Rocky Mountain Laboratories, Inc., and James W. Fitches

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IN THE MATTER OF ~OCKY MOUNTAIN LABORATORIES, INC., AND JAMES "\V. FITCHES "COMPLAINT, FINDINGS, AND ORDER IN REGARD TO THE ALLEGED VIOLATION OF SEC. 5 OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1914 Docket 2953. Complaint, Oct. 20, 1936-Decision, Mar. 29, 1938 'Where a corporation and an individual, its presid£-nt and general manager, engaged in manufacture, distribution and sale in commerce of a pharmaceutical preparation called "Biotone"; in adv£-rtising same in newspapers and periodicals of general circulation throughout the United States, and through advertising folders and literature printed and circulated through the various States to customers and prospective customers, and by radio broadcasts- {a) Represented that said pr£-paration was natural solution for all health problems and that average individual was not getting the elements from his food supply to maintain normal chemical balance in the body, and· that such elements were supplied by said "Biotone"; (b) R£-presented that most common ailments have their origin in the digestive system and that "Biotone" had healiug qualities that corrected serious disorders, and aided nature in its natural cleansing, building, and normalizing process of the body and helped to neutralize acids therein and combat and eliminate toxins, build sound healthy tiss.!les, and promote vigorous normal body functions; and (c) Represented that said ''Biotone" was a helpful remedy for malnutrition, loss of appetite, lack of energy, stomach ulcers,. and various other ailments and conditions;

ll'acts being normal average American food supply furnishes enough chemical substances to keep body normal without supplementing diet by medicine, said preparation was not a helpful remedy in cases of malnutrition, blgb blood pressure, etc., generally caused by or directly associated with serious systemic or metabolic disorders, most common ailments do not have their origin in digestive system nor are great majority of common ailments of humanity traceable to unbalanced body chemistry resulting in acidity, toxemia, or mineral deficiency, natural cleansing, etc., processes cf the body do not need aid of any medicine or chemical to take place and function properly, ingredients in said preparation were present in such small Quantities as to be totally ineffective, and aforesaid repres£-ntations as to functioning and values of said preparation in aiding nature, etc., and with respect to Its curative and remedial qualities were grossly exaggerated, false, misleading, and untrue;

\with tendency and capacity to mislead and deceive a large portion of purchasing public into erroneous belief that all said representations were true and that preparation possessed substantial therapeutic value, and with result that a number of said public, as direct consequence of such erroneous beliefs, bought substantial volume of said product and trade was Unfairly diverted to them from Individuals and roncerns likewise engaged ln sale of other preparations designed and Intended for simllar usage, and FEDERAL TRADE COJ\lmission DECISIONS984 Complaint 2GF.T.C· who truthfully advertise efficacy of their products; to the substantial injury of competition in commerce :

Held, That such acts and practices were to the prejudice of the public !lnd competitors and constituted unfair methods of competition. Before Mr. Oha:rules P. Vicini and Mr. Robert S. !!all, trial examiners.

Mr. George Foulkes for the Commission.

llfr. James TV. F-ilches, of Salt Lake City, Utah, for respondents. Complaint 1 Pursuant to the provisions of an Act of Congress, approved September 26, 1914, entitled "An Act to create a Federal Trade C01n· mission, to define its powers and duties, and for other purposes," the Federal Trade Commission, having reason to believe that James '"· Fitches, an individ)..tal, and Rocky Mountain Laboratories, Inc., a cor· poration, hereinafter referred to as respondents, have been and are using unfair methods of competition in commerce, as "commerce" is defined in said act of Congress, and it appearing 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. Respondent, Rocky Mountain Laboratories, Inc. is a corporation existing and doing business under the laws of the State of Utah, with its principal office and place of business located at 18 'Vest Second South Street, Salt Lake City, Utah. Respondent, James ,V. Fitches, also of Salt Lake City, Utah, Wlll president and manager of respondent, Rocky Mountain Laboratories, Inc., during the time of its corporate existence, and controlled, tnan· aged, and directed the business activities, sales policies, and tnnlsactions of said corporate respondent, Rocky Mountain Laboratories, Inc., and used said corporation as an instrumentality and agency to accomplish such things as he proposed and planned. Respondent, Rocky Mountain Laboratories, Inc., and respondei:t, James ,V. Fitches, are now, and have been for some time engaged 111 the business of manufacturing, distributing, and selling in coiW merce, as herein set out, a medicinal preparation designated ns "Biotone."

PAR. 2. Said respondents, being engaged in business as aforesaid, caused said medicinal preparation when sold, to be transported frolll their respective offices and places of business in the State of l7tah to purchasers thereof, located at various points in States of the United States other than the State from which said shipments were 1 Published as amended to conform to proof by order dated March 18, 1938. ROCKY MOUNTAIN LABORATORIES, INC., ET AL. 985 Complaint Inade. Both respondents have maintained, and now maintain, a constant current of trade in commerce in said meuicinal preparation, manufactured, distributed, and sold by them between and among the v-arious States of the United States and in the District of Columbia. PAR. 3. In the course and conduct of their respective businesses, both said respondents are now and ha\e been in substantial competition with other corporations, and with individuals and firms likewise engaged in the business of manufacturing, distributing, and selling medicinal preparations and kindred remedies :for the same ailments for which said respondents represent "Biotone" to be a remedy, in commerce among and between the various States of the United States and in the District of Columbia.

In the course of operation of their respective businesses and for the purpose of inducing individuals to purchase "Biotone" both respondents have caused advertisements to be inserted in newspapers and magazines of general circulation throughout the United States and have printed and circulated throughout the various States to customers and prospective customers advertising folders and literature. Both respondents have caused statements and representations concerning the curative and remedial quality of "Biotone" to be made over radio broadcasts. Certain advertising matter used b:y said respondr,nts in making said representations, and certain statements made or caused to be made by said respondents over radio stations are set out herein, as illustrative of said representations, but are not all-inclusive. Such advertisements and statements are as follows:

:BtOTONE-THE :NATURAL SOLUTION FOR YOUR HEALTH PROBLEM:\l. The average family is not getting the elements from its food supply necessary to maintain no1·mal chemical balance.

l\Iost common ailmeuts have their origin in the digestive system. Because of the natural healing qualities of BIOTONE and its normalizing a.ud alkalizing effects, it has proven a most remarkable corrective for many or the more serious stomach and intestinal disor·ders. It helps to neutralize acids, combat and eliminate toxins, the building of 8011nd, healthy tissues, and the promotion of vigorous, normal body functions. Especially helpful in malnutrition, loss of appetite, lack of energy, languidness and depleted vitality.

BIOTONE g!'ts results even when all other methods have failed. The basic causes of most ailments are Acidity, Toxemia, and lack of the ;s~t:>ntial el!'ments which the body must have. BIOTONE corrects all those 0111ldations of illness, by neutrallzlng acids and toxins and supplying the body '1\>lth these vital elements.

It Your bloodstream and the vital fluids of the body are normally alkaline ~ou cannot keel from enioyin~: health and ,·itality. But the big trouble is, lat our modern methods of eating devitalized, demineralized and refined foods11 ellrives us of the essential elements to maintain a normal chemical balance. Complaint 2GF.T.C· The lack of even one or two of these important substances may result ID serious physical and mental disturbances. The absence of several of tbein may bring about a complication of said symptoms. Sour stomach, gastritis, internal ulcers, high blood pressure, rheumatism. arthritis, eczema aud many others are the result of chemical deficiencies. .All acid condition proves the lack of sodium, magnesium and cblorin. A toxic con· dition proves the lack of sufficient sulphur, potassium, iodin, iron, manganese, phosphorus and similar elements. We urge the use of BIOTONE as the real and quick solution to these deficiency disorders. By the use of advertisements in newspapers, pamphlets, testimonials, and over the radio, both respondents represent that : 1. Biotone is the natural solution for an health problems. 2. The average individual is not getting the elements from his food supply to maintain a normal chemical balance in the body, and that Biotone supplies these elements.

3. The most common ailments have their origin in the digestive system, and that Biotone bas healing qualities that correct serious stomach and intesU· nal disorders.

4. Biotone aids nature in its natural cleansing, building and normalizing processes of the body and helps to neutralize acids in the body, and combat and eliminate toxins, and aids in building healthy tissues and the promotion of vigorous healthy body functions.

5. Biotone is a helpful remedy for malnutrition, loss of appetite, lack of energy, languidness, depleted vitality, ulcers of the stomach, liver trouble, prostatitis, eczema, high blood pressure, acidity, toxemia, sour stomach, gas· tritls and rheumatism.

PAR. 4. Representations made by said respondents with respect to the curative and remedial qualities of Biotone when used, are grossly exaggerated, false, misleading, and untrue. In truth and in fact Biotone is not a natural solution for all health problems, and it is not true that the average individual is not getting the elements from his food supply necessary to maintain normal chemical balance in the body. In truth and in fact the most common ailments do not have their origin in the digestive system, and Biotone does not hav-e healing qualities of such a character as to correct serio.us stomach and intestinal disorders. Biotone does not aid nature in its natural cleansing, building and normalizing processes of the body, and ~t does not help to neutralize acids in the body, or to combat and eliml· nate toxins. Biotone does not aid in the building of healthy tissn~ 5 or in the promotion of vigorous healthy body functions. Biotone 19 not a helpful remedy for malnutrition, loss of appetite, lack of energy, languidness, depleted vitality, ulcers of the stomach, Ji•er trouble, prostatitis, eczema, high blood pressure, acidity, toxe~uia, sour stomach, gastritis, and rheumatism.

PAR. 5. Each and all of the false and misleading statements and representations, made by both respondents, as hereinabove set forth, in their advertising in newspapers, magazines, pamphlets, and other ROCKY MOUNTAIN LADORATORIES1 INC., ET AL. 987 983 Findings advertising literature, in offering for sale and selling Biotone, had and now has the tendency and capacity to mislead and deceive a large portion of the purchasing public into the erroneous belief that all of said representations are true. Further, as a direct consequence of the stated misleading, mistaken, and erroneous beliefs, induced by advertisements and statements of both respondents, as hereinabove enumerated, a number of the purchasing public purchased a substantial volume of respondents' product with a result that trade has been Unfairly diverted to respondents :from individuals, firms, and cor- Porations likewise engaged in the business of selling medicinal preparations, who truthfully advertise their products. As a result thereof, substantial injury has been done and is being done by both respondents to competition in commerce, among and between the l>arious States of the United States and in the District of Columbia. PAR. 6. The above and foregoing acts, practices, and representations of the respondents have been, and are, all to the prejudice of the public and respondents' competitors, as aforesaid, and are U:Q.fair lllethods of competition 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.

REPORT, FINDINGS AS TO THE FACTs, AND Onder Pursuant to the provisions of an Act of Congress approved September 26, 1914, entitled "An Act to create a Federal Trade Comlllission, to define its powers and duties, and for other purposes," ~he Federal Trade Commission, on October 26, 1936, issued and served Its complaint in this proceeding upon Biotone Laboratories, Inc., a corporation, and Rocky Mountain Laboratories, Inc., a corporation, charging them with the use of unfair methods of competition in Commerce in violation of the provisions of said act. After the issuance of the complaint and the filing of respondents' answers thereto, testimony and other evidence in support of the allegations of the co~plaint were introduced by George Foulkes, attorney for the Comll1Ission, and in opposition to the allegations of the complaint by ~ames ·w. Fitches, who appeared on behalf of both respondents, efore Charles P. Vicini and Robert S. Hall, examiners of the Com· lnission theretofore duly designated by it, and said testimony and Other evidence was duly recorded and filed in the office of the Com- ~ission. The chief counsel filed a motion to amend the complaint th conform to the proof contained in the record by deleting from . e ~complaint Diotone Laboratories, Inc., as respondent, and inserting In heu thereof James W. Fitches, an individual, as respondent, and FEDERAL TRADE COMMISSION DECISIO~S 988 Flu dings 26F. T.C.

it appearing that the respondents had due notice of the pendency of said motion, the motion of the chief counsel was granted. Thereafter the proceeding came on for final hearing before the Commission on said complaint and answer thereto, testimony and other evidence and brief in support of the amended complaint, respondents not having filed briefs, and having not requested oral arguments herein; and the Commission having duly considered the same and being now fully ad vised 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 FACTS PARAOnAPH 1. The respondent Rocky Mountain Laboratories, Inc., is a corporation existing and doing business under the laws of the State of Utah with its office located at 18 ·west Second South Street, Salt Lake City, Utah.

In the year 1936 respondent Rocky Mountain Laboratories, Inc., became inactive, and respondent James ,V. Fitches became trustee of the corporate property.

Respondent James \V. Fitches, also of Salt Lake City, Utah, was president and general manager of respondent Rocky Mountain Lab· oratories, Inc., during the time of its corporate activity, and controlled, managed, and directed the business activities, sales policies, and transactions of the respond£>nt Rocky Mountain Laboratories, Inc., and used said corporation as an instrumentality and agency to accomplish such things as he proposed and planned. There is a possibility that respondent James ,V. Fitches may again organize respondent Rocky Mountain Laboratories, Inc., for the purpose of resuming sales of its principal commodity, "Biotone." Respondent James W. Fitches now holds title to the said product "Biotone" as trustee of respondent Rocky Mountain Laboratories, Inc· Respondent Rocky :Mountain Laboratories, Inc., and respondent James 1V. Fitches ha,·e for some time last past been engaged in the business of manufacturing, distributing, and selling in commerce a. pharmaceutical preparation designated as "Diotone." PAn. 2. The respondents caused the medicine designated "Biotone," when sold, to be transported from their principal office and place of business in the State of Utah to purchasers thereof located at various points in States of the Unih•d States other than the State fronl which said shipments were made.

Respondents have maintained a course of trade in commerce in said preparation, manufactured, distributed, and sold by them be· twt>en and among the variou<; States of the United States and in the District of Columbia.

ROCKY MOUNTAIN LABORATORIES, INC., ET AL. 989 983 Findings PAR. 3. In the operation of their business, respondents have been in substantial competition with other corporations and with indi- "Viduals and firms likewise engaged in the business of manufacturing, distributing, and selling other preparations and treatments for the same ailments for which the respondents represent "Biotone" to be a remedy, in commerce among and between the various States of the United States and in the District of Columbia. Respondent Rocky Mountain Laboratories, Inc., and respondent James ,V. Fitches caused advertisements descriptive of said preparation to be inserted in newspapers and magazines of general circulation throughout the United States, and have printed and circulated throughout the various States, to customers and prospective custotners, similar advertising folders and literature. The respondents have also caused statements and representations concerning the curative and remedial quality of "Biotone" to be made over radio broadcasts.

Certain advertising matter used by the respondents in making the aforementioned representations, and certain statements made or caused to be made by respondents onr radio broadcasts are as follows: lHOTONE-TflE NATURAL SOLUTION FOR YOUR HEALTH PROBLEl\L The m·erage family Is not getting the elements from its food supply necessary to maintain normal chemical balance.

Most common ailments liaYe their ot·igin in tbe digestive system. nf'cau;;e of the natural healing qualities of BIOTONE and its normalizing and alkalizing effects, it has proven a most remarkable corrective for many of the more serious stomach and Intestinal disorders. It helps to neutralize acids, combat and eliminate toxins, the building of sound healthy tissues, and the promotion of vigorous, normal body functions. Especially helpful in malnutrition, loss of appetite, lack of energy, languid~ ness and depleted vitality.

BIOTONE gets results even when all other methods have failed. The basic causes of most ailments are Acidity, Toxemia, and lack of the ;essential elements which the body must have. BIOTONE corrects all those boundations of illness, by neutralizing acids and toxins and supplying the Ody With these vital elements.

It Your bloodstream and the vital fluids of the body are normally alkaline l·oth u cannot keep from enjoying health and vitality. But the big trouble Is, f at our modern methods of eating devitalized, demineralized and refined loods•Ilia deprives us of the essential elenwnts to maintain a normal chemicalr nee. The lack of even one or two of these Important substances may t~8111t In ~>erions physical and mental fli~turbanc£>s. The ab;;ence of ~;;several of ern may bring about a complication of said 11ymptoms. Sonr stomach, gastritis, Internal ule£>rs, high blood pressure, rl1eumatism,111 n. ·~britts, I.'Czema, and many others are the result of chemical deficiencies. An n(J(' d Condition pro¥es the lack of sodium, magnesium and chlorln. A toxic ' lld"t•1n ton pro\"es the lack of sufficient sulphur, potassium, Iodin, Iron, manga- I"S(> "l htl" ' .. Josp orus and similar elem£>nts. \Ve urge the U!'!e of BIOTO~E ns the 81 &nd quick solution to these deficiency disorders. 160451"'-39-vos:.. 26---65 Findings 26F. T.C.

By use o£ advertisements in newspapers, pamphlets, testimonials, and over the radio, both respondents represent that: 1. Biotone is the natural solution for all health problems. 2. The average individual is not getting the elements from his food liUPJllY to maintain a chemical balance in the body, and that Biotone sull!Jlie::; thes~: elements.

3. The most common ailments have their origin in the digestive system. and that Biotone has healing qualities that correct serious stomach anli Jntestlnal disorders.

4. Biotone aids nature in its natural cleansing, building and normalizing processes of the body and helps to neutralize acids in the body, and comb1tt and eliminate toxins, and aids in building healthy tissues and the promotion of vigorous healthy body functions.

5. Biotone is a helpful remedy for malnutrition, loss of a11pet1te, lack of energy. languidness, depleted vitality, ulcers of the stomach, liver trouble, prostatitis, eczema, high blood pressure, acidity, toxemia, sour stomach, gastritis, and rheumatism.

An analysis of the commodity "Biotone" shows that it is made up as follows:

Silica ( Si02) --------------------------- 317.0 parts per million Calcium ( Ca) -------------------------- 125. 0 " " Magnesium (1\Ig)---------------------- 1G5. 0 " " " Sodium (Na>--------------------------- 34.0 " " Potassium (K>------------------------- 55.0 " Phosphorus (P205) -------------------- 5. 0 " Chlorides (Cl) ------------------------- 122. 0 " ·" Sulphur ( S) --------------------------- 373~. 0 .. Iron (Fe)------------------------------ 5153. 0 " Alumina (AI)-------------------------- 228.0 '' l\Ianganese ( l\In) ----------------------- 5. 0 " " Notrogen (N>-------------------------- 64.0 " Carbon (C)---------------------------- 974. 0 " Iodine (I>----------------------------- Trace PAR. 4. The foregoing representations made by respondents with respect to the curative and remedial quality of "Biotone" when used are grossly exaggerated, false, misleading, and untrue. In truth and in fact the normal average American food supply furnishes enough chemica} substances to keep the body normal, and it is not necessary to supplement the diet by taking internally any medicine. "Biotone" is not a helpful remedy in cases of m~l­ nutrition, high blood pressure, ulcers of the stomach, prostatitis, rheumatism, gastritis, and eczema. The aforesaid conditions and ailments are generally caused by or directly associated with serious systemic or metabolic disorders and do not respond to treatm_ent~ containing ingredients similar in their properties to those cont:une in respondents' preparation. Said preparation is not a helpful ROCKY 1\IOUNTAIN LABORATORIES, INC., ET AL. 991 983 Findings remedy in cases of loss of appetite, or in cases of lack of energy. Said preparation is not of any value in cases of liver trouble, acidity, sour stomach, and toxemia. In the treatment of such cases a diagnosis is necessary and no medicine such as respondents' compound could be applied in all cases.

The most common ailments do not have their origin in the digestive system, and respondents' preparation does not have healing quality of such a character as to correct serious stomach and intestinal disorders.

Respondents' preparation does not aid nature in its natural cleansing, building, and normalizing processes of the bod)·, and it does not help to neutralize acids in the body or to combat and eliminate toxins.

"Nat ural cleansing, building, and normalizing processes of the body" mean the normal processes of eating, digesting, assimilating, and eliminating food material maintaining it by normal adequate intake of food, and the average individual does not need the aid of any medicine, chemical, or chemical compound for the cleansing, building up, or for the so-called normalizing processes to take place. The great majority of the common ailments of humanity are not traceable to unbalanced body chemistry, resulting in acidity, toxe.rnia, or mineral deficiency.

From the expert testimony adduced at the hearings, it is found that the ingredients of respondents' preparation are present in such ~.mall quantities as to be considered totally ineffective. Many of the lngredients present in the preparation are in no higher concentration ,than may be found in ordinary drinking water. Even if the system is deficient in some element or necessary ingredients, the amount of said element or ingredient in respondents' preparation is so minute n.s to render it ineffectual in supplying the deficiency. The only illgnificant ingredients in respondents' preparation are iron and alutninum. The physiological effects of such quantities of aluminum ~s are contained in the preparation are negligible. The amount of ~ron that is contained in three teaspoonsful of the preparation, which ~s the prescribed dose per day, is equivalent to about one grain of lron per day. In certain deficiency diseases, varying dosages of iron tnay be prescribed .

. PAn. 5. The abm·e fabe and misleading statements and representa- ~lons, made by respondents, as above set forth, in their advertising 111 newspapers, magazines, pamphlets, and other advertising literat~re, in offering for sale and selling "Biotone," had and now have t fe tendency and capacity to mislead and deceive a large portion 0 the purchasing public into the erroneous beliefs that all the said Order 26F.T.C.

representations are true and that said preparation possesses sub· stantial therapeutic value.

As a direct consequence of the stated mistaken and erroneous beliefs as hereinbefore enumerated, a number of the purchasing pub· lie purchased a substantial volume of respondents' product, with the result that trade has been unfairly diverted to respondents from individuals, firms, and corporations likewise engaged in the busines~ c:.f selling other preparations designed and intended for similar usag~, who truthfully advertise the efficacy of their products. As a result thereof, substantial injury has been done, and is being done, by respondents to competition in commerce among and between the various States of the United States and in the District of Columbia. CONCLUSION The aforesaid acts and practices of respondents Rocky Mountain Laboratories, Inc., a corporation, and James ,V, Fitches, an individual, are to the prejudice of the public and of respondents' competitors, and constitute unfair methods of competition in commerce within the intent and meaning of Section 5 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." ORDER TO CEASE AND DESIST This proceeding having been heard by the Federal Trade Comn1is· sion upon the amended complaint of the Commission, the answer of respondents, testimony and other evidence taken before Charles p. Vicini and Robert S. Hall, examiners of the Commission, theretofore duly designated by it, in support of the allegations of the complaint and in opposition thereto, and brief in support of the complaint, re· spondents having filed no brief and having not requested oral argll· ment, and the Commission having made its findings as to the facts and its conclusion that said respondents have violated the provisioll5 of an Act of Congress approved September 26, 1914, entitled "An _A.ct to create a Federal Trade Commission, to define its powers and duties, and for other purposes."

It is ordered, That the respondents Rocky Mountain Laboratories, Inc., a corporation, and James W. Fitches, an individual, their officers, representatives, agents, and employees1 in connection with the offer· ing for sale, sale, and distribution of a pharmaceutical product no"' known as "lliotone" or any product containing the same or substa.Ild tially the same ingredients, and possessing similar properties, s~l under that name or any name, in interstate commerce or in the Distrtct of Columbia, do forthwith cease and desist from representing: ROCKY MOUNTAIN LABORATORIES, INC., ET AL. 993 983 Order 1. That said preparation is the natural solution for all health problems.

2. That the average individual is not getting the elements from his food supply necessary to maintain a normal chemical balance of the body, and that "Biotone" supplies these elements. 3. That the most common ailments have their origin in the digestive system, and that said preparation has any healing qualities that correct stomach and intestinal disorders.

4. That said preparation aids nature in its natural cleansing, build- Ulg, and normalizing processes of the body, helps to neutralize acids in the body, combats and eliminates toxins from the body, or aids in building healthy tissues and the promotion of vigorous, healthy body functions.

5. That said preparation has any beneficial value whatsoever for the treatment of malnutrition, loss of appetite, lack of energy, languidness, depleted vitality, ulcers of the stomach, liver trouble, prostatitis, eczema, high blood pressure, acidity, toxemia, sour stomach, gastritis, and rheumatism, or similar diseases, ailments or conditions. It is further ordered, That the respondents shall, within 30 days after service upon them of this order, file with the Commission a report in writing setting forth in detail the manner and form in which they have complied with this order.

994 FEDERAL TRADE UU~E\IISSION DECISIONS Syllabus !WF.T.C.