sixth sense" about choosing products to offer by Mail Order and other ways we show you...especially imports needing the "feminine touch." Husband/wife teams have created many highly successful businesses.

Enjoy all the benefits of being your own boss in your own part-time or fulltime home business

START WITH CHOICE OF 24,221 TODAY'S HOTTEST NEW PRODUCTS! Hundreds more discovered every month!

PROFITS...SECURITY...INDEPENDENCE! How often have you talked about getting into your own business? Now think seriously about your opportunity to start...quickly ...in your own home Import/Export/ Mail Order business. No employees to hire or pay. Little or no investment in products. Even keep your present job income while operating in spare hours. No store or warehouse to rent. For your fastest possible start, the Mellinger Plan reveals how to handle orders without putting up a penny of your own money. Everything you will do is based 100% on positive, proved practical "doing!" Our founder started with almost nothing, determined to "make it on his own!" He drew on experience of his successful forebearers. His hard-earned methods are yours to follow in the Mellinger Plan! You can start in the garage or at the kitchen table. Our family did! Avoid usual newcomer's costly mistakes thanks to the Mellinger Plan! Remember...dealing DIRECT means you keep all the profits. More money to save and work with! Carefully screened suppliers in Africa, Italy, Austria, Germany, Latin America, Asia, Australia and many other lands...prefer to do business with International Traders Members. We find the Imports. You pick them. The Mellinger Plan shows how to sell by mail and many other ways. You can't get rich working for someone else. You CAN make it big being your own boss in your own business as so many I.T. Members have proved!

Your bi-monthly Trade Opportunities magazine brings contacts with hundreds of suppliers. Many can be sources for personal use. Save on offers of watches, cameras, furniture, tools, electronics, etc. Always save the International Traders way! Products like these you buy DIRECT:

COMPUTERS DIAMONDS SECURITY PRODUCTS BEER STEINS AUTO ACCESSORIES DINNERWARE CHRISTMAS GIFTS GERMAN CLOCKS COSMETICS TELESCOPES CUTLERY SETS FISHING RODS ELECTRONIC GAMES SPINNING REELS ATHLETIC GEAR WATCHES CERAMICS RADIOS

Turn Import Values Like These Into Immediate Big Profits!

TRAVEL OPPORTUNITY Go abroad if you like! Travel to locate products on your own and deduct travel expenses. Plan includes complete details. Combine business with travel to Europe, South America, Asia for supplier contacts. I.T. Membership assists in recognition, assures a warm welcome. The IRS can be contacted for advice regarding individual cases.

They provide useful information.

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

You are never alone when you follow the Mellinger Plan

The Mellinger Team is ready to help you make money! Here are some of the key International Traders staff... totally dedicated to helping ambitious men and women get a fast start to World Trade/Mail Order profits. Experts in all aspects of World Trade/Mail Order work for your success. Discover what this team can do for you... send for the complete Mellinger Plan to examine seven full days in your own home!

PIRI COLLINS World Trade Consultant Whether you need advice on just starting out, or have a question in one particular area, Piri has your answer. You may call or write any time!

LAURA SELBERG World Trade Consultant Ask Laura... and know you are getting the most accurate answers to your questions. You may contact her by phone or call for an appointment.

HAL TAYLOR Vice President/CFO As Mellinger Comptroller, he brings many years of financial experience that can assist in dealing with raising operating capital for your business.

KRISTIN LARSON Office Manager Mrs. Larson's managerial skills keep The Mellinger Co.

operating at top efficiency. She will speed your call to I.T. Headquarters.

ALBERTA KURGAN Import Assistant Her background in World Trade helps you create vital contacts with important overseas suppliers. Seek her advice on any World Trade topic.

B.L. MELLINGER III President/CEO The Mellinger Co. Drawing upon wide foreign travel and four generations of Mellinger family accomplishment, he brings expert guidance you can turn at once into profit. He contributes personally to Trade Opportunities magazine.

CHRIS HARDENBROOK Import Manager Supervises vast corps of Mellinger Global Product Scouts. One of the world's most knowledgeable experts on import product sources.

LISA M. GARCIA Advertising Manager Her advice guides you in advertising your Imports for peak Mail Order sales and profits.

Lisa is always ready with answers.

JOHN ORBANKO Sales Director John manages all marketing and sales activities for peak results. He passes his expertise on to you by closely working with I.T.

Consultants.

JOHN MORGAN Mail Order Publications Benefit from his wide contacts with import publishers.

Learn from him when, where, how to run your Mail Order ads for most profitable results.

Take a tour of the vast International Traders WORLD HEADQUARTERS Your guide: famed motion picture/TV star and I.T. Member Richard Anderson

Personal help and service you can [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

Complaint EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

SUCCESS STORIES in World Trade! Read these ACTUAL REPORTS of MONEY- MAKING...told by Members of INTERNATIONAL TRADERS

There's no sure way to judge a product or service. That is to get the opinion of users. These original letters are on file in our offices. They are not the usual "testimonials." They show the confidence coming from being well informed. The same Mellinger World Trade/Mail Order Plan and same individual Consultation Service that guided these Members of International Traders is available to you!

International Traders

Bob and Margaret Evans Recovering from a job related injury, Mr. Evans sought a part time business he could start on a shoestring. He found his answer in the Mellinger Plan. He and his wife, Margaret, devote just one or two days a week to their business and report first year Sales of $55,000.00 including a single day's order of $3,000.00! They now serve about [illegible] customers and are "trying for a million!"

Ademola Ogunbanwo Using advice from the Mellinger Plan and exhibiting at Mellinger Trade Shows, this Nigerianborn inventor has turned the tide of success in his direction. His first year brought $30,000.00 and recently had sales of $41,920.00 in a single day! About International Traders he states, "It is the best organization in the business world."

David Stoltenberg After eleven years as an executive for a steamshipline, Mr. Stoltenberg learned much about World Trade. Using Mellinger advice, one of his products enjoyed Mail Order sales of more than $13,000.00 without his spending even a single dollar on advertising. His single day's sales have run as high as $32,000.00 and anticipated sales of more than $450,000.00 in the coming year.

C. Richard Carpenter "I learned more at a Mellinger World Trade/Mail Order Seminar than I did in an eight week course at a local college! Since the Seminar I make it a point, before making any important decision, to look to the Mellinger Plan."

Brian Winch Mr. Winch used the Mellinger Product Research Program to locate a source for his "Litter- Catch", a cleanup tool used in his business. Using Mail Order techniques taught by Mellinger, he marketed "LitterCatch"

and a janitorial sales plan, "Cleaning For Cash". The result? $200,000.00 annual sales!

Fred Olivo Concentrating on imported sports equipment, Mr. Olivo took in $35,000.00 the first year, devoting only a few hours a day away from his fulltime men's hair salon. At age 61, Fred Olivo now knows his future is secure, and profitable!

Kirk Yager Mr. Kirk Yager states, "My business helped me buy my own home when I was just 23. I took in $10,000.00 in one weekend selling toys now available direct from abroad. Thank you Mr. Mellinger for your help and guidance."

Stewart Heatler & Tony Schwartz These two gentlemen received Free Advertising by following Mellinger advice. This publicity brought profit of $12,000 in only 10 days! About the Mellinger Plan, they state, "The World Trade/Mail Order Plan has given us a very real sense that dreams can be had as reality. It is the most comprehensive plan of its kind. We are truly grateful for not only the Plan itself, but to the staff at Mellinger also."

Nicole Allen This 26 year old former private secretary knew exactly what she wanted when she contacted The Mellinger Co., "I wanted my own business and I wanted to make money!" In two months after starting with a borrowed $500.00, she had paid off her previous bills and in six months made $45,000.00! She gives the Mellinger World Trade/Mail Order Plan and her Membership in International Traders great credit for her rapid success. Do it this way, she says, and "anything can be done!"

Pat Almong Marketing her own creation, the "Wacky Umbrella,"

Pat reports a single day's sales as high as $1,700.

Estimated earnings in the next 12 months...$50,000.

to $80,000.

MEN—WOMEN Each of these successful I.T. Members started as a World Trade/Mail Order newcomer. The Mellinger Plan changed their lives...bringing success, money, security! We invite you to examine the Mellinger Plan for 7 full days. Discover what The Plan holds for you!

Why Imports are best for Mail Order!

Imported products bring you two vital requirements for Mail Order success...low cost and distinctive appeal. Many imports come from countries where people work for $4. a day. Cost is low. You make giant profits marking up prices many times. Imports come from countries of different backgrounds and cultures. They offer newness and unique appeal. Their low prices, fresh ideas and top quality are snapped up by Mail Order buyers.

Mail Order is the ideal business to start in spare hours...with only a tiny investment. You can operate from anywhere...in hours you choose. Go after orders from coast to coast...which means your prospect for profit is just about unlimited. Discover the thrill of opening piles of envelopes containing orders and money!

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN Your very first day Start Importing — Start Making Money A Complete Business Plan — How it Works for You . . .

The day you open the Mellinger World Trade/Mail Order Plan, you can make your first Import transaction. Do it within 10 minutes! That's a fact! Instantly, you get the feel of this exciting business. You get everything needed to make money fast, including free Membership in International Traders. At once, you are in direct contact with suppliers all over the world! We show you how to get high-profit orders by mail, from stores and individuals, at swap meets...many ways to make money. THE MELLINGER PLAN is a complete business plan you put to work from the day the mail carrier delivers it!

Personal Step-by-Step guidance It's like having experienced friends at your side! If you have a question about suppliers, products, advertising, printing, shipping...anything about your business...just pick up the phone. A skilled counselor is ready to help. Also you will be invited to personally conducted Mellinger Seminars near your home for individual guidance!

FREE Specialty Merchandise Catalogs As your business grows, you may want to expand your lines. One way is to profit with products offered by local merchandise jobbers. International Traders Members get sources for merchandise catalogs...free. You will deal directly with these sources without paying a fee for the privilege of buying wholesale.

Sources for U.S. Manufacturers As a Member of International Traders, you may contact domestic manufacturers for products in which you can deal. Products like cosmetics, vitamins, clothing, tools, auto and garden supplies...take in many millions of dollars annually in Mail Order. Cash in on this bonanza with Mellinger contacts.

We show you how to set up shop without paying rent or employees...how you can use the very same Plan that developed Mellinger World Trade/Mail Order business bringing in many millions of dollars!

COMPARISON PROVES MELLINGER WORLD TRADE/ MAIL ORDER BUSINESS PLAN Gives you everything you need for quick start to profits...

The Mellinger Plan comes from four highly successful generations of one family— a name instantly associated with World Trade and Mail Order. When you look at the facts— when you ask questions... you discover quickly why so many ambitious men and women succeed by following the Mellinger Plan. Compare...then decide.

ASK THESE QUESTIONS—INSIST UPON ANSWERS—THEN DECIDE | QUESTIONS | [illegible] | [illegible] | [illegible] | [illegible] | [illegible] | | Can you start with at least 24,000 products? | No | No | No | No | No | | Can you choose from 1000 of new products every other month? | No | No | No | No | No | | Will you have global computer product searching? | No | No | No | No | No | | Will you have full-time consultants to answer your questions? | No | No | No | No | No | | Will you be invited to personal World Trade and Mail Order Seminars? | No | No | No | No | No | | Will you be invited to an annual Trade Show/Convention each year...talk personally with suppliers? | No | No | No | No | No | | Will you have to pay a fee for the 'privilege' of buying products? | Yes | No | Yes | Yes | Yes | | Will your name be given to leading overseas suppliers, opening doors to exclusive deals? | [illegible] | No | [illegible] | No | No | | Will you get selling materials [illegible] copy, photos, sales [illegible]? | [illegible] | [illegible] | [illegible] | No | No | | Will you get free Membership in International Traders worldwide organization? | [illegible] | [illegible] | [illegible] | No | No | | Will you get actual sample imports for test [illegible]? | [illegible] | No | No | No | No | | Can you order supplies at special low prices: letterheads, invoices, envelopes, cards? | No | No | Yes | Yes | No | | Can you get FREE Mail Order ads in national magazines not available to outsiders? | [illegible] | [illegible] | [illegible] | No | No | | Will you get a private list of Trade Opportunity [illegible] product leads and profit [illegible]? | [illegible] | [illegible] | No | No | No | | Will you be able to deal directly [illegible] cut costly middlemen? | [illegible] | [illegible] | [illegible] | No | No | | Will you be able to buy [illegible] products at special, direct prices? | [illegible] | [illegible] | [illegible] | No | No | | Can you start without investment in products? | [illegible] | No | No | No | No |

EXPORTS BOOMING! Get your [illegible]...

Dramatic world changes open amazing opportunities for Exporters. From flower seeds to bulldozers...from a few dollars to millions! The Mellinger Plan shows how to contact buyers and manufacturers of products needed in other countries. We tell you what products are needed...who needs them...your Exporter's [illegible] could be [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER — BUSINESS PLAN — Everything you need to know to Start Fast for Big Profits —all this is yours the day you join INTERNATIONAL TRADERS

Yours FREE as a member of International Traders 6 Valuable Exclusive Trade Agreements You don't have to invest a penny in merchandise [illegible] you receive [illegible] Trade Agreements for thousands of [illegible] from many overseas suppliers in leading [illegible] trade centers. Every detail is revealed. So [illegible] the Mellinger Agreements you should [illegible] be ready to make profitable sales. Get [illegible] for drop ship costs on single imports [illegible] as quantity prices for the entire line. Exact [illegible] selling tips are included

Personal Consultation and Guidance [illegible] of the important services included with the Mellinger Plan is the privilege of consulting with [illegible] experts as your business progresses. Our staff of skilled specialists is ready to help you. Call on us for individual guidance in importing, exporting, advertising, sales, record keeping, Mail Order and any related topic. This service alone may be worth many times the cost of your Plan.

Many imports we discover are available to you in small quantities — even one at a time. You can start by ordering samples or just a few imports. As the money rolls in, you can expand, ordering larger quantities at even lower, direct, below-wholesale prices. Compare your import bargains with department store prices. Think of the giant markup! You can start your small business at home, supplying stores, friends and others seeking exciting new products but don't know where to find them!

FREE SAMPLE IMPORTS with I.T. Membership. Show and start taking orders the day they arrive! These actual sample imports are a Mellinger Plan PLUS. We send them to you for one important reason... to give you an instant start to profit. Show your samples and take orders right away. Let people see these unusual imports from faraway places... get their reaction of delight and wonder! With each import comes full supplier ordering directions which help you introduce other imports in the high-profit lines from which they are selected. These imports give you a quick start in your newly established World Trade/Mail Order business.

Make DROP SHIPMENTS from abroad without investing in stock Here's how this unique plan works: (1) Merely show samples (or pictures when you sell by mail)... (2) Collect the full sales price... (3) Air mail order to supplier [illegible] you enclose payment only for the [illegible] cost. Shipment is made [illegible] direct import basis. Shipment is made directly to your customer. At the time you join International Traders, you get a large I.T. Drop Ship Directory with names and addresses of responsible foreign suppliers who ship individual orders directly to your customers. You invest nothing. You take no risk and get your full profit in advance. Customers love the idea. It's thrilling to get a package direct from Paris or Bombay!

You are invited TO MR. MELLINGER'S PERSONAL SEMINARS NEAR YOUR HOME Your business goals and needs are what we'll be talking about. We meet informally near your home. We get to know each other right away like a family gathering. We sit down together as we answer and discuss your questions. You get advance news of hot new imports and how to sell them. Only I.T. Members are invited to attend. Plan to join us!

PLUS... all these additional Mellinger aids for a quick, easy start in your business!

How to Start in World Trade The basics you need to locate customers, how to handle inquiries, how to price products, all about documents needed, hundreds of other subjects. A vital reference that guides you step-by-step as you start in World Trade/Mail Order. * Membership in International Traders Free Membership arranged. The I.T. Seal on your business cards and stationery identifies you as a Member of this global organization. Opens doors to opportunities tightly closed to outsiders. Entitles you to privileges you could never enjoy any other way. * Invitation to Trade Show/Convention Each year, the giant Mellinger Trade Show/Convention in Las Vegas is host to suppliers and I.T. Members from all over the world. You will be invited. Meet famous suppliers in person... see and deal in over 10,000 newest products... hear famous Mail Order/World Trade personalities. * How to Export for Big Profits Plan shows how export sales are made to buyers abroad... also how to contact manufacturers of products needed in other countries. All profit. No investment. You are continually advised what products are in demand for export with names and addresses. *

Profitable Marketing of Imports Plan gives guidance for doing profitable business by Mail Order and many other ways to turn imports into big money. Direct Selling, Swap Meets, Party Plan, Cart Merchandising and Fund Raising are just some of the ways you can boost your earnings. * 11-Piece World Trade Visualizer Kit Complete set of forms used in World Trade. Includes Quotation and Foreign Order Forms, Bill of Lading, Certificate of Origin, Export Declaration, Consular Invoice, common U.S. and Canadian Duties. Easy to understand as you see them. * World Trade Membership Certificate As you join International Traders, you receive a beautiful Certificate certifying your entrance into World Trade/Mail Order. Frame and hang it on your wall... an impressive symbol of your career. Display your Certificate proudly to all who visit your business. * Big Portfolio of Business Forms Carrying on your business with foreign suppliers and customers, you will need printed forms... letterheads, envelopes, invoices and purchase forms. A large sample assortment is included with I.T. Membership. You may order supplies at big discount.

Your Personal I. T. Member Subscription to TRADE OPPORTUNITIES Magazine Every other month as an International Traders Member, you receive your own personal copy of your official magazine. Features trade leads for hundreds of newest import products, helpful articles by Mellinger World Trade/Mail Order experts and names and addresses of overseas firms seeking export products. Trade Opportunities magazine is available only to I.T. Members for their exclusive benefit and profit.

Complaint EXHIBIT D

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN MR. MELLINGER ANSWERS YOUR QUESTIONS

These are questions most often asked when I meet with International Traders Members at my Seminars. Perhaps you have questions like these. I believe my answers will help you...

Breinerd L. Mellinger III President/CEO The Mellinger Co.

Chairman, International Traders

Q: You say I can start immediately. How? A: The day you receive the Mellinger Plan, you get exact, easily followed instructions for making your first import transaction. You could be making your first supplier contact within 10 minutes.

Q: How soon can I start making money? A: The minute you become a Member of International Traders, I send you actual sample Imports. With these Imports plus supplier introductions I include, you can start taking profitable orders at once. You can operate on my Drop Ship Plan. You can collect your profit even before paying for products.

Q: How do I hear about new products? A: Every other month, you receive Trade Opportunities magazine (exclusively for I.T. Members)... revealing trade leads for hundreds of products, plus moneymaking news, ideas and export leads.

Q: Do I need previous experience? A: Not at all! The Mellinger Plan is a complete home business plan. Follow it and you have everything you need to start and operate your business. Successful I.T. Members come from all walks of life... all ages... all kinds of backgrounds. Your sincere ambition to make money is what's really important!

Q: Does Mellinger import and export? A: Indeed! Our warehouse receives almost daily shipments from abroad, filling orders for contacts who have depended upon us for decades. Our World Trade activities place us in an enviable position to inform I.T. Members about what's really going on.

Q: Is my I.T. Membership renewable? A: Yes, you can renew Membership. We have many Members with I.T. service records of 25 years or more.

Q: Do I need a lot of capital to start? A: Probably no other business can be started with so little... and pay off so big! Following the Mellinger Plan, you actually need no investment in products. Later, as you grow bigger, you can stock your products for quick delivery.

Q: Can I start without quitting my job? A: Yes, most newcomers start at home in spare hours. Keep present income while building your World Trade/Mail Order business. Consider going full-time only when you are ready.

Q: What if I have questions? A: It's unlikely because The Plan is so up-todate and revised constantly. Still, if a question does come up, the Mellinger Consultation Staff will promptly answer your question by phone or in person.

Q: Do you check suppliers personally? A: Mellinger Executives and Product Scouts visit suppliers and factories in overseas trade centers. We spend large amounts of money doing this. When you see a product offered in Trade Opportunities, you know the supplier has been carefully checked first!

Q: Can I deduct foreign travel from my taxes? A: As an active I.T. Member, you are in business. The tax laws permit deduction of businessrelated travel for the purpose of meeting and dealing with overseas suppliers... or any expense having to do with your Import/Export business. Remember, you do not have to travel unless you want to. The Mellinger Plan does the hard work of product searching for you.

Q: What are the opportunities for women? A: Exactly the same as for men! I.T. Membership includes a large proportion of women and husband/wife teams earning fine part-time and full-time incomes!

Now—let us send you this 5-Volume World Trade/Mail Order Plan Examine the Plan 7 Full Days Before You Decide

In these pages, you have read many facts about exciting opportunities for starting your own Import/Export/Mail Order business from home. You have read about ambitious men and women who profited spare-time and full-time following the Mellinger Plan. You've learned how we help you get started... how we invite you to join International Traders for exclusive direct belowwholesale import offers. But we do not ask you to make a decision on this information alone. See

The Plan for yourself... read it... discover how complete and easy it is to follow. We invite you to send for the Mellinger World Trade/Mail Order Plan (all 5 volumes) to examine for 7 full days in the quiet of your home. Then, and only then, decide if this is the opportunity for profits, security and personal success you have always looked for. We know from generations of experience we can help you win fortune in your own business. But it is you who must decide that

Seeing is believing... and understanding! That's why we will send you the Mellinger Plan on a 7-day examination. Examine The Plan... find out what it can do for you!

Here is just a partial list of subjects and guidance you'll discover in the Mellinger Plan. We invite you to inspect the complete Plan... see everything for yourself:

• WELCOME TO WORLD TRADE/MAIL ORDER • TURNING IMPORTS INTO PROFIT • HOW TO IMPORT BY DEALING DIRECT • STARTING AN IMPORT MAIL ORDER BUSINESS • HOW TO MAKE UP LOW-COST MAIL ORDER ADS • HOW, WHEN, WHERE TO RUN MAIL ORDER ADS • HOW TO SELL BY DIRECT MAIL • SELLING IMPORTS THROUGH DIRECT SALES REPRESENTATIVES • OTHER PROVEN WAYS TO MARKET IMPORTS • HOW TO START WITHOUT PRODUCT INVESTMENT • HOW TO BECOME AN EXPORT AGENT • EASY BUSINESS RECORD KEEPING • WORLD TRADE CORRESPONDENCE • WORLD TRADE BANKING PROCEDURE • HOW TO HANDLE MAIL ORDERS • HOW TO GET PROFESSIONAL AD HELP FREE • FREE ADVERTISING IN NATIONAL PUBLICATIONS • HOW TO TRAVEL ABROAD TAX FREE • MEETING WITH SUPPLIERS FROM OVERSEAS • HOW TO PRICE IMPORTS FOR TOP PROFITS • COMPLETE WORLD TRADE REFERENCE SECTION

Mail 7-Day Home Inspection Request... NOW

Complaint EXHIBIT D

Follow The Mellinger Plan to World Trade/ Mail Order Profits We are ready now to help you get your fast start in your own profitable business... THIS IS YOUR DAY OF DECISION

There comes a time when success hinges on a decision...a change in life's direction. Perhaps you are at that turning point now...

How often have you heard people say—"IF only I had gone into real estate before prices started shooting up" Or "IF I had only known how well this or that would sell...I could have made a fortune." Usually decisions like that call for risk and big investment that may not turn out at all. I am ready to remove the risk from your decision today. It's like having your cake and eating it, too.

Your decision...today...to enter the world of World Trade/Mail Order is ONLY TO LOOK AT THE MELLINGER PLAN. I do not want you to obligate yourself in any way whatsoever. Just look and consider. This could be your opportunity to look back in years to come and

say, "I got my start the right way...struck it rich...not only in money, but in all the good things of life!"

You will be taking your first all-important step by filling out and mailing the enclosed Home Inspection Request. In return, I will send the Mellinger World Trade/Mail Order Business Plan to inspect and discuss for seven full days.

We take the risk...you have a whole world of opportunity to gain. All that stands between you and an active role in this great and exciting business...is your decision to look at the Mellinger Plan. Make that decision today. Mail your Home Inspection Request now!

Start small at home...as others did... move ahead when you are ready

MAIL HOME INSPECTION REQUEST NOW ...IMMEDIATE ATTENTION ASSURED Only Mellinger gives you this MONEY-BACK AGREEMENT

It's only fair and right! Purchase of a product or service should come with an agreement to refund your money if you are not satisfied. The Mellinger Co. does this without question...for a very important reason. We want you to be sure you are not only pleased with the Mellinger Plan but that you know you can be a success. Read the Money-Back Guarantee. It is offered for your protection.

THE MELLINGER CO.

6100 Variel Avenue, Woodland Hills, CA 91367-3779 U.S.A.

POSITIVE MONEY-BACK GUARANTEE Order your Mellinger World Trade/Mail Order Plan with the understanding that you can examine it in your home for 7 days after it has been delivered. If, within that time, you decide for some reason —any reason—that you do not wish to keep The Plan, simply mail it back to us by insured parcel post and we will refund your inspection deposit in full.

The Mellinger Co.

1554 CORPORATION, ET AL. 1167

1108 Decision and Order

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 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 the respondents with violation of the Federal Trade Commission Act, 15 U.S.C. 45 et seq.; 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, 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, 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 1554 Corporation is a California corporation, with its office and principal place of business located at 6100 Variel Ave., Woodland Hills, CA. Respondent 1554 Corporation has traded and done business as The Mellinger Company. Respondent Brainerd L. Mellinger, III, is president of the corporate respondent. Individually, or in concert with others, he formulates, directs and controls the acts and practices of the corporate respondent, including the acts and practices alleged in the draft complaint. His principal office or place of business is the same as that of the corporate respondent.

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

Decision and Order 123 F.T.C.

ORDER

DEFINITIONS

For purposes of this order, the following definitions shall apply:

1. "Mellinger Plan" shall mean the Mellinger World Trade Mail Order Plan.

2. "Business opportunity" shall mean an activity engaged in for the purpose of making a profit. 3. "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.

I.

It is ordered, That respondents 1554 Corporation, a corporation, its successors and assigns, and its officers, and Brainerd L. Mellinger, III, individually and as an officer of said corporation, and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of the Mellinger Plan, or any other product or service concerning business opportunities, 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:

A. That consumers who use such product or service typically succeed in readily starting and operating profitable businesses; B. That consumers who use such product or service typically earn substantial income; or C. Otherwise concerning the performance, benefits, efficacy or success rate of any such product or service,

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.

1554 CORPORATION, ET AL. 1169

1108 Decision and Order

II.

It is further ordered, That respondents 1554 Corporation, a corporation, its successors and assigns, and its officers, and Brainerd L. Mellinger, III, individually and as an officer of said corporation, and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of any product or service, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from:

A. Using, publishing, or referring to any endorsement (as "endorsement" is defined in Section 255(b), Part 255, Title 16, Code of Federal Regulations) unless respondents have good reason to believe that at the time of such use, publication, or reference, the endorsement reflects the honest opinions, findings, beliefs, or experience of the endorser and contains no express or implied representations which would be deceptive or unsubstantiated if made directly by the respondents; or

B. Representing, directly or by implication, that any endorsement of the product or service represents the typical or ordinary experience of members of the public who use the product or service unless such representation is true and unless, at the time of making the representation, respondents possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates such representation. Provided, however, respondents may use such endorsements if the statements or depictions that comprise the endorsements are true and accurate, and if respondents disclose clearly, prominently, and in close proximity to the endorsement:

1. What the generally expected performance would be in the depicted circumstances; or 2. The limited applicability of the endorser's experience to what consumers may generally expect to achieve; i.e., that consumers should not expect to experience similar results.

Decision and Order 123 F.T.C.

III.

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

1. All advertisements and promotional materials setting forth any representation covered by this order; 2. All materials that were relied upon to substantiate any representation covered by this order; and 3. All test reports, studies, surveys, demonstrations or other evidence in their possession or control, or of which they have knowledge, that contradict, qualify, or call into question such representation or the basis upon which respondents relied for such representation, including complaints from consumers or governmental entities.

IV.

It is further ordered, That:

A. Respondent 1554 Corporation shall notify the Federal Trade Commission at least thirty (30) days prior to any proposed change in the corporation such as dissolution, assignment, or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries or any other change in the corporation which may affect compliance obligations arising under this order; and B. Respondent Brainerd L. Mellinger, III, shall, for a period of three (3) years from the date of service of this order, promptly notify the Commission of the discontinuance of his present business or employment, or his affiliation with a new business or employment, with each such notice to include his new business address and a statement of the nature of the business or employment in which the respondent is newly engaged as well as a description of the respondent's duties and responsibilities in connection with the business or employment.

1554 CORPORATION, ET AL. 1171

1108 Decision and Order

V.

It is further ordered, That respondents, their successors and assigns, shall forthwith distribute a copy of this order to each of their operating divisions and to each of their officers, agents, representatives, or employees engaged in the preparation and placement of advertisements, promotional materials, product labels or other such sales materials covered by this order, and shall obtain from each such person or entity a signed statement acknowledging receipt of the order.

VI.

It is further ordered, That this order will terminate on April 14, 2017, 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 had never been 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.

VII.

It is further ordered, That respondents, their successors and assigns, 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 or intend to comply with this order.

Complaint 123 F.T.C.

IN THE MATTER OF

HERB GORDON AUTO WORLD, INC., ET AL.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT, THE TRUTH IN LENDING ACT, REGULATION Z, THE CONSUMER LEASING ACT AND REGULATION M

Docket C-3734. Complaint, April 15, 1997--Decision, April 15, 1997

This consent order prohibits, among other things, the Maryland company and its seven dealerships from obscuring important cost information in fine or unreadable print, from advertising financed purchase or leasing terms that are not available to consumers, and from misrepresenting the terms of financing or leasing any vehicle, the existence of the amount of any balloon payment, or the existence, number or amount of payments for financed purchases. The consent order requires the respondents to make all the disclosures required by the Truth in Lending Act, Regulation Z, Consumer Leasing Act, and Regulation M, and to ensure that the disclosures are noticeable, readable, and comprehensible to an ordinary customer.

Appearances

For the Commission: Carole L. Reynolds. For the respondents: Charles M. English, Jr., Ober, Kaler, Grimes & Shriver, Washington, D.C.

COMPLAINT

The Federal Trade Commission, having reason to believe that Herb Gordon Auto World, Inc. dba Herb Gordon Auto World, Herb Gordon Dodge, Herb Gordon Mercedes-Benz, Herb Gordon Nissan, Herb Gordon Oldsmobile, Herb Gordon Volvo, and Herb Gordon Used Cars, a corporation, ("respondent") has violated the Truth in Lending Act ("TILA"), 15 U.S.C. 1601-1667, as amended, and its implementing Regulation Z, 12 CFR 226, as amended, the Consumer Leasing Act ("CLA"), 15 U.S.C. 1667-1667e, as amended, and its implementing Regulation M, 12 CFR 213, as amended, and the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 45-58, as amended, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, hereby issues this complaint and alleges:

PARAGRAPH 1. Herb Gordon Auto World, Inc. dba Herb Gordon Auto World, Herb Gordon Dodge, Herb Gordon Mercedes- Benz, Herb Gordon Nissan, Herb Gordon Oldsmobile, Herb Gordon