Tru-Vantage International, L.L.C

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

IN THE MA TTER OF TRU-VANTAGE INTERNATIONAL, LLC CONSENT ORDER, He., IN REGARD TO ALLEGED VIOLATION OF SEC 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3798. Complaint, April 1998--Decision, April 6, 1998 This consent order prohibits, among other things, the Ilinois-based respondent from making claims, in radio and television infomercials, about Howard Berg Mega Reading System and its ability to successfully increase an individual' reading speed to above 800 words per minute while substantially comprehending and retaining the material.

Appearances For the Commission: Russell Damtoft, Mary Tortorice, Charluta Pagar, Theresa McGrew and C Steven Baker, For the respondent: David Bradford, Jenner BI?ck Chicago, IL COMPLAINT The Federal Trade Commission, having reason to believe that Tru-Vantage International, LLC , a limited liability company ("respondent"), has violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the public interest, alleges: 1. Respondent Tru-Vantage International, LLC, is an Ilinois limited liability company, with its principal office or place of business at 7300 North Lehigh Avenue, Niles, Ilinois. 2, Respondent has advertised, offered for sale, sold, and distributed products to the public, including but not limited to Howard Berg s Mega Reading, 3, Respondent's advertisements include, but are not limited to program-length television commercials which run for 30 minutes or less and fit within nonnal television broadcasting time slots. Respondent' s television commercials were and arc broadcast on network, independent and cable television stations throughout the United States. Several of the respondent s television commercials are identified as "Vantage Point with host Kevin Trudeau. 4, The acts and practices ofrespondent alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act. Complaint 125 F.TC. 5, Respondent has created, disseminated or has caused to be disseminated advertisements for Howard Berg s Mega Reading, including but not necessarily limited to the attached Exhibit A. These advertisements contain the following statements: Berg: I teach children not just how to read faster but to comprehend, retain and stay focused, , . . So, Mega Reading is a complete accelerated learning system that doesn t just teach you to read quickly, Trudeau: Right.

Berg: On a skimmng level.

Trudeau: Right.

Berg: But to comprehend, apply and use it. Even under test situations. Berg: I'm working with companies like Pfizer, Mobil Oil, that have high tech reading. And they used it because it was easy to retain complicated information. Trudeau: So, even the detailed complicated material, people can read quickly and grasp it and comprehend it and recall it.

Berg: Over long periods of time, Berg: They hired me to train their cditors not only in how to speed read but how to make books easier to comprehend, because my program teaches people how to understand text.

Trudeau Right.

Berg: Not just blur through it.

Trudeau: Folks, if you want more information on Howard's program, Mega Reading program, it s a home study course that you can go through at your leisure and it will virtually release your own super reading speed, mega reading. You ll be able to read almost as fast as Howard. Virtually quadruple, five, ten times your reading speed right now, Ben!: I have a letter here from a girl who has brain damage. Trudeau: Right.

Berg: Brain damage. She was in a car accident and half her brain stopped functioning. It was electrically dead.

Trudeau: Right.

Berg: And she writes, It says that on a coffee break in my word shop, she went three to 600 words per minute. This is someone with severe brain damage. So yes it works for anyone. And you can t get worse than that. Berg: At the end of the workshop, every child and parent had at least doubled except for one.

Trudeau: Uh-huh, Berg: That child was reading at five seconds a page and I quizzed her. Trudeau: Five seconds.

Ber!:: Five seconds a page. And the vice principal was there. Trudeau: And they re reading it? TRU- V ANT AGE INTERNATIONAL, L.L.c. 637 635 Complaint Benz: Comprehending it and retaining it.

Berg: Anybody, In fact, I had a blind student in Huntsville, Alabama, Trudeau: Yeah.

Benz: I swear to you it s true.

Trudeau: Wait a minute. You can t read if you can t see. Berg: She was reading in Braille.

Trudeau: Oh, okay, Berg: And she took the program to learn the memory skils, Because a lot of people when they hear speed reading, they think fast reading. With Mega Reading it's not just fast reading, it s fast learning. Remember what Tommy said, it s a complete accelerated learning program. And what I teach them is storing, retrieving, recalling, focusing, 6, Through the means described in paragraph five, respondent has represented, expressly or by implication, that Howard Berg s Mega Reading is successful in teaching anyone, including adults, children and disabled individuals, to significantly increase their reading speed while substantially comprehending and retaining the material. 7. In truth and in fact Howard Berg s Mega Reading is not successful in teaching anyone, including adults, children and disabled individuals, to significantly increase their reading speed while substantially comprehending and retaining the material. Therefore, the representation set forth in paragraph six was, and is, false or misleading, 8, Through the means described in paragraph five, respondent has represented, expressly or by implication, that it possessed and relied upon a reasonable basis that substantiated the representation set forth in paragraph six, at the time the representation was made. 9. In truth and in fact, respondent did not possess and rely upon a reasonable basis that substantiated the representation set forth in paragraph six, at the time the representation was made, Therefore, the representation set forth in paragraph eight was, and is, false or misleading, 10. The acts and practices of respondent as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commssion Act.

Commissioner Thompson and Commssioner Swindle not participating, Complaint 125 FTC. EXHIBIT A FEDERA TRAE COMMISSION FTC MATTER KO, 942-3278 TITLE: HOWARD BERG' S MEGA READING TELEVlSION il'FOMERCIAL PAGES: 1 THOUGH 31 TRJDEAU COMPLAL'rr ErBIT l.

CCMPL\ :EIT A :: C: \::l ::-;3'::: A , ._.. : . ._.. .: :. .. TRU- V ANT AGE INTERNATIONAL, LLC 639 635 Complaint EXHIBIT A R. AU; Thanks :or watching. m Kevin Trudeau, 2 anc t is is ano the edi tied Vantage Point. How would you like 3 to read 25, DOC words a minute? How about reading an er.t re book 4 Just like is n about twenty minutes instead of te hours? Imagine reading a newspaper or magazine in a fraction of the time it would normally ta Well, my guest today can do st t at as well as comprehend and remember everything. Howarci g is the world' s fastest reader. ' 5 in the Guiness Beok of :;orld Records. s the founder of the Berg Reading Instit te and authcr of Meaa R"ilrh.r9. s been :eatured on virtua:ly thousands of radio 2nd television shews as wel: as written about in literally hund 2ds of newspaper s and magaz nes al around the wer2-c. Howard, thanks fer being my guest today. MR. BERG: Well, it' great to be here, Kev'::1. MR. TRlJD OK, you take a book like this, and how 10:1g would it take you to read it? MR. BERG: Well, top speed. five six u::es. MR. TRUDEAU: Five six minutes.

MR. BERG: been tested. was P-egis Kathie Lee and they gave me a book about that size. MR. TRUDEAG: This would be a g eat book to read, y the way, :or somebody. obviously Warren Buffet is the wor:.c' 23 i greates:: investor.

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Complaint 125 F.TC. EXHIBIT A game when I got there. Instead, they had the a or come on as a sUTFrise to test me ahd see me it I had really learned the book. And I got every question right by not just re ding it, but reta ning and comprehending and focusing.

MR. ':Rt. EAU; New this was Regis ",od Ka':hie Lee, 6 and the book was about t, how 101:'3 book was it? MR. EE Between 2 u and 300 pag2S.

MR. Tr.:;.J And hew long did it t e yo to reac that 9 ! beo.':? EE.c:; I read it like four times sa it took t r.. jtes. I was :.l"'!:.orizing, I w t reading, : fias memor zil fo:: a test.

MR. E. EAU: Wait a minute, let me ke sure I got t1:,:", straight. ':cu took a bool:, it took you tv:er:ty minutes to r2ad it fo r ti es, to memorize it.. Now, here ' 5 the questior. viously, you re the world' 5 fastest reader. ::ou ' re in the .iness Beck of World Records. Is this scmetr-..i:'g that everybody ca:1 do, or is it just a gift that you have? MR. BERG; Let me tell you, someone else asked e that question. I was n Canada, and Oini Petty who s a national talk show host n Canada said the same thing. She said, Heward, it sounds tea good to be tnle that anyone could co it. I said, :3. " ::.ir. i, :r.oW a::eut you pick a few audience merr.re::s, and ycu and ''C::. -:5::C:: :cn Tc::c:,.::c, a;;d we .!.' see ",'ha: :-ap::e 1, r::e:: CCDe :::: rr,: ' ''2: ' ::-2 :::: :;-- 2.S 2. 3 ='''-:2:-- :: :;, ..,. ; ; p.! .. . TRU-VANTAGE INTERNATIONAL, LLC. 641 635 Complaint EXHIBIT A one of the was a professional. Cini :O gDt he slasses, so someone had to run back and ge: them. It' s gcod to have your own talk show. Ar.d at thee d 0: the workshop, Dini had slightly dou=led, and the two other people were close to quadrupling their reading speed.

MR. TRt.'DEAU: That workshop is just a co ple hours. MR. BERG: Less than four hours. And they went on national television in Canada. And Dini went on the air and says Howard' 5 really onto somethir.g. think eve one 10 Car.ada should be using this. And then off the air, she came up to me, and she said, "! have a son, and I wanted to know if the next time you re in Toronto, could my son please ccme to yo workshop, because I think every child should be gett ng these skills. Because I kr.ow how much they helped me. MR. TRtJDEAU; So now your course actually releases a person s natural ability to speed read, MR. BERG; And it' s easy, it' s fun, and it' systematic.

MR. TRUDEAU: re going to test you right now. have over here, by the way, stacks of books, and we ' re gc ng :0 ce, ::est Eeward. The fi st bock I have is by Jerry Spe 'T-; Jerry Spence. I love ::::i5 guy, by ::: 1:; way, fan':astic. And I' m going to glve you.; little pcr::.o:J :r2 ::0:":-.:: ::0 of t:. beok, 1-8warc., d I want you to re.;c. :.t. :33: :.: ' S =c:.

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Complaint 125 FTC. EXHIBIT A ng to quiz im. is is an easy one, we ' 11 sta: eff as an easy O:1e. It' s just about the author. A great bco, it' 5 about the author. OK, now told on, here ' 5 the page, put YOUT ger in there, don t open it yet. ow hold on beca se :. m goir.g e yeu with my stopwatch. , ready? MR. BERG: Yes MR. TRUDEAU; Go.

MR. BERG: Good MR. TRUDEAU; About --. little over four seconds. MR. BERG: I haven t warmed up yet.

. TRUDEAt"; Four seconds? OK, now give me the beok. P.. EERG:

MR. TRlJDEAU: Now you ve read that? . BERG: Yes, I have.

MR. TRUDEAU: OK. Well, m going to test yet. on a couple questions on this thing.

MR. BERG: No problem.

MR. TRUDEAU: All rig!'.':. First thing - - r.ow, by the 19 way, : went through these books that I r goi to be giving 20 Howard and it took me eight hours yesterday. Eecause I we t to the book store, bought a whale bunch of books, and:: said: I just going to b y ra dom beaKs and we re going to test you. i: talks a out e: ::e e:.::: I Okay. ; j, ...... , .. .

TRU-VANTAGE INTERNATIONAL, L.L.e. 643 635 Complaint EXHIBIT A MR. BERG: Yes, it did.

MR. TRUDEAU: Give me a couple of t.he people. MR. BERG: There were two. There was Randy Weaver MR. TRUDEAU: Right.

MR. BERG: d Imelda Marcos.

MR. TRUDEAU: COrrect. Wr.ere does he Ii ve? MR. BERG: Jac!;son Hole I wyoming.

MR. TRu EAU: C'::!rect. d he has a wife: 11h :.':' s his wife 1 5 Il:3me? MR. 5ERG: Emma Jean.

MR. TRUDEAU; Correct. Emma Jean.

!v.R. BERG: Yes.

MR. TRUDEAU: A:l right. Hold en I we re gains to -- MR. BERG.: A little slow.

MR. TRUDEAU: Well, a little slow. Okay. We' re 9'0::-". to make it a little bit tougher now. Here r 5 an other book. Here' s another bock. Math Magic by Scott Flansburg. Scott 15 a good friend of mine. re going to have Scctt on the show. He I s the human calcula or.

Now, this book teaches you how to do math calc lations in you:: head. Now, this is go ng to be a good test, folks. Now - - because imagi e :his. What - - the techniques - . the technology that Ecw2rd has -- Eowayd tas t at he teaches people is how :0 e2d CCC 2 a d ctvicusly ecge cwe t c y 1: ::C: ::

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Complaint 125 F.T. EXHIBIT A MR. BERG: And apply it.

MR. TRUDEAU; And apply it. Okay: So, I ' m goi g to ve you a chapter. This is the entire chapter seven. MR. BERG: Ok.ay.

MR. TRUDEAU: m going to time you.

MR. BERG: Cf:ay.

MR. TRUDEAU: Let' s get this cleared out h re. And this is n multiplication tricks.

MR. BERG:

MR. TRUD t:: You I re going to read this. ':,:1 then I' going tc test your m :iplication skills because th is go ng tc teach ycu how to do ultiplication in your head. MR. BERG: I get to use a calculator? MR. TRUDEAU: No calculator.

MR. BERG: okay- MR. TRUDEAU: Okay. All right, hold on. Hold on, I' going to time you. I'll say go. Ready I set, go. (Whereupon, there was a brief pause ile M . Berg was reading the book.

R. BERG: Okay.

MR. TRUDEAU; Twenty four seconds. Twenty four and a half seccnds.

MR. BERG: There was a lot of pages.

. TR:""'9. A lct 0: poses. New, you ' r ll'::1g me h . ::'6: .

: :.: :; : : :: TRU-VANTAGE INTERNATIONAL, L.L.C, 645 635 Complaint EXHIBIT A "f. BERG: I 1 ea:cned it.

MR. TRUDEAU; 'feu learned it? MR. BERG: Yes, and so could you. That I S e whole pair-to MR. TRUDEAU: All right. Well let me test you or. this. is is on multiplication -- it' s on multiplication skills. Okay? MR. BERG: Okay.

MR. TRUDEAU; Let me g ve you a couple of 10 multiplication tables here. Okay. 45 times 45? .. EERG: That would be 2, 025.

MR. TRLi'DEAU; You just did that in your head? MR. BERG; ':r:at I S right. It teaches you how to do it. That' 5 the whole pain MR. TRUDEAU: You den I t have a calculator here by the way? Can we -- Paul, make sure we get that -- I want to ake sure someone g ves me a thumbs up if that' s the right answer. Let me give you another one here.

MR. BERG: It' s right. Okay.

MR. TRUDEAU: 75 times 75? MR. BERG: 625.

R. ':R'L"DEAU: I want Paul to make su=e -- g:ve me like e - - we got a th s up the=e? s r.:gbt. ::-1 I-R. 5::,,G: Of C8urse I' IT, r.:gr::. . "7, .. - =0'=::=:: ;::-. ''S: :-. : ... .. . Complaint 125 F.T. EXHIBIT A MH.. BERG: That' s the whole poi t, Kev :;t' sOmethlng everyone shc ld be doing. yO\: know the Ur.iced S':a':es has been ated in 49th position in l acy by the United Nations. I think all our viewers should be ccr.cernec. . They just had a front page story in USA Today about how our education system is failing to teach the students.

MR. TRUDEAU: Uh- huh.

/".R. BERG: Time Magazine talk.eci about the educational crlsis. Even the teachers unions are becoming concerned. Governor Bush has just made the ost highest priority in his second term of office is teaching reading skills, because 25 percent of the children in Texas don I t knew how to read. ':1". i5 15 what it' s about.

I teach c ildren not just how to read faster but to ccrnprehend, re:ai and stay :ocused. Because face it, how many es have you or the people at home take a test or gone to an mportant meeting and got tense. You got :rightened. You go': worried. And all that information that. .ou stored and worked so hard at learning was forgotten.

So, Mega Read ng s a complete accelerated :earn system that doesn t just teach you to read ckly. MR. TRUIEAU: gh:: .

1R . BERG: Cn a skirr,mi:19 level.

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MR. TRUDEAU: Ard it just takes a few short hours to learn. Correct? MR. EERG: Couple of hours. That' s it. MR. TRUDEAU: New, let me ask you a question. There ' 5 been speed reading courses been around for ye rs. MR. BERG: That r 5 true.

MR. TRlJDEAU: Evel . Wood is prob :y the most c: and I' m sure there r dozens oi other speed readi g courses. MR. BERG: Yes, nd some of them 8 quite good. MR. TRUDEAU: But the biggest ch nge most peo found is, number one, it tcc;: days, weeks, rr.:J,. ths ot. pract::ce and training.

MP.. SERG: Absolutely. Hours a C9.y.

MR. ':Rli"DEAU: Rigr.

MR. BERG: With days, weeks and months. :t' s not just days I weeks I and months, but hours a days e2 h of these days. MR. TRUDEAU: So, how is yours dif:erent t an those ::0 that respect? MR. BERG: First of all, =he program takes less tha four hours to :.earn.

MR. T::UI:EAU: That' s i::? MR. BERG: That' s J.t.

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c:-, ..,.. . _. : ..:: . ._. .. Complaint 125 F.T.c. EXHIBIT A MR. ':RUDEAu: :.i;'8 learning hew to ide a bike. . BERG: you never forget how once you k ow how. Once you release it, s there.

MR. ':ii\JEP. You re re:easing someone ' s abi Ii ty. 50, it' s radically di:ferent than these other courses. MR. BERG: Can you cross the street and look at the tr2.==ic and know ' !1ere you re goi::g? Look at all the information that your brain 1:".= to process ::;1 a:: instant. T...:t sam€: brain shc ld be reading .: ook just as e::ortlessly nd that' 5 what: tea.c:,.

MR. TRU:E:AI..: well, now -- 50, these ot er courses t!",at. have been out there, your progr& is a revolutic ary -- it I 5 totally different.

MR. BE?G: Let me tell you a story, !:ev::n. MR. TRL'"EAU; Yeah.

MR. BERG: The former president of Evelyr. Wood, the chai an of Evelyn Wood is Maur ce Thompson, Jr. ., have a letterfrom him.

MR, TRUDEAU: Right.

MR. BERG: Tommy asked me to train him and h s family last September. The fo er president of Evelyn Wood asked me to trai his far:ily. Now this is the r:an who k cws speed rea.cing. R. TRUDEA;;; Right, 3::?G; Eis sen c;..3.-:r-' ..pl-e.d i:-, e ' e:-. :::Cr. ::1 '" 23 -. .-.

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TRU-V ANTAGE INTERNATIONAL, L.L.e. 649 635 Complaint EXHIBIT A mentioned how his grades i mediately shot up from t e previous term. d would you like to read the comment he has cn the .bottom. !' m really proud of this. This is the former president of Evelyn Wood.

MR. TRUDEAU: It says, 1 feel you have moved one step beyond speed reading -- MR. BERG: That' right.

MR. TR'UDEAO: - - to speed learning. Bringing the discipline to the 21st first century.

MR. BERG: Exactly. Now, I' m proud of that. MR. TRUDEAU; , what you re actually have is really a revolutionary break through in what you I ve developed. MR. BERG: Totally different. Now, other programs were mechanical. That' 5 why they took so long. They required repetition. Like learning to type or playing a instrument, to work.

MR. 7RlJDEAU: Right.

MR. BERG: And a lot of people found they loss their speeds almost as quickly as they gained them. MR. TRUDEAU: Right. .

MR. BERG: I read 80 to 90 pages a minute at. my top speed. But I don read 80 to 90 pages a mi every time I J epe:: a beok. Scmetimes wa"t to relax. Someti es I' m a itt :':::2::. . v,'c::t to read in bed.

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Complaint 125 FTC. EXHIBIT A MR. BERG: So, r :Jave t.1.at cpticn. th the ache:: 2 program 5 because it was conditioned, it was a1: or nothing. you s1 wed dO that was the end of you spee2. most people 4 told :: the y set a ve superficial understand g, like a skim.

working with companies like Pfizer (Phonetic), Mobil Oil, that have high tech reading. And they used it because it was easy to retain complicated information. 9 !/ MR. !FTmEAU: So, even the detailed complicated 10 material, people can read quickly and grasp it and comprehend it 11 and recall it.

MR. BERG: Over long periods of time.

MR. TRtJ"'EAU: Now, how about students? Mea"S straight , As with less study time? MR. BERG: Not only do they get straight As with less study time, but think about this, Kevin, they get better self esteem. They begin to =ee1 confident. Now, you spend over 15, 000 hours when you go to school.

MR. TRUDEAU: Right.

MR. EERG: Think about that. Ar,d out of all of these hou s and the people at home think about it, too, how many of those hours did they spend teaching you how to lea 2J I MR. TRt."DEAU: Right.

2.1 MR. 3E::G: T::ey ::3. CI,. sys a:-:: ::::ey ::5 1 ::e' /e:: ;". :=3;:;". 23::::. : , ::.,.. : . , ::g TRU- V ANT AGE INTERNA TJONAL, L.L.e. 651 635 Complaint EXHIBIT A ;.m. . 7R.UDEAL' And peop e obviously i busi ess because you work with virtually dozens of major corpora ions an Fortune 500 companles.

MR. BERG: Allover the country.

MR. TRUDEAu: So, people ca ake more money because there I 5 so much material to learn tod y, so much reading t people have to grasp.

MR. BERG: I nave an interesti g letter here rom Pfeiffer. Pfeiffer is the leading p blisher in the wor: human resource training materials.

MR. TRUDEAU: Okay.

MR. BERG: Every corporate trainer has heard 0: these people.

MR. TRL'1EAt:: Right.

15/ MR. BERG: They hired me to train their editors not 16 only in how to speed read but how to make beoks easier to comprehend, because my program teaches people how to unce=s text.

MR. TRUDEAU: Right.

MR. BERG: Not just blur through it.

MR. 7'UDEAU: Right. .

MH.. BERG: And t e head editor - - t aging edi says here that this prog am that: gave h m gave him a inct .J I' 2.::v2.::tage tC their ishing I'." n I Complaint 125 FTC. EXHIBIT A MR. BERG: That' s the managi edi of the world I largest human resource publisher. Here ' 5 a letter from the York Prep School. The head master is Ronnie Stewart. He r 5 aT'. Oxford graduate. This man knows education.

MR. TRUDEAU: Right.

MR. BERG: u don t get be ter than Oxf rd. And here t it says. :-:award, just 2 note to let you know hew positive he feedback w s of your lectures to the ::th and 12th grades. 50 positive in fact, that w ever it' s con\=nient for you, r would love -- I ike that wcr -- I would lo e for you to come and do the ninth ::..,.j !:2'rth gra::::s on a similar basis. And eddy booked th ON SCREEN: :-ar more info c1'-ll; 800- 2.33- 9666. This is a paid commercial prcsram for Tru-Vantage Interli tiona MR. TRUDEAU: That' s great. Folks, if you want more information on Howard' s program, Mega Reading program, it' s a home st dy course that you can go through at your leisure and it will virtually release your own super reading speed, mega reading. You ' 11 be able to read almost as fast as Howard. Virtually quadruple, five, ten times your reading speed right now. Call the number en yc r screen. And I I ve worked out a special arrangement with Howard. 'll give you an over 50 percent discount ofi the regular pr oe of the prcsram. So, oa:.l ris;ht ;1010 ':0 set SCT:.e mere. :.r.:c::.at:.on 0;: l t. ;C\-. , s cc ..:"L"1 :::'e t-:s::.:::c; i". ::2 . . .. .. : ._ :; .. . . TRU- V ANT AGE INTERNATIONAL, L.L.e. 653 635 Complaint EXHIBIT A another book. How to Win Friends and Influence ecple by Dale Carnegie. Great book. Everybody should read this be ok . Now, let' s see. I went through this last night and I got chapter six and glve us a six. I want you to read the entire chapter quick synopsis of the chapter.

Okay. New, I r m going to time you again. A.'1d folks, the important thing is what Howard is saying is every 5: ngle person -. now, you' ve taught hew many -- what thousands and thousands of people? MR. BERG: T.thousands. Can I say something? MR. TRL"BEAU: Yeah.

MR. EERG: I have a letter here from a girl who has brain damage.

MR. TRUDEAU: Right.

MR. EERG: Brain damage. She was in a car accident and half her brain stopped functioning. It was electrically dead. MR. TR'L"BEAU: Right.

MR. BERG: And she wri tes . It says that on a coffee break in my word shop, she went three to 600 words per minute. This is someone with severe brain damage. So yes, it works for anyone. Ar.d you can t get worse than that. MR. TRUDEAU: At what age, by the way? Howald? MR. BERG: The youngest student I ever had was e a::S: t:-- V:"C'2 was :":1 Tc:c::nto. I W5S doing a live wc:cksh a sc was there w s w::'2. :5 ;". ?, . :) Complaint 125 F.T. EXHIBIT A Ted said, "Howard we would really love fo you to come to OUy 2 e emer.tary scr.oal. My wife and r jus: q.ladr pled. MR. :RUDE.U: Right.

MR. BERG: And we thi k you car. do this for cur kids. I said, how old are they? He said third, f ourtl". grade. I said it' s kind of young. ally, in that age group: teach the 7 memory and learning skills. d I r ye done that all ever the country because a lot of kids aren t reading yet at at age. MR. ':RUDEAU: Right.

MR. BERG: He said, our students are reading and reading well. Let try it. I said, fine. And the parents came. How many things did parents do today with their families? MR. TRL'DEAU: Right, rig!:t right.

MR. BERG: Okay. At the end of the workshop, every child and parent had at least doubled except for one. MR. TRUDEAU: Uh- huh.

MR. BERG: That child was reading at five seconds a page and I quizzed her.

MR. TRUDEAU; Five seccnds.

MR. BERG: Five secor-ds a page. d the vice principal was there.

MR, TRUDEAU: And they re reading MR. BERG: Comprehendi g ic and reta lng it" -='=:A;): All ri;r. I'e ' -:e a.::'S: :0 ::05 :5 s C : s :?:..: . . , . TRU- V ANT AGE INTERNATIONAL, L.L.e. 655 635 Complaint EXHIBIT A MR. BERG: okay.

MR. TRUDEAU: Dale Ca egie ' s How to Win Friends. Reac.y? MR. EERG: Yes.

MR. TRUDEAU: Go.

(Whereupon, there was a brief pause ile Mr. Berg wat. 7 reading the book.

MR. TRL"DEAU; This is am zing. You I re reading it? 9 Okay, give it back. That was about 16 seconds. MR. BERG: Right.

MR. TRUI:9. Okay. Now, tell us -- j:' s: g ve me a quick syr.cpsis af that chapter.

MR. BERG: Well, the cor-cept was make people feel important and do it sincerely. And by the way, Kevin you r re doing an exceller.t job with this shew and I really mean that. MR. TRUD=:U: Thank you very much. Okay, wait -- 17 you re - - the name of that chapter by the way was, How To Get People To Like You.

MR. BERG: By the way, one of my favorite uses of speed readi g is learning new skills super. as I just showed you" MR" TRUDEAU: Right.

BERG; Learning how to use pute or do better= - - a,. ing th relatio ships" , this - - (inat:dible) 24: MR. "ISAU; To ::ea 5:'.:/t."12.::S; '!""l:: "..s 2. oee -:3.:::.-:3.

,,::: ;. ..:;:.

Complaint 125 F.T. EXHIBIT A MR. BERG: Okay, it starts off he s i a pas: office and he see ' 5 a postal employee that he ' 5 family ar with and the guy looks very very depressed and down. And he starts talking to the guy and fi ds out the guy feels that nobody really appreciates what he s doing.

T?UDEAU: Uh- 1:e starts tell'::19 the g'..Y (;0... 7 II "'.R. E::RG: And so, important he i:: and how mt:ch he apprecia.:es him. t'- e: guy 1J 11 just perks L' d he says t:p-t' s what it r 5 all about. Yeu ""ant 10 eople to 1.:);:e you. Let th know how im? tant they are and it I' jj I' improves their',: Eelf .:steem. d they rela e that to YOu the 1"'" ::cause.

MR. TRL EAU: Uh- Now, what - - there was 1-- I principle dis.=ussed in this. . :or.RG: Yes, the principle w s make people feel important and be sincere.

MR. TRUDEAU; Make people feel i portant and - - now you just said almost verbatim. :t says ake people feel important and do it sincerely.

MR. BERG: Well, you ay not set every word. You know when you re going a page and a talf a s cond, you might miss an Okay.

MR. TR:'''EAG; And a tually -- wait a minute. o'ait, we set to do anct er cck cw.

: . ,:

TRU-VANTAGE INTERNATIONAL, L.L.e. 657 635 Complaint EXHIBIT A MR. TR;"''EAU, This book by the way, this is my boo This is my beok, Kevi Trudeau' s, Mega Memory. Everybody should read this book. Eve body go out and get this book. It I 5 my book Mega Memory. Now, it' the first -- you know we sold three and a half million capies of my Meqa Memory program. . BERG: That' s a lat.

MR. TRUDZAU, Yeah, and this is a great book. Just says published by Wi iam Morrow. :t' 5 in all the D ok stores. Call, you can get it.

MR. BERG: Now, make the c ll.

MR. TRtJDt:U: Now, make the call r.o... K:)w, I want you to read j list chapter or.e.

MR. BERG: Okay.

MR. TRLT2AU: On hew to use this beok, and then give a quick synopsis en this. Not that we don' t trust you. Go. (Whereupon, there was a brief pause while Mr. Eerg was reading he book.

MR. BERG: Okay that' s 11 pages.

MR. TRUDEAU: About 16 seconds.

MR. BERG: Okay. And I' m getting clcser to my speed. MR. TRUDEAU; And you read this? You read this? MR. BERG: Yes. It' s first - . it sets the ground n.:les.

141 M.R. ':,,:..::::E. Ar.C anybody who gets s c u=se := ::=.:-. co ''3: c.:::? ? . . . .. . . ::: _ Complaint 125 F.T. EXHIBIT A MR. BERG: Thousands af people are dOlOg what ,; JUs: 1 did.

MR. TR'JEAL': All right, tell me about the book. 4 k cw all about it because r just wrote it. HR. BERG: Okay. I guess you would k ow. This is like Regis and Kathy Lee allover.

R. TRUDEAU: Y€3.:1, the au::hcr. Exactly. OJ:ay. 11 MR. Z)ZRG: Well, it s arts off: l ing ab6ut weat you culd do to develop your memory, bou:: setting up 10 II ::pecific time .;od place to do it, avoidi:: ce:ctain fcods, ..:ow 11 . 'Tuen tlme you should be de::;'.,;, hew to prep"=-e YOl.:rse:"f. A.;1:i 1211 chat' s essentially what the first chapter is about. Getting set. 13 . TRUDEAU: Now, there was four things I tioned. 1411 The four steps you go through. 15' MR. BERG: Yes, there were. Let !r.e think. First there 16 was unconscious i competence, where you do t know what you 17 doing.

"1. TRti'DEAU; Right.

MR. BERG: You don I t even know you den ' t knew what 20 you re doing.

MR. TRUDEAU: Right.

MR. EERG: 7he second one was CCO&ClOUS lncompetence, where you know yeu don k:r. what I re Go: MR.. T;::"""E;;U: Ri.gr.': . :-i.s;:-. , :: .. ,.!: ;,. TRU-V ANT AGE INTERN A Tional, L.L.e. 659 635 Complaint EXHIBIT A was consc ous cc petence, where you know what you re doing but you have to think about it. Sor of like when you re riding a bike and you know you have . to think how to stay on the bike. MR. TRL"IEAU: Right.

MR. BERG: d the fourth step was unconscious competence, where it I 5 at released skill and you I re doing instinctively. You don t have to think about it. MR. TRtJ'"EAU: That' 5 the point I want to falk about. Because your course gets people very quickly to that unconscious competence level where it happens automatically. MR. BERG: In hours. In hours.

MR. TRUDEAU; So, it I 5 like learning how to ride a bike or learning how to swim. You don t have to practice and pract and practice. You re just releasing the skill. MR. BERG: No. I have a story about that. "'.R. TRUDEAU: Hold on for one second because I want to tell people how to get this program.

MR. BERG: Okay. Okay.

MR. TRUDEAU: If people do want more information on Howard I S program The Mega Reading Home Study Course . fo ks, this works for everybody. Thousands of people have gone through Howa::d is the it. I highly encorse and recommend this program. world' s fastest reader. There is nothing OU ther!: like it a:-y..nere :.n t!". wor::d. work :sr ycn ;:bo' ::.t t::: . te.:- " G... :2 a s ";2:: ::: :: : : .::: , Complaint 125 F.TC. EXHIBIT A get it fo them. If you re in business, if you read papers 2 you like to read novels -- MR. BERG: The Sunday paper.

MR. TRUDEAU; You ' 11 learn this infa ation, you ad it quickly and you 'll be able to recall it. C2.11 the number 6 en your screen. And again, we worked out a special arrangement 7 lNith Howard. You will get a 50 percent discount while we re on show. You can call right now and get more information tr, :,s program. So, call the number.

MR. BERG: You mentioned how you don J t have to practice.

MR. TRtJDEAU: Right.

MR. BERG: I have an interesting story. One of my students called me and was really excited. A grandmother and she learned how to do this at my live program and then she didn t use for like six weeks.

MR. TRIJDEAU: Right.

MR. BERG: And with any speed readi g program if you don i t use it for six weeks, you can kiss it goodbye. It' s eve::. MR. TRUDEAU: Right - MR. BERG: He:: g::andscn came to her. He had a book report and he needed her to help him. She read the break in 15 rr:.::u:es. He got arl A. She sa.:d, Howard, I dOrl ' t know he did i:. I tave,, ' t use t:-e prcs=am :.:: s:.x wee:'Cs. 1: operled t:-:e boak and - 5a s w ::.: 5 \,:;. ::.:... :

TRU-VANTAGE INTERNATIONAL, L.L.C. 661 635 Complaint EXHIBIT A about t . You already have the ability. m just showing you how to release it.

MR. TRUDEAU: Well, we re going -- we re going to test 4 you again. I keep testing you because this is really im =essive to me. All right, I got another book here. And I went to the 6 book store and picked these up. Rush Limbaugh, See I Told You So, like Rush by the way. We advertis 2 lot on his S OW. Rush is a reet guy.

2. BERG: Um- MR. TRUDEAU: I have a per5oral ' ;;utographed c=.-;y this book by the way.

HR. BERG: Do you? MR. TRUDEAU: Yes, Rush sent to me. Okay. I want you to read a chapter here. Let me see if I can find the chapter about Rush. We went to Rush. Okay.

MR. BERG: Don' t rush.

MR. TRUDEAU: Don t rush, don t rush. Now, by the way, when I' m finding this chapter - - because I read things last 19 night. Okay? MR. BERG: Yeah.

MR. TRUDEAU: Anybody can do this I mentioned? MR. BERG: Anybody, MR. TRADE.U: And the age -- how old was the eldest !=e:-son at went t this? I h c a wc 2:; yea.:c.: cI._ 00.. Complaint 125 FTC. EXHIBIT A Pasacier. And she teok the program a d I teld them where I was stayi:lg. he next day in my hotel I get a phone call a d I say oh, what' 5 wrong. I said nobody calls me. Everybody J.ear:1S it. /Y. TRL'DEAU; Right.

MR. BERG: I say what' s the problem. She says :'0 6 prc=lem. I just called to tell you her :lame was Ruth. She 7/ says, Howard, I ' ,.nt home after taking your ,program. I' m 83 8 years old and I r;:ad two 300 P::ge books in \,:::::r three hours. m 83 years old.

MR. T2:'"'EAU: Wow.

MR. BERG: Do you know how happy ! am? S1-.e says do:' ' t know how much more time I have left, but there ' 5 so things I want to o and learn and you' ve just ;iven me the tools f:;:: doing it.

MR. TRUDEAU: You know, there are so many books OU t:-.ere with so uch mater al that -- newspapers, publ cations for 17 business people, you knew, magazines, publications ney have to read, books and all these manuals, Learning computers, Thick manuals.

MR. BERG: Thick manuals, MR. TRUDEAU: You know, you were telling me that you learned co puters in one night.

MR. EERG: That' s absolutely tr I bcug t at K- ?rc .Ise:: CC:;, outer befor T:: ::.r5: : I ::; ::::," c :::r : \ ..

TRU-VANTAGE INTERNATIONAL, L.L.e. 663 635 Complaint EXHIB IT A MR. TRlj'DEAU; Right.

!v.R. EERG; I learned Wordstar, DataStar, and Formstar and published an article the next day. d t at' s the truth. 4 Ar.d I 11 tell you a little funny story. MR. TRUDEAU: And anybody can do this, right? MR. BERG; Anybody can do it. )L,d what happened was the margins weren' t perfect and I thought so ething was wrong. 8 And then someone said, do you know it takes 80 hours normally to do what you did in three. And I said I guess I should feel a little bit better then.

MR. TRL"DEAU: Now, by the way, before - - well, I want to do this test. I am going to have one more test. Okay. got one more. This s the chapter. Put your finger in there. m going to get my little trusty -- this is for amazing on the time. Ready? MR. BERG: Yep.

MR. TRUDEAU: Go.

(Whereupon, there was a brief pause while Mr. Berg was reading the book.

MR. BERG: The pages are sticking. Okay. Well, that slowed me down a bi t, MR. TRUDEAU: Okay, yeah. Still about. seccnc.s. MR. BERG: Okay, apologize for at. :-R T;;.L':E.':: Okay, All ::ir;ht. !:' 5 R'.S be::!.. .3: 'N:=.3 ::cc:-:; ::.. . ...... ! . ! . . . Complaint 125 F.TC. EXHIBIT A MR. BERG: The gist was that government' 5 too big. 2 We ve got to make it smaller and vote conse ative republican. Okay. But he really has .3 lot of points. He talks about welfare and how about 27 or 28 cents out of every collar gets to the reciprocate because the rest of that is bei g spent on 6 administration. And that' 5 an example how government waste 7 not helping us.

l-:R. TRUDEAU; And that' s -- when you were on Regis and 9 Kathy Lee, you had the author come in. You read the book. MR. BERG: (Inaudible) .

MR. TRUDEAU; And he gave you very tough questions. MR. BERG: ! still remember one of them. He asked me what did say abau t let' 5 see. asked several questions. asked what did he say abau t the Pirates Penzance - was trick question. The bock wa, called Going 16 Movies and it was a vig ette. Every two pages was another movie. 17 So, it wasn' t a story. It was hundreds of little movie vignettes.

MR. TRUDEAU: Right.

MR. BERG: And I said, Craig, that' s a trick question. Because it wasn - there was chapter in there about a different 22 movie and the Pirates of Penzance was used as an example of how if the cirectcr had used :he tecb ique5 of Pirates of Per.zar.ce ! lI:::en;: s;:e of e te e5 he a.c. c:"ose:". :"5 :7cv:.e would .0 - - -"

:;\ . ::., TRU-VANTAGE INTERNATIONAL, L.L.e. 665 635 Complaint EXHIBIT A trick me because that wasn even what the cha9ter was about. R. TRUDEAU: So, anybody can do this? MR. BERG: Arybody. In fact, I had a blind stude t i Huntsville, Alabama.

MR. TRUDEAU: yeah.

MR. BERG: I swear to you it' 5 true.

MR. TRUDEAU: Wai t a mhmte. You can I t read if you can see.

MR. BERG: She was reading in Braille.

MR. TRLi)EAU: Oh, okay.

MR. BE::G: And she took the program t learn the memcry skills. Because a lot of people when they hear speed reading, they think fast reading. With Mega Reading it I s ot just fas reading, it' s fast learning. Remember what Tom said, it' 5 a complete accelerated learning program. d what I teach them storing, retrieving, recalling, focusing. Here I S a important skill. Knowing wh t to look fc How many times have you studied for a test - - people at home. You study for a test, you take the test and none of the questions you studied are asked. Everything else they ask. You go to an importa t meeting and everything you thought was important was not as:",ed.

23 i ''el1, i: you don I t know what to leok for, you e go '" I :0 c:.:SS 1.: A.-:c I :;:.00:: !'. to figl.::e cut at to loc !'C' you ' ::e I was just: -- ,, ,_ ::.,..., : ::. ( : :;, :::::: _.. Complain! 125 F.TC. EXHIBIT A interesti g to note beca se obviously there are so many books out the e, like Wealth Without Risk by Charles Givens (phonetic! which is a phenomenal book, How to Attract yone &,y e by Susan Raven (phc:,.etic), Les Brown (phenetic), Live Your Dreams. There are so many phenomenals out -- ary I:. Ash (phenetic) and ..e can I t do l: 0= these.

1 - M.. BERG: No.

. T:".UDEAU: (Inaudible) .

XR. BERG: I could.

loll Kr. '!r.1JEAU: Yea.:;. 1!1' Wel: that' s -- this is the amazi g thing. H:J'" c.'Jout ;; learning David Letterman s top ten list. 1311 . B!:RG: did a show America I 5 :alking about a year 1411- c7O They had e read 18 700 page books in an hour and a alf I - ' 15 I d they iz=ed me on them and I get every e5tion right. MR. '!Rt"'EAU: Well, like -- I got Larry King' s book. got Bill Gates book. I got Colin Powe:l. I got -- ::0\.0, the Interr.et for Dummies if people want to lear how to ru the Ir.ternet. I get - - here s magazines.

MR. BERG: By the way I Forbes Magazine just did an article en this.

. TRUDEAU; No kiddir.

MR. BERG: Forbes said :his is a wonce::rul pros=am ::or ' business people.

;Q" - ::;:c -:2 N2W :2::. 2:: , : ?, .:: . .._ .. TRU-VANTAGE INTERNATIONAL, LLe. 667 635 Complaint EXHIBIT A - - now, hew about biology. I mean leon. at -- folks,- look these books. Ard I' m putting these all in front me JUs to show yeu the point here. Calculus. Now, you re telling me -- this is wha t kids have to go through in school. MR. BERG: Right.

MR. TRUDEAU: Look a t this book. They have read this. You re telling me - - I know this is a mess here. But if a person calls and g ts ycur program, they 'll be able to go through these 9 books. Now, let I 5 be honest here. I got all these books here. P 5 See if you can get a wide shot of this. : got Howard Stern book. I was invited to Howard Stern s birthday party. MR. BERG: I read his book Private Parts in s x minutes on Comedy Central and then he tested me on the book and I got it right.

MR. TRUDEAU; Howard did? MR. BERG; Right.

MR. TRUDEAU: Howard did? MR. BERG: I was on John Stewart' (phonetic) shpw and Howard was the guest. He had just written Private Parts. It' as thick as this book.

MR. TRUDEAU: Right.

MR. BERG; :t took me I think six and a al: minutes to reac and then he quizzed me and I got all the est:or.s scmetccy . a - i M,,. L--::_ Ckay. ""; :1 - t::==:.:;!1 eve::y::::r.g that' s C ;:es:-: i g :: : :_ ;: , .:. Complaint 125 FTC. EXHIBIT A New York Times, all ttese books, how long would it take hem to do that? First it takes them a few hours to learn the technique. Right? MH. . BERG: 1 would -- it just takes abo t three three, four hours to learn the techni ,'R. TRUDEAU; Norr.ally it would take, what, a week? 7 Two, three week::? A hundred hours to learn a:l this stu:f -. to 8 go through all this stuff? MR. Eie:RG: I would say for the average person that wauld be being kind.

MR. TRUIEAU; So, maybe 150 to 200 hours ( MR. BERG: d say several months for some of the science books for certain people.

MR. TRUDEAU: That' 5 right because that' 5 all scientific.

M.'!. BERG: It I 5 not just light reading there. MR. TRUDEAU; A person calls and gets your program, how long? MR. BERG: I'd say you CQuld do that eas ly in at least a month tops. Two weeks to a month depending upon your background.

MR, TRUDEAU: Folks, you heard this, You can call right new, get Heward' pr::gram It takes just a fe short ho'-"=-s It:' s easy. It' 5 :'.:1. ocy ca:: ce You :il ze t!'e 5: G 2=5 :5: ::s '0';': : ::-. :""2SS S ': '..c::: TRU-VANTAGE INTERNATIONAL, LLe. 669 635 Complaint EXHIBIT A time. You ll make more mor.ey in business because you ll be able to remember all the information. Call the nuw er on you screen. You'll get a 50 percent discount to boot. This is Kevin Trudeau, thanks for watching. This has been another edition of Vantage Point.

ON SCREEN; For more information or to orc=r Eoward 7 Berg I 5 Mega Reading call: 800- 283-5666. Tru-Vantage Internation 7300 Lehig Avenue Niles, IL 60714 (847) 647- 0300.

The praceedir.g has been a paid advertise ent for Tru- Vantage International.

Cibereupon, the taping was concluded.

Decision and Order 125 F.TC. DECISION AND ORDER The Federal Trade Commssion having initiated an investigation of certain acts and practices of the respondent named in the caption hereof, and the respondent having been furnished thereafter with a copy of a draft of complaint which the Chicago Regional Office proposed to present to the Commssion for its consideration and which, if issued by the Commssion, would charge respondent with violations of the Federal Trade Commssion Act; and The respondent, its attorney, and counsel for the Commssion having thereafter executed an agreement containing a consent order an admission by the respondent of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondent that the law has been violated as alleged in such complaint, and waivers and other provisions as required by the Commission s Rules; and The Commssion having thereafter considered the matter and having detennined that it had reason to believe that the respondent has violated the said Act, and that complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of sixty (60) days, and no comments having been filed thereafter by interested parties pursuant to Section 2.34 of its Rules the Commssion hereby issues its complaint, makes the following jurisdictional findings and enters the following order: I. Respondent Tru-Vantage International, LLC, is an Ilinois limited liability company with its principal office or place of business at 7300 North Lehigh Avenue, Niles, Ilinois, 2, The acts and practices of the respondent alleged in this complaint have been in or affecting commerce, as "commerce " is defined in the Federal Trade Commission Act. 3. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is in the public interest.

ORDER DEFINITONS For purposes of this order, the following definitions shall apply: I. Competent and reliable scientific evidence shall mean tests analyses, research, studies, or other evidence based on the expertise , TRU-V ANT AGE INTERNA TJONAL, L.L.C 671 635 Decision and Order 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, 2. Unless otherwise specified respondents shall mean Tru- Vantage International, LLC, its successors, assigns, managers and each of its agents, representatives and employees. 3, " Commerce shall mean as defined in Section 4 of the Federal Trade Commission Act, 15 U, C 44.

It is ordered That respondent, directly or through any corporation, subsidiary, division, or other device, in connection with the labeling, advertising, promotion, offering for sale, sale, or distribution of Howard Berg s Mega Reading or any substantially similar product in or affecting commerce, shall not represent, in any manner, expressly or by implication, that such product is successful in teaching anyone, including adults, children and disabled individuals, to increase their reading speed above 800 words per minute while substantially comprehending and retaining the material. For purposes of this Part substantially similar product" shall mean any product that is substantially similar in components, techniques composition and properties.

II.

It is further ordered, That respondent, directly or through any corporation, subsidiary, division, or other device, in connection with , sale, orthe labeling, advertising, promotion, offering for sale distribution of any product or program purported to significantly increase one s reading speed in or affecting commerce, shall not make any representation, in any manner, expressly or by implication about the benefits, performance, or effcacy of such product, unless, at the time the representation is made, respondent possesses and relies upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates the representation, It is further ordered, That respondent Tru- Vantage International LLC , and its successors and assigns, shall, for five (5) years after the last date of dissemination of any representation covered by this order, maintain and upon request make available to the Federal Trade Commssion for inspection and copying:

Decision and Order 125 P. A. All advertisements and promotional materials containing the representation;

B. All materials that were relied upon in disseminating the representation; and C. All tests, reports, studies, surveys, demonstrations, or other evidence in their possession or control that contradict, qualify, or call into question the representation, or the basis relied upon for the representation, including complaints and other communications with consumers or with governmental or consumer protection organizations, IV, It isfurther ordered That respondent Tru- Vantage International LLC, and its successors and assigns, shall deliver a copy of this order to all current and future members and managers, and to all current and future employees, agents, and representatives having responsibilities with respect to the subject matter of this order, and shall secure from each such person a signed and dated statement acknowledging receipt of the order. Respondent shall deliver this order to current personnel within thirty (30) days after the date of service of this order, and to future personnel within thirty (30) days after the person assumes such position or responsibilities, It is further ordered That respondent Tru- Vantage International LLC, and its successors and assigns shall notify the Commssion at least thirty (30) days prior to any change in the corporation that may affect compliance obligations arising under this order, including but not limited to a dissolution, assignment, sale, merger, or other action that would result in the emergence of a successor corporation; the creation or dissolution of a subsidiary, parent, or affiliate that engages in any acts or practices subject to this order; the proposed filing of a bankruptcy petition; or a change in the corporate name or address, Provided, however, that, with respect to any proposed change in the corporation about which respondent learns less than thirty (30) days prior to the date such action is to take place, respondent shall notify the Commssion as soon as is practicable after obtaining such knowledge, All notices required by this Part shall be sent by certified mail to the Associate Director, Division of Enforcement, Bureau of Consumer Protection, Federal Trade Commission, Washington, D, TRU- V ANT AGE INTERNATIONAL, L.L.e. 673 635 Decision and Order VI.

It is further ordered That respondent Tru- Vantage International LLC, and its successors and assigns, shall, within sixty (60) days after the date of service of this order, and at such other times as the Federal Trade Commssion may require, file with the Commssion a report, in writing, setting forth in detail the manner and fonn in which it has complied with this order.

VII.

This order wil tennnate on April 6, 2018, or twenty (20) years from the most recent date that the United States or the Federal Trade Commission fies 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 wil not affect the duration of:

A. Any Part in this order that tennnates in less than twenty (20) years;

B. This order s application to any respondent that is not named as a defendant in such complaint; and This order if such complaint is fied after the order has tennnated pursuant to this Part.

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 tenninate according to this Part as though the complaint had never been filed, except that the order wil 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.

Commssioner Thompson and Commssioner Swindle not participating, Complaint J 25 FT.C.