Paramount Distilling Corp

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IN THE MATTER OF PARAMOUNT DISTILLING CORPORATION COllll'LAINT, FINDINGS, AND ORDER IN REGARD TO 'lue ALLEGED VIOLATION Ol•' SEC. 5 OF .AN ACT OF CO~GHESS APPROVED SEPT. 2a, l!l14 Doeket 2HG. Complaint, June 19, 1935-Deeision, Aug. 12, 1937 Where a corporation engaged in rectifying and bottling both rectified and straight distilled spirits, and in making gin, with a still whkh it used therefor, by redistillation of purchased alcohol, not produced by it, over juniper berries and other aromatics, and in selling its aforesaid produ-,.:ts to wholesalers and dh;trilmtors thereof in various ~tatcs and ln the District of Columbia, in substantial competition with those engaged in the manufacture by true distillation of whiskies, gins, nnd other spirituous beverages from mash, wort, or wash, and ln selling such products in trade and cornmeree among the various States and in said District, and with those engaged in purchasing, rectifying, blending, and bottling such various bl)veragi'S and similarly selling same, and including among said eompctltors those who, as munufactm·ers and distillers from mash, wort, or wash of whiskies, gins, and other spirituous be,·erages sold by them, truthfully use words "distillery," "distilleries,'' "distillers," or "tlistilling" ns a part of their corporate and trade names and on their statiout>ry and advertising and on the labels of the bottles in which they sell and ship their said products, and those who, engaged in purchasing, rectifying, blending, bottling, nud selling such various products, do not use aforesaid words as above set forth- Represented, through use of word "Distilling" in its corporate name, printed on its stationery and advertising, and on the labels attached to the bottles in which it sold and shipped its said products, and in various other ways, to its customers, and furnished same with a me11ns of representing to their venuecs, both retailers and ultimate consuming public, that it was a distiller and that the whiskies, gins, and other alcoholic beverages contained in such bottles were by it made through process of distillation, notwithstanding fact it did not distill said various beverages, thus bottled, labeled, sold, and transported by it, through original and continuous distillation from mash, wort, or wash, through continuous closed pipes and vessels until manufacture is complete, as long definitely understood from word "distilling," used in connection with liquor Industry and products thereof, In the trade and by the ultimate consuming public, and did not own, operate, ot' control any place or places where such bC)verages are made by process of distillation from mash, wort, or wash, and was not a distiller, for the purchase of the bottled liquors of which there is a preferenee on the part of a substantial portion of the purchasing public, and plant, equipment, and requirements of which are more elahorate, extensive a ud bnrdPnsome than those of rectifier ; With effect of misleading and deceh·ing dealers and purchasing public into the beliefs that it was a distiller or distilling comJJUny in the ordinarily accepted sense of those terms, and that the whiskies, gins and other 158121m--39----52 'I 784 FEDERAL TRADE COMMISSION DECISIONS Complaint 25 F. T. C. spirituous bererages sold by It were by It made or distilled from mash, wort, or wash by one continuous process, and of inducing dealers and pm·cltasiug public, in such beliefs, to buy its said whiskies aud other alcoholic beyerages, rectified and bottled by it, and with distinct tendency to give it an unfair advantage over those of Its competitors who do not, through use of such terms in their trade or corporate names, represent that package of alcoholic liquor offered to retailer, and iu turn to consumer, is a dlst!Ilery-bottled one, and thereby to divert trade to it from such competitors; to the substantial injury of competition in interstate commerce:

Held, That such ttcts and practices were to the prejudice and injury of the public and competitors and constituted unfair methods of competition. Defore Mr. John L. Il ornor, trial examiner. Mr. PGad B. Morehouse for the Commission.

Mr. R. E. Joyce, of Washington, D. C., for respondent. COl\IPLAINT Pursuant to the provisions of an Act of Congress approved September 26, 1914, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes," the Federal Trade Commission, having reason to believe that Paramount Distilling Corporation, hereinafter referred to as respondent, has been and is using unfair methods of competition in commerce, as "conunerce" js defined in said act, and it appearing to the said Commission that a proceeding by it in respect thereof would be in 1he public interest, hereby issues its complaint, stating its charges in that respect as follows:

PARAGRAPH 1. Respondent is a corporation organized, existing, nnd doing business under the laws of the State of Illinois, with its oflice and principal place of bu.siness in the city of Chicago, in said State. It is now, and for more than one year last past has been, engaged in the business of wholesaler and rectifier, purchasing, rectifying, blending, and bottling whiskies, gins, and other alcoholic beverages and in the sale thereof in constant course of trade and commerce between and among the various States of the United States nnd in the District of Columbia. In the course and conduct of its said business, it causes its said products when sold to be transported from its place• o£ business aforesaid into and throuO'h0 various States of the Umted States to the purchasers thereof consisting' of whole- Falers and retailers,• located in other States of' the Unite,d0 States nnd the District of Columbia. In the course and conduct of its business as aforesaid, respondent is now, and for more than one year last past has been, in substantial competition with other corporations and with individuals, partnerships, and firms engaged PARAMOUNT DISTILLING CORP. 785 783 Complaint in the manufacture by distillation of whiskies, gins, and other alcoholic beverages and in the sale thereof in trade and commerce between and among the various States of the United States and in the District of Columbia; and in the course and conduct of its business as aforesaid, respondent is now, and for more than one year last past has been, in substantial competition with other corporations, and with individuals, firms, and partnerships engaged in the business of purchasing, rectifying, blending, and bottling whiskies, gins, and other alcoholic beverages and in the sale thereof in commerce between and among the various States of the United States and in the District of Columbia.

PAR. 2. For a long period of time the word "Distilling" when used in connection with the liquor industry and the products thereof has had and still has a definite significance and meaning to the minds of the wholesalers and retailers in such industry and to the ultimate vurchasing public, to wit, the manufacturing of such liquors by the process of original and continuous distillation from mash, wort, or wash, through continuous closed pipes and vessels until the manufacture thereof is completed; and a substantial portion of the purchasing public prefers to buy alcoholic liquors prepared and bottled by distillers.

PAn. 3. In the course and conduct of its business as aforesaid, by the use of the word "Distilling" in its corporate name, printed on its stationery and advertising, and on the labels attached to the bottles in which it sells and ships its said products, and in various other ways, respondent represents to its customers and furnishes them with the means of re,presenting to their vendees, both retailers and the ultimate consuming public, that it is a distiller and that the whiskies, gins, and other alcoholic beverages therein contained were by it tnanufactured through the process of distillation from mash, wort, or wash, as aforesaid, when, as a matter of fact, respondent is not a distiller, does not distill the said whiskies, gins, or other alcoholic beverages by it so bottled, labeled, sold, and transported, and does not own, operate or control any place or places where such beverages are tnanufactured by the process of distillation from mash, wort, or wash. PAn. 4-. There are among the competitors of respondent engaged in the sale of alcoholic beverages as mentioned in paragraph 1 hereof corporations, firms, partnerships, and individuals who mi111ufacture and distill from mash, wort, or wash, as aforesaid, whiskies, gins, and other alcoholic beverages sold by them and who truthfully use the words "distillery," "distilleries," "distillers," or "distilling'' as a Part of their corporate or trade names and on their stationery and advertising, and on the labels of the bottles in which they sell and FEDERAL TRADE COl\I:MISSION DECISIONS786 Findings 25F.T.C.

ship such products. There are also among such competitors corporations, firms, partnerships, and individuals engaged in the business of purchasing, rectifying, blending, bottling, and selling whiskies, gins, and other alcoholic beverages who do not use the words "distillery," "distilleries," "distilling," or "distillers" as a part of their corporate or trade names, nor on their stationery or advertising, nor on the labels attached to the bottles in which they sell and ship their said products.

PAR. 5. Representation by respondent, as set forth in paragraph 3 hereof, is calculated to and has the capacity and tendency to and does mislead and deceive dealers and the purchasing public into the beliefs that respondent is n. distiller and that the whiskies, gins, and other alcoholic beverages sold by the respondent are manufactured and distilled by it from mash, wort, or wash, as aforesaid, and is calculated to and has the capacity and tendency to and does induce dealers and the purchasing public, acting in such beliefs, to purchase the whiskies, gins, and other alcoholic beverages bottled and sold by th~ respondent, thereby diverting trade to respondent from its competitors who do not by their corporate or trade names or in any other manner misrepresent that they are manufacturers by distillation from mash, wort, or wash, of whiskies, gins, and other alcoholic beverages, and thereby responuent does substantial injury to substantial competition in interstate commerce.

PAn. 6. The acts 11nd things above alleged to have been done and the false representations alleged to have been made by respondent are to the prejudice of the public and the competitors of respondent and constitute unfair methods of competition in commerce within the intent and meaning of Section 5 of an Act of Congress, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes," approved September 26, 1914. REI'ORT, FINDINGS AS TO THE FACTS, AND ORDER Pursuant to the provisions of an Act of Congress approved September 26, 1914, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes," the Federal Trade Commission, on June 19, 1935 issued, and on June 21, 1935 served its complaint in this proceeding upon the respondent, Paramount Distilling Corporation, charging it with the use of unfair methods of competition in commerce in violation of the provisions of said act. After the issuance of said complaint and the filing of respondent's answer thereto, testimony and other evidence in support of the allegations of said complaint were introduced by PGad B. PARAMOUNT DISTILLING CORP. 787 783 !<'in dings exammer Morehouse,. ofattorneythe Commission,for the Commission,theretofore dulybeforedesignatedJohn L. Hornorby it. ' Noan testimony was introduced or offered in opposition to the allegations of the complaint by R. E. Joyce, attorney for respondent. The testimony and other evidence in support of the allegations of the complaint were duly recorded and filed in the office of the Commission. Thereafter, the proceeding regularly came on for final hearing before the Commission on the said complaint, the answer thereto, testimony and other evidence, and briefs in support of and in opposition to the complaint, no oral arguments having been made; and the Commission having duly considered the same and being now fully advised in the premises, finds that this proceeding is in the interest of the public, and makes this its findings as to the facts and its conclusion drawn therefrom:

FINDINGS AS TO THE FACI'S I>ARAGRAPII 1. Respondent is a corporation originally incorporated October 16, 1934, existing and doing- business under the laws of the State of Illinois, with its principal office and place of business at 512 South Peoria Street, Chicago, Ill.

It is now and has been since February 2, 1935, engaged in the business of rectifying and bottling both rectified and straight distilled spirits, and in the sale thereof, in constant course of trade and commerce, between and among the various States of the United States and in the District of Columbia.

In the course and conduct of its said business, it causes said })roducts, when sold, to be transported from its place of business aforesaid into and through various States of the United States to the purchasers thereof, consisting of wholesalers and distributors, some located within the State of New York, and some located in other States of the United States and the District of Columbia. In the course and conduct of its business as aforesaid, respondent is now, and since February 1935, has been, in substantial competition "With other corporations and with individuals, partnerships, and firms engaged in the manufacture by true distillation of whiskies, gins, Und other spirituous beverages from mash, wort, or wash, and in the sale thereof in trade and commerce between and among the various Statt's of the United States and in the District of Columbia; and in the course and conduct of its business as aforesaid respondent is, and since February Hl35, has been, in substantial competition 'with other corporations and with individuals, firms, and partnerships engaged in the business of purchasing, rectifying, blending, 788 FEDERAL TRADE CO:Ml\IISSION DECISIONS Findings 25F.T.C.

and bottling whiskies, gins, and other spirituous beverages in rectifying plants under rectifiers' permits, and in the sale thereof in commerce between and among the various States of the United States and in the District of Columbia.

PAn. 2. Upon the premises of respondent's place of business aforesaid, there is a still for use in the production of gins by a process of rectification whereby alcohol, purchased but not produced by respondent, is redistilled over juniper berries and other aromatics. Such rectification of alcoholic spirits does not make or constitute respondent a distillery or a distiller, as defined by Section 3247 of the Revised Statutes regulating Internal Revenue. A brief description of the equipment used by said respondent at its rectifying plant in Chicago is as follows: "66 processing receptacles with a total capacity of 2,303 gallons; 40 bottling tanks, total capacity 10,330 gallons; 1 only 40-gallon still for distilling gin; receiving tank, 115 gallons; 1 vacuum filling machine for bottling; '.l: regular filling machines for bottling; 5 conveyor tables for bottling; also filter machine.

PAn. 3. Rectifying in the distilled spirits rectifying industry means the mixing of whiskies of different ages or types or the mixing of other ingredients with whiskies, but reducing proof of whiskey by adding water is not rectifying. Rectifiers also blend whiskies with neutral spirits (grain alcohol).

Many distillers operate a separate establishment 600 feet or more away from their distillery, known as a rectifying plant, wherein they operate in the same manner as described above, for a rectifier-sometimes exclusively with spirits of their own distillation and sometimes with spirits purchased from other distillers, or both. Some distilleries have a tax-paid bottling room on the distillery bonded premises, wherein their distilled spirits are bottled straight as they come from the still, or in a bonded warehouse after aging, or after reduction of proof.

Any rectifying by a distiller, however, must be done in his rectifying plant under his rectifier's permit.

On some bottled liquors, whether bottled at the distiller's rectifying plant or at any rectifying plant, appear the words "Bottled'' e case may e y le _____________________ _or "Blended" (as th b ) "b tl Company."

. If t~e d~stil.le~ spirits therein contained are bottled by a distiller either m h1s distillery or are spirits of his own distillation bottled in his rectifying plant, the distiller may and does put "Distilled and Bottled by ----------------------Company." If, in the distiller's PARA11IOUNT DISTILLING CORP. 789 783 Findings rectifying plant, other spirits have been blended or rectified, he puts "Blended and Bottled by ----------------------Company." With reference to the gin produced by respondent by the redistil· lation of purchased alcohol over juniper berries and other aromatics, existing regulations promulgated pursuant to Federal Alcohol Ad· ministration Act, approved August 29, 1935, ( 49 Stat. 977), provide that rectifiers who redistill purchased alcohol over juniper berries and other aromatics must call such resulting product "distilled gin," and require that the labels state who distilled it. This serves to distinguish between gin produced by such method and "cold" or compounded gin prepared by mixing neutral spirits with essential flavoring oils.

There' is usually blown in the bottom of each bottle a symbol con· sisting of a letter followed by a number, identifying the bottler, viz, a "D" for a distillery and "R" for a rectifier, the number following said letter corresponding with the distiller's or rectifier's permit; thus, "R 233" designates this respondent.

A distiller, who also operates a rectifying plant, having both kinds of permits, may use either symbol depending upon whether the liquor contained in the bottle was produced and bottled under his distiller's or his rectifier's permit.

A distiller has a maximum bond of $100,000.00, and is permitted to have untaxed liquor; the average bond of the rectifier is about $5,000.00; the distiller must own tho fee title of the premises upon Which the business is conducted, or have consent from the owner Waiving the owner's interest so that the Government can have a first lien upon the property for taxes; a distillery is under constant general supervision by storekeeper gaugers, who are always there; absolute supervision is maintained over the bonded warehouse of a. distillery and rectifying plant; they do not lock the premises and ll'laintain general supervision over the bottling and rectification; the Primary distinction is that one storekeeper gauger may take care of several rectifying plants, but at the distillery he is in constant supervision, primarily to supervise the tax payments; a rectifier is not Permitted to store spirits in bond; a distiller produces spirits from grains, alcohol, molasses, and fruits; a rectifier produces no distilled · spirits whatever, but must obtain them from the producer or from 8?meone holding warehouse certificates; the requirements are con- Siderably more detailed in the case of a distiller than in the case of a rectifier .

. A distiller must have a distillery, which must be a complete build- Ing and a warehouse, a separate building; he has to have necessary Weighing equipment, a grain hopper, cooker, cooking equipment, 790 FEDERAL TRADE COM!\IISSION DECISIOXS Finding-s 2:'1F.T.C. mash tubs, fermenters, sufficient distilling equipment to take care of his continuous distillation until the spirits are run through the pipe lil1f'S into the receiving tanks; at the warehouse he has to have the weighing and testing instruments for checking and many other things; a rectifier is not required to have a separate building. A rectifying plant may consist of a room within a building. He needs no bonded \\·warehouse. If one room, it would have to be divided into three separate rooms by wire mesh partitions. The regulations for the equipment of a rectifier are not so specific as those for a distiller. Knowledge of these details is not widespread among the retail trade and is very limited to the general public. All whiskies, ·whether emanating from tlistillel'ies or rectifiers, are generally in the trade conceded to Le "distilled products."

It is not possible to determine from the presence of the phrase "Blended and Bottled by" alone, or the phrase "Bottled by" alone, on the label whether the package was bottled by a rectifier who is a distiller or Ly a rectifier who is not a distiller. PAn. 4. In the course and conduct of its business as aforesaid, by the use of the word "Distilling'' in its corporate name, printed on its stationery and advertising, and on the labels attached to the bottles in which it sells and ships its said products, and in various other ways, respondent represents to its customers and furnishes them \with the means of representing to their vendees, both retailers and the ultimate consuming public, that it is a distiller and that the whiskies, gins, and other alcoholic beverages therein contained were by it manufactured through the process of distillation from mash, wort, or wash, as aforesaid, when, as a matter. of fact, respondent 1s not a distiller, does not distill the said whiskies, gins, or other alcoholic Leverages by it so bottled, labeled, sold, and transported, and does not own, operate, or control any place or places where such Leverages are manufactured by the process of distillation from mash, wort, or wash.

The testimony of those having long experience in both the distilled spirits rectifying industry and the distilling industry, established, and the Commission finds, that the foregoing rectification of alcoholic spirits by redistillation over juniper berries and other aromatics in the production of gin does not make or constitute this respondent a distilling company in the sense commonly understood by the liquor industry. There were also called a large number of witnesses who were lay-members of the purchasing public, and with few excl'ptions, their testimony was to the effect, and the Commission also finds it to be a fact, that by such terms as "distilling" or "distillery" or "distiller" when used in the trade or corporate name of a PARAMOUNT DISTILLING CORP. 791 783 Findings concern handling alcoholic beverages, the public understands that that concern is engaged in the initial distilling process of producing spirituous or alcoholic beverages from fermented grain or mash, and that they have a preference for a distillery bottled package over one bottled by a rectifier.

The Commission finds that for a long period of time the word "<listilling" when used. in connection with the liquor industry and With the products thereof has had and still has a definite significance and meaning to the minus of wholesalers and retailers in such industry and to the ultimate purchasing public, to wit, the manufacturing of spirituous liquors by an original and continuous distillation from lh.ash, wort, or wash, through continuous closed pipes and vessels Until the manufacture thereof is complete, and a substantial portion of the purchasing public prefers to buy spirituous liquors: bottled and prepared by distillers .

• PAR. 5. There are among the competitors of respondent engaged ln the sale of spirituous beverages, as mentioned in paragraph 1 hereof, corporations, firms, partnerships, and individuals who lh.manufacture and distill from mash, wort, or wash, whiskies, gins, and other spirituous beverages sold by them, and who truthfully Use the word.s "distillery," "distilleries," "distillers," or "distilling" as a part of their corporate or trade names and on their stationery, advertising, and on the labels of the bottles in which they sell and ship such products.

There are also among such competitors, corporations, firms, Partnerships, nnd inuividuals engaged. in the business of purchasing, tectifying, blending, and bottling whiskies, gins, and other spirit- Uous beverages in rectifying plants under rectifiers permits who do not use the words "distillery," "distilleries," "distilling," or "<listillers'' as a part of their corporate or trade names, nor on their stationery, advertising, nor on the labels attached to the bottles in Which they sell and ship their said products. PAn. 6. Subsequently to the issuance of complaint herein, and on the 3rd day of June 1936, pursuant to proper application approved by the requisite governmental authorities, there was issued to respondent by the Federal Alcohol Administration a basic distiller's Permit, No. D-740, authorizing it to distill spirituous beverages from lhash, wort, or wash, but up to the present time respondent has not colhmenred operations under said basic permit. That permit authorized respondent to engage in the production ~nd sale of distilled spirits at a registered distillery not yet in ex- Jstence, at St. Charles, Ill. The construction of such distillery was begun at St. Charles, Ill., by the Mervyn Building Corporation, a Findings 25F.T. C.

company owned outright by Mr. N.C. Meyer, Mr. M. C. Meyer, and Mr. Joseph N. Meyer, under an agreement by which the land and buildings may be purchased by the Paramount Distilling Corporation, upon completion, for the sum of $200,000.00. All of the moneys advanced by the Mervyn Building Corporation for the construction of this distillery have been furnished by N. C. :.\!eyer, M. C. Meyer, and Joseph N. Meyer. The distillery, when completed, will have a capacity of approximately 4,000 gallons of distilled spirits per eight-hour working day, and at the time of the hearings it was anticipated that actual operation of the distillery by the Paramount Distilling Corporation would t:ommence the latter part of January 1937.

Respondent expressed the intention, that as soon as the construction was completeu and the necessary arrangements could be made, to proceeu to engage in the manufacture of distilled spirits by a process of original and continuous distillation from mash, wort, or wash at the aforesaid distillery.

Respondent has not yet engaged in actual distillery operations. P .AR. 7. The representations by respondent, as set forth in paragraph 4 hereof, have the capacity and tendency to and do mislead and deceive dealers and the purchasing public into the beliefs that respondent Paramount Distilling Corpomtion is a distiller or uistilling company in the ordinarily accepted sense of those terms, and that the whiskies, gins, and other spirituous beverages sold by respondents are manufactured or distilled by Paramount Distilling Corporation from mash, wort, or wash by one continuous process, and have the capacity and tendency to and do induce dealers and the purchasing public, acting in such beliefs, to purchase the whiskies, gins, and other alcoholic beverages rectified and bottled by the respondent. The Commission finds that the whole situation in this industry is such that the foregoing representations have a distinct tendency to give respondent what amounts to unfair competitive advantage over those of its competitors who do not, by the usc of such terms in their trade or corporate names, represent that the package of alcoholic liquor offered to the retailer and in turn to the consumers, is a distillery-bottled package and this in turn tends to divert trade to respondent from such competitors and thereby respondent does substantial injury to competition in interstate commerce.

PAR. 8. Because of existing regulations promulgated under the Federal Alcohol Administration Act approved August 29, 1935 ( 49 Stat. 977), providing that rectifiers who redistill purchased alcohol over juniper berries and other aromatics may label such resulting PARAMOUNT DISTILLING CORP. 793 783 Ot·der product "Distilled Gin," and requiring that the label state who distilled it, the Conunission has excepted gins produced by respondent by redistillation of alcohol over juniper berries and other aromatics from the prohibitions of its order. CONCLUSION The aforesaid acts and practices of respondent, Paramount Distilling Corporation, are to the prejudice of the public and of respondent's competitors, and constitute unfair methods of competition in commerce within the intent and meaning of Section 5 of an Act of Congress, approved September 26, 1914, entitled "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes."

ORDER TO CEASE AND DESIST This proceeding having been heard by the Federal Trade Commission upon the complaint of the Commission, the answer of respondent, testimony and other evidence taken before John L. Hornor, an examiner of the Commission theretofore duly designated by it, in support of the allegations of said complaint and briefs filed herein (no testimony or other evidence having been offered in opposition to the complaint and no oral arguments having been made either by PGad 13 . .Morehouse, counsel for the Commission, or by R. E. Joyce, counsel for the respondent), and the Commission having made its findings as to the facts and its conclusion that said respondent has violated the provisions of an Act of Congress approved September 26, 1914, entitled, "An Act to create a Federal Trade Commission, to define its powers and duties, and for other purposes." It is ordered, That the respondent, Paramount Distilling Corporation, its officers, representatives, agents, and employees, in connection 'With the offering for sale or sale and distribution by it in interstate commerce or in the District of Columbia, of whiskies, gins, or other spirituous beverages (except gins produced by it through a process of rectification whereby alcohol purchased but not produced by ra. spondent is redistilled over juniper berries and other aromatics), do cease and desist from:

Representing, through the use of the word "distilling" in its corporate name, on all stationery, advertising, or labels attached to the bottles in which its said products are sold and shipped, or in any other Way by word or words of like import, (a) that respondent is a distiller of the said whiskies, gins, or other spirituous beverages; or, (b) that the said whiskies, gins, or other spirituous beverages were 794 FEDERAL TRADE COl\U.USSION DECISIONS Order 25F. T. C.

by it manufactured through a process of distillation; or (c) that respondent owns, operates or controls a place or places where any such products are by it manufactured by a process of original and continuous distillation from mash, wort, or wash, through continuous closed pipes and vessels until the manufacture thereof is completed, unless and until respondent shall actually own, operate, or control such a place or places.

It is further O'rdered, That the said respondent, within 60 days from and after the date of service upon it of this order, shall file with the Commission a report or reports in writing setting forth in detail the manner and form in which it is complying and has complied with the order to cease and desist hereinabove set forth. I ARPAUL CO., INC. 795 I Complaint