Oliver L. Von Bachelle

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IN THE MATTER OF OLIVER L. VON BACHELLE, DOING BUSINESS AS H. SHADE'S LABORATORIES, AND BtJREAU OF EDU- CATION, SHADE'S LABORATORIES COMPLAINT, FINDINGS, AND ORDER IN REGARD TO Tlle ALLEGED VIOLATION OF SEC. 5 OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1014 Doclcet 3101. Complaint, Apr. 9, 1937-Decision, Aug. 25, 1987 Where an Individual engaged in sale and distribution of certain medical preparations for use in meeting so-called problems of feminine hygiene, and for use in prevention and treatment of diseases, ailments, and conditions to which women are particularly susceptible, In substantial competition with those engaged in sale and distribution, in commerce among the States and in the District of Columbia, of products intended, designed, and used and useful for the purposes for which said individual represented and implied that his said products were effective, and including, among his competitors in said commerce, m.any who truthfully represent their products and the nature of their orgaoization- (ai) Falsely represented, in adyertlsing his "Cones," "Suppositories," and "Antiseptic Powder," as variously known and described, in certain advertising literature, such as books, pamphlets, and circulars, distributetl to purchasing public through boxes in which products were marketed, and through druggists and the United States mails, direct to prospective purchasers, and In newspaper and magazine advl'rtlsing, that the particular product, os the case might be, was efficacious for use in prevention, treatment, and cure of diseases, ailments, and conditions peculiar to women, arising out of so-called problems of feminine hygiene, ana was safe for general use and solved problems of aforesaid hygiene, and con· stltuted an efficient prophylactic where possibility of venereal infection was present, and was more effective than carbolic acid or chlorine in prevention and treatment and cure of aforesaid diseases, etc., and constituted an efficient treatment for certain specified ailments and conditions, and promoted cleanliness and good bl'alth, and misrepresented, in various specific particulars, the functioning and qualities or properties of said products; and (b) Made use, In his advertisements, of name "Dureau of Education" in connection with other statements in said advertising matter, in such a manner as to represent ana imply, and thereby lead purchasing public to believe, that such ''Dureau of Education" was a separate organization or institution, in no wise connected with his business, organized to carry on scientific research in methods of preventing, treating, or curing maladies peculiar to women, ana that his products had been tested or approved by said organization or institution, facts being there was no such organization creatPa to carry on scientific research in such methods, his products hnd not been tested by snell an organization, ana so-called "Dureau of Education" was simply a name adopted in furtherance of the sale thereof; \With effect of misleading and deceiving many members of the purchasing Public and en using them erroneously to believe that said representations Complaint 25F.T.C.

were true, and, because of such erroneous belief, to buy substantial quantities of his said products, and of thereby unfairly diverting trade in commerce to hlm from hls competitors who truthfully represent their products; to their substantial injury and that of the public: Held, That· such acts and practices were to the prejudice of the public and competitors and constituted unfair methods of competition. Before J.fr. Roberts. Hall, trial examiner. J.fr. William L. Taggart for the Commission. Complaint Pursuant to the provisions of an Act of Congress approved Sep· tember 26, 1914, entitled "An Act to create a Federal Trade Commis· sion, to define its powers and duties, and for other purposes," the Federal Trade Commission having reason to believe that Oliver L. Von Bachelle, doing business as H. Shade's Laboratories and as Bureau of Education, H. Shade's Laboratories, hereinafter referred to as respondent, has been, and is using unfair methods of competi· tion in commerce as "commerce" is defined in said act, and it appear· ing to said Commission that a proceeding by it in respect thereof would be in the public interest, hereby issues its complaint stating its charges in that respect as follows:

PARAGRAPH 1. The respondent, Oliver L. Von Bachelle, of 2335 Commonwealth Avenue, Chicago, Ill., is engaged in business indi· vidually and under the trade names H. Shade's Laboratories and n.s Bureau of Education, H. Shade's Laboratories, 2148 North Halsted Street, Chicago, Ill. He directs and controls the sales policies and business operations of said businesses.

PAR. 2. The respondent has been and is now engaged in the business of manufacturing, advertising, distributing and selling certain medical preparations for use in so-called feminine hygiene and for use in the female anatomy to purchasers in commerce among nnd between the various States of the United States and in the District of Columbia. He maintains a constant course of trade and com· merce in said products so distributed and sold by him. In the course and conduct of said business respondent has been, and is, in substantial competition with other corporations and with firms, individuals, and partnerships engaged in the distribution and the sale of similar products and other products intended and de· signed for similar use by women in commerce among and between the various States of the United States.

PAR. 3. The products marketed by respondent are variously known and described as "Shade's Cones," "Shade's Suppositories," "Shade's Antiseptic Powder."

H. SHADE'S LABORATORIES, ETC, 919 917 Complaint In the operation of his business and for the purpose of inducing the purchase of said products on the part of members of the purchasing public, the respondent has made use of certain advertising literature, such as books, pamphlets, circulars, as well as newspaper and magazine advertising which purports to be descriptive of the Various products herein named. The advertising literature herein referred to is distributed to the members of the purchasing public ~through the medium of the boxes in which the products are marketed, In advertising literature distributed through the medium of drug stores, through the United States mails direct to prospective purchasers and in newspapers and magazines.

With reference to the product designated as "Shade's Suppositories," such statements as the following are made: NEW BLESSING for MODERN WOMANHOOD.

Solve Problem of Feminine Hygiene.

The intelligent practice of feminine hygiene ls of vital importance to good health. Shade's Suppositories, a recognized reliable formula, permits modern Wives to enjoy the benefits of feminine hygiene without its attendant problems. Sate, reliable and convenient. No water. or accessories needed. Melting at body heat, they provide a protective film which is powerfully germicidal, yet soothing to delicate membranes. Don't wait I Send 10~ for samples and personal information. Dox of 24 cones-$1.00. . In said statements, together with other similar statements not here- In set out with respect to the product named, respondent directly and through implication represents and the public is thereby led to believe that said product forms a safe, competent, reliable remedy, cure and Preventive of ill health in that it solves the problem of feminine hygiene; that said product is a safe product, reliable and convenient to ~se and forms a protective film in the vaginal canal which is powerfully germicidal and that said product is soothing to delicate membranes.

PAn, 4. In truth and in fact the product designated above does not form a safe, competent treatment, remedy, cure and preventive· of ill health. It does not solve the problem of feminine hygiene and, further, the said product is not a safe product for general use. It will not form a protective film which is powerfully germicidal. PAR. 5. 'With reference to the product designated as "Shade's Cones," such statements as the following are made: • • • Known to the medical profession as Vagi-Seals for Intimate F'emlnine Hygiene • • • Shade's Cones are also in dcmnnd as a prophylactic, where tbe possibility of Venereal Disease communication is present. Dainty women appreciate the value of cleanliness, but cleanliness is far more Important In the delicate mucous membrances of the hidden parts, as It Is on the ·920 FEDERAL TU.ADE COMMISSION DECISIONS Complaint 25 F. T. C. face. In fact, any matter foreign to the parts, may soon cause inflammation and annoyance. The use of Shade's Vagi-Seal Cones tends to relieve inflammation and soothes the irritated membranes.

Shade's Cones contain no poisonous chemicals, yet they are more effective than any Solution of odorous Carbolic acid or Chlorine, that can be applied to the human body. Physicians testify to the utter harmlessness and effectiveness to the purpose of these Ingredients * * * Shade's Cones deposit a protective film or coating over the mucous membranes of the area, which is effective for a long period * * * They also act as a deodorant and the women that use them, can always be sure of being protected from embarrassing odors, which sometimes arise from vaginal disorders.

We know that Shade's Cones are safe, healthful and clean, and that they should be left nt least 8 to 10 hours in the cavity, before being washed out with a Shade Antiseptic Powder douche.

In said statements, together with other similar statements not herein set out with respect to the product named, respondent directly and through implication represents and the public is thereby led to believe that said product forms a safe, competent, reliable remedy, cure and preventive of ill health and that it is known to the medical profession for intimate feminine hygiene; that said product is a competent and satisfactory prophylactic for nse where the possibility of venera! disease and contamination are prrsent; that said product will relieve inflammation and soothe the, irritated membranes of the vagina; that said product is more effective than carbolic acid or chlorine and physicians testify to the utter harmlessness and effectiveness of these products for the troubles set forth; that the product when used deposits a protective film or coating over the mucous membranes of the vagina which is effective for a long period; that the product acts as a deodorant and the women that u~e it can always be sure of being protected from embarrassing odors which arise frotn vaginal disorders.

In truth and in fact said product will not form a safe, competent, reliable remedy, cure and preventive for ill health. It is not known to the medical profession as a remedy for intimate feminine hygiene. It is not in demand as a prophylactic and. it is not in demand as a prophylactic for use where there is a possibility of venereal disease and contamination present. It will not relieve inflammation or soothe irritated membranes of the vagina. It is not more effective than carbolic acid or chlorine. Physicians do not testify as to its harn?· lessness and effectiveness for the troubles herein set out and it lS not harmless or fully effective for such use. The protluct when used does not deposit a protective film or coatinrr over the mucous rnern· branes of the vagina and is not effective fo; long periods. Further, the product does not act as a deodorant and the woman who uses H. SHADE'S LABORATORIES, ETC. 921 1ll7 Complaint it cannot be sure of always being protected from embarrassing odors Which usually arise from vaginal disorders. PAR. 6. With reference to the product designated and known as "Shade's Antiseptic Powder" such statements as the following are made:

Vaginal douching is so important to health, that dainty women, cannot afford to neglect it. Douching should be practiced regularly by every woman, and especially the married woman. Secretions in the marital state are more frequent and opportunities for infection are increased. Shade's Antiseptic Powder not only promotes cleanliness and healtll, but also destroys bacteria, and it soothes and beals the dellcate tissues. Two teaspoonfuls of the powder to 2 quarts of warm water, used daily, in Leucorrhea (Whites), Vaginitis and Cervicitis. It destroys unpleasant odors, and produces that wonderful feeling of inner cleanliness, so much desired by every dainty woman. In said statements, together with other similar statements not herein set out with respect to the product nameu, respondent directly and through implication represents and the public is thereby led to believe that saiu product promotes cleanliness and health, destroys bacteria and soothes and heals the delicate tissues of the vaginal tract; that it is a competent and satisfactory treatment for leucorrhea, Whites, vaginitis, and cervicitis and destroys unpleasant odors and Promotes a feeling of cleanliness.

In truth and in fact the product does not promote cleanliness and ~health. It does not destroy bacteria nor soothe nor heal the delicate tissues of the vaginal tract. It is not a competent and satisfactory treatment for leucorrhea, whites, vaginitis, and cervicitis and, further, it will not destroy unpleasant odors and promote a feeling of cleanliness.

PAR. 7. In the operation of his business, as aforesaid, respondent makes use of in his advertisements the name of "Bureau of Education." Said statement together with other statements in said ad- Vertising represents to the public directly or through implication that the Bureau of Education is a bureau devoted to scientific research on questions involving so-called marriage hygiene. In truth and in fact the said Bureau of Education is not a separate organization or institution organized for the purpose of carrying on scientific research in the methods of preventing, treating or. curing maladies peculiar to women or any other questions, and said bureau does not actually exist but the name is used for the Purpose of encouraging the sale of respondent's products. PAn. 8. There are among respondent's competitors in commerce, ns herein set out, those 'vho do not in any way misrepresent the ·tharacter and nature of their products and who do not make use Findings 25 F. T. C. of any of the misleading representations herein set out and similarones with respect to the therapeutic value of the product and others. PAR. 9. The aforesaid false and misleading statements and representations used by the respondent in offering for sale and selling the various products as herein described in commerce as herein set out, have had, and now have the tendency and capacity to, and do, mislead and deceive members of the purchasing public into the erroneous and mistaken belief that said representations are true ami into ·the purchase of substantial quantities of respondent's. various products on account of said erroneous and mistaken belief. As a result thereof trade is unfairly diverted from competitors of respondent who do not in the sale and distribution of their respective products make usc of the same or similar misrepresentations. In consequence thereof injury has been and is now being done by respondent to competition in commerce among and between the various States of the United States.

PAR. 10. The methods, acts, and practices of respondent herein bet forth are to the prejudice of the public and of competitors of the respondent as hereinabove alleged. Said methods, nets, and practices 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.'' REPORT, FINDINGS AS TO Tile FACTS, AND ORDER Pursuant to the provisions of an Act of C~ngress 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 April 9, 1937, issued, and on April 13, 1937, served, its complaint in this proceeding upon respondent, Oliver L. Von Dachelle, doing business as II. Shade's Laboratories, and as Bureau of Education, II. Shade's Laboratories, charging him with the use of unfair methods of competition in commerce in violation of the provisions of the said act. On July Hi,. 1937, the respondent filed his answer, in which answer he admitted all the material allegations of the complaint to be true, and stated tha~ he waived hearings on the charges set forth in the said complamt nml that, without further evidence or other intervening pro- <·Nlure, the Commission might issue and serve upon him findings ns to the facts and conclusions and an order to cease and desist frottl the vio~ations of law charged in the complaint. Thereafter, the proceedmg regularly came on for final hearinO'o before the Commis- H. SHADE'S LABORATORIES, ETC. 923 Findings sion on the said complaint and the answer thereto, and the Commission having duly considered the same, and being now fully advised in the premises, finds 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 FACTS P ARAGRArH 1. The respondent, Oliver L. Von llachelle, is engaged in business under the trade name H. Shade's Laboratories and under the trade name Bureau of Education, H. Shade's Laboratories, and has his office and principal place of business at 2148 North Halsted Street, in the city of Chicago, State of Illinois. Pan. 2. The respondent is now, and has been for more than one Year last past, engaged in the sale and distribution of certain medical preparations, for use in meeting the so-called problems of feminine hygiene, and for use in the prevention, and treatment of diseases, ail- Inents and conditions to which women are particularly susceptible. Respondent causes said products, when sold, to be transported from his place of business in the city of Chicago, State of Illinois, to the Purchasers thereof located in various States of the United States other than the State of Illinois anu in the District of Columbia. Respondent maintains a constant current of trade in commerce between and among the various States of the United States and in the District of Columbia in the sale and distribution of said products. In the course and conduct of his business in said commerce respondent has been, and is, in substantial competition with other individuals and with firms, corporations, and partnerships engaged in the sale and distribution in said col)1merce of products intended, designed, and used and useful for the purposes for which the respondent represent and implies that his said products are efficacious. J> AR. 3. The products marketed by respondent are variously known and described as "Shade's Cones," "Shade's Suppositories," "Shade's Antiseptic Powder."

In the operation of his business and for the purpose of inducing the purchase of said products on the part of members of the purc?asing public, the respondent has made use of certain advertising hterature, such as books, pamphlets, circulars, as well ns newspaper nnu magazine ad,·ertising which purports to be descripthre of the Various products herein namt>d. The advertising literature ht>rein referred to is distributed to the members of the purchasing public through the medium of the boxes in which the products are marketed, through advertising liter·nature distributed by drug stores, and through the United States mails direct to prospective purchasers. 924 FEDERAL TRADE CO:Ml\IISSION DECISIONS Findings 2::iF.T.G. Respondent also uses advertisements of similar nature and effect which are placed in newspapers and magazines of interstate circulation.

'With reference to the product designated as "Shade's Suppositories," such statements as the following are made: NEW llLESSING FOrt 1\IODERN WOl\IENHOOD.

Solve Problem of Feminine Hygiene.

The intelligent practice of feminine hygiene is of vital importance to gootl health. Shade's Suppmdtories, a recogni7.ed reliable formula, pf'rmits modern wives to enjoy the benefits of feminine hygiene without its attendant problems. Safe, reliable and convenient. No water or aecessori<'s ueeded. Melting at body heat, they provide a protective film which is llOwerfully germicidal, yet soothing to delicate membranes. Don't wait I Send 10¢ for samples and personal information. nox of 24 cones-$1.00.

Through said statementst and in other statements not herein set out, with respect to the product Shade's Suppositories the respondent represents and implies, and the pmchasing public is thereby led to believe, that said product is £>fficacious for use in the prevention, treatment and cure of diseases, ailm£>nts and conditions peculiar to women arising out of the so-called problems of feminine hygiene; that it solves the problem of feminine hygiene; that the product may be us£>d with safety; that its use forms 11 protrcth·e film which is powerfully germicidal, and that its usc is soothing to delicate membranes. Uespomlent's product, Shade's Suppositorirs, is not effi· cncions for use in the prevention, treatment and cure of diseases, ailments and conditions peculiar to women arising out of the so-called problems of feminine hygiene; said product does not soh·e the problems of ft•mininc hygie.ue, and is not safe for general usc; said product does not form a protective film which is powerfully germicidal and its use is not soothing to delicate mcmbrnnccs. l)An. 4. "'ith reference to the prOlluct designated as "Shade's Cones," such statements as the following arc ma<le: • • • Known to the medical profession as Yngi-Senls for intimate Feminine Hygiene.

Shade's Con<>s ore nl:io in demand ns a prophylactic, where th<' possibility of Venerol Dls<>ase commtmlf'atlon Is present. Shade's Cones contain no poisonous <·hf'micnls, yet thf>y are more effectire than ony Solution of oclol'Ous Carbolic ncld or Chlorhw, that can he npplil•d to the humnn t.ocly. thy~<lclans te~tlfy to the utter hnrmlt>ssn<>ss and eff<>ctlveuess to the purpo,;e of th<>se lugr<>dlents • • • Shade's Cones d<>rJosit a prol<>cth e film or eontlng oret· the mucous mern· brnncs of the arf>n, whirh Is et'fe<'tive for n long (lt'l'iod • • • They also act as a dl•odoront aml the wonwn that use thl'm eon always ue sure of b<'lng prot<>lted from embnrrnssing oclors, which sometimes arise frolll vaginal disorders.

H. SHADE'S LADORATORIES, ETC. 925- 917 Findings We know that Shade's Cones are safe, healthful and clenn, and that they should be left at least 8 to 10 hours in the cavity, before being washed out With a Shade Antiseptic Powder douche.

Through said statements, and in other statements of similar import, with respect to the product "Shade's Cones," the respondent represents and implies, and the purchasing public is thereby led to believe, that said product is efficacious for use in the prevention, treatment and cure of diseases, ailments and conditions peculiar to Women arising out of the so-called problems of feminine hygien.e; that said product is safe for general use; that said product is an efficient prophylactic where the possibility of venereal disease infection is present; that said product relieves inflammation and is soothing to irritated membranes; that the product is more effective than carbolic acid or chlorine in the prevention, treatment and cure of diseases ana ailments peculiar to women arising out of the so-called Problem.>ms of fE.>minine hygiE.>ne; that its use deposits a protective film or coating m·er the mucous membranes which remains effective for a long period of time, and that the product is a deodorant and assures the user of protection from embarrassing odors arising from the so-calle.>d problems of feminine hygiene. Respondent's product "Shade's Cones" is not efficacious for use in the prevention, treatl1lent and cure of diseases, ailments and conditions peculiar to women arising out of the so-called problem.>ms of feminine hygiene; said prodllct is not safe for general use and is not an efficient prophylactic '"here the possibility of venereal disease infection is present; said Product docs not relieve inflammation and is not soothing to irritated membranes; said product is not more effective than carbolic acid or chlorine in the prevention, treatme.>nt and cure of diseases and ailments peculiar to women arising out of the so-called problems of ~eminine hygiene; its use does not deposit a protective film or coat- Ing over the mucous membrane which remains effective for a long Period of time; said product is not a deodorant and its use will not nssure the user of protection from embarrassing odors arising from the so-called problems of feminine hygiene. PAn. 5. 'With reference to the product designated and known as ''Shade's Anti:;;eptic Powder" such statements as the following are l11nde:

Vaginal donchlug Is ~>o Important to lwnlth that dainty womrn cannot afford to 1Wglrct ft. Douehlug should hr prnctlcrd rrgnlarly by every woman, and ~'~<lJ<·clnlly thp marrlt•'l woman. f;l'crl'tious in the marital state are more frequl'ut n n<l opportnnitl<'s for infl'ctlou ore increnHPd. Shndt>'s Antl~rptlc Powdrr not only promotrs cleanliness and health, but also d('l!troys bnet<'rln, nnd It soothrs and heals the delicate tissues. . Findings 25 F. T. C. Two teaspoonfuls of the powder to 2 quarts of warm water, used daily, in Leucorrhea (Whites), Vaginitis and Cervicitis. It destroys unpleasant odors, and produces that wonderful feeling of inner cleanliness, so much desired by every dainty woman. Through said statements, and in other statements ~f similar import, with respect to the product "Shade's Antiseptic Powder," the respond~:mt represents and implies, and the purchasing public is thereby led to believe, that said product promotes cleanliness and good health; that it destroys bacteria and soothes and heals delicate tissues, and that it is an efficient treatment for leucorrhea (whites), vaginitis and cervicitis and destroys unpleasant odors. The product "Shade's Antiseptic Powder" does not promote cleanliness and good health, destroy bacteria nor does it soothe and heal delicate tissues; said product is not an efficient treatment for leucorrhea (whites), vaginitis and cervicitis and its use has no beneficial effects in the treatment of such conditions, nor will it destroy unpleasant odors. PAR. 6. In the conduct of his business as aforesaid the respondent uses in his advertisements the name "Bureau of Education" in connection with other statements in the advertising matter in such 11 manner as to represent and imply, and thereby lead the purchasing public to believe, that the "Bureau of Education" is a separate organization or institution in no wise connected with the business of the respondent, organized for the purpose of carrying on scientific research in the methods of preventing, treating or curing maladies peculiar to women, and that respondent's products have been tested or approved by such organization or institution. There is no such organization as the "Bureau of Education" organized for the purpose of carrying on scientific research in the methods of preventing, treating or curing maladies· peculiar to women, and respondent's products have not been tested by such an organization. The so-called "Bureau of Education" is simply a name adopted by the respondent to use in furtherance of the sale of his said products. There are among respondent's competitors in said commerce many who truthfully represent their products and the nature of their organization.

PAn. 7. The representations and implications used by the respondent as above set out in connection with the offering for sale and sale of the products herein described in said commerce are false, misleading and deceptive and have had, and now have, the tendency and capacity to, and do, mislead and deceive many members of the purchasing public and cause them erroneously to believe that said representations are true and cause them, because of said erroneous belief, to purchase substantial quantities of respondent's said products, H. SHADE'S LABORATORIES, E'l;O. 927 fll7 Order thereby unfairly diverting trade in said commerce to the respondent from his competitors who truthfully represent their products to the substantial injury of said competitors in said commerce and to the injury of the public.

CONCLUSION The aforesaid acts and practices of the respondent, Oliver L. Von Bachelle, 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 2G, 1914, entitled "An Act to create a Federal 1'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 and the answer filed herein on July 1G, 1037, by respondent admitting all the material allegations of the complaint to be true and waiving the taking of further evidence and all other intervening procedure, 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 2G, 1014, 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, Oliver L. Von Bachelle, an individual, doing business as H. Shade's Laboratories, and as Bureau of Education, H. Shade's Laboratories, or under any other name, his representatives, agents and employees in connection with the offering for sale, sale and distribution of the medicinal or pharmaceutical }n·eparations now designated Shade's Cones, Shade's Suppositories and Shade's Antiseptic Powder, or any other preparations of substantially the same ingredients and therapeutic efficacy, whether designated by the aforesaid names or by any other names, in interstate commerce or in the District of Columbia, do forthwith cease and desist from representing or implying in connection with the offering for sale, sale and distribution of any of said products. 1. That said product is efficacious for use in the prevention, treatll1ent and cure of diseases, ailments and conditions peculiar to women arising out of the so-called problems of feminine hygiene; 2. That said product is safe for general use; 3. That said product solves the problems of feminine hygiene; 158121m---a9----59 Order 25F.T.C.

4. That said product is an efficient prophylactic where the possibility of venereal disease infection is present; 5. That said product relieves inflammation and is soothing to irritated or delicate membranes ;

6. That said product is more effective than carbolic acid or chlorine in the prevention, treatment and cure of diseases, ailments and conditions peculiar to women arising out of the so-called problems of feminine hygiene;

7. That the use of said product deposits a protective film or coating over the membrane which remains effective for a long period of time;

8. That said product is a deodorant and that its use will assure the user of protection from embarrassing odors arising from the so-called problems of feminine hygiene;

9. That said product forms a protective film which is powerfully germicidal ;

10. That said product promotes cleanliness and good health, dee.troys bacterial and soothes and heals delicate tissues or membranes; 11. That said product is an efficient treatment for leucorrhea (whites), vaginitis and cervicitis, or has a beneficial effect in the treatment of such ailments or conditions, or that it will destroy unpleasant odors;

12. That, through the use of the words "Bureau of Education" or other words, said products have been submitted to or approved by an institution organized for the purpose of carrying on scientific research in the methods of treating and curing maladies peculiar to women, and that respondent's products have been tested by such an organization. · It is, further ordered, That the respondent shall, within 60 days after service upon it of this order, file with the Commission a report in writing setting forth in detail the manner and form in which it has complied with this order.

PIGRO CHAMOIS CO. 929 Syllabus