Kressin, Maurice

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

IN THE MATTER OF MAURICE KRESSIN, TRADING UNDER THE NAME UNITED DELIVERY SYSTEM-, AND ESTHER KRESSIN COMPLAINT, FINDINGS, AND ORDER IN REGARD TO THE ALLEGED VIOLATION OF SEC. 6 OF AN ACT OF CONGRESS APPROVED SEPT. 26, 1914 Docket 4873. Complaint, Nov. 24, 1942-Decision, May 1, 1944 Where a husband and wife engaged in the interstate sale and distribution of postcards, envelopes, and form letters, designed to be used by creditors and collection agencies in obtaining information concerning debtors-the cards, addressed to "UNITED DELIVERY SYSTEM, Distribution Department, 639 NEW YORK AVENUE, N. W., WASHINGTON, D. C." and containing on the reverse side, among other matter, "Return this notice promptly, UNITED DELIVERY SYSTEM, Distribution Department, UNCLAIMED PACKAGE DIVISION, WASHINGTON, D .•c., Package Reference Number, A package bearing your name and address is held at your risk·subject to your forwarding directions below." and "CONSIGNEE MUST BE IDENTIFIED"; under the instruction "Deliver the Above Package to" calling for name and address of debtor and, under "For Identification I Refer You to My Employer and bank," their name and address: and the form letters, using the same trade name and address, and such matter as "f..IERCHANDISE, Distribution Department, Specialists in Package Deliveries" and other statements calculated to create the impression of a storage, shipping and distribution concern, including the words" Unclaimed Package Division," inquiring of the recipient when addressed to other than debtors, as to whether he could advise as to the present address of the debtor, and stating that "we have a package addressed to the above party and we understand that there has been some change in their address." and "We would appreciate your kindness in advising us of their present location"; and that they were "enclosing a self addressed and stamped envelope, and would appreciate any information," etc.; and, where employed for contacting the debtors directly, having appropriate changes such as "we have a package for you which we would like to complete delivery of," etc.; and in both cases, including bl(lonks for the name and address of the debtor and those of his employer and bank;

Making use of a plan under which material in question was sent by them-along with unaddressed envelopes bearing their return address and a notation "Postmaster- Important. If this letter cannot be delivered to address shown, please forward to last address."-to their customers, who addressed the envelopes to the last known addresses of the debtors about whom information was sought and returned them in bulk to said persons in Washington, who there mailed said material to the debtors, sent to the customers, identified by a code number placed on the forms, the information received, and sent to debtors replying thereto a few paper cups or a six-inch cardboard ruler or some similar article of trivial value "in order to comply with the post office regulations"- Falsely represented, through use of said name, "United Delivery System," and placed in the hands of others the means of representing, through use of said cards and form letters, to the debtors and others, that the information was desired for use in connection with the delivery of goods to the proper consignees; The facts being said name as thus used was merely a disguise to conceal from the addressee the true nature of said persons' business; 591546DL-46-vol. 38--29 410 FEDERAL TRADE. COMMISSION DECISIONS Complaint 38 F. T. C.

With capacity and tendency to mislead and deceive the addressees of said matter, and cause them to furnish said persons with information which would not have been furnished if the true purpose of their inquiry were known: \. Held, That such acts and practices, under the circumstances set forth, were all to the prejudice and injury of the public and constituted unfair and deceptive acts and practices.

Before Mr. John L. Hornor, trial examiner.

Mr. Randolph W. Branch for the Commission.

Mr. Albert Brick, of Washington, D. C., for respondents. COMPLAINT Pursuant to the provisions of the Federal Trade Commission Act, and by virtue of the authority vested .in it by said act, the Federal Trade Commission, having reason to believe that Maurice Kressin, an individual, trading tinder the name United Delivery System, and Esther Kressin, an individual, hereinafter referred to as respondents, have violated the provisions of said act, and it appearing to the 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, Maurice Kressin, is an individual, trading under the name United Delivery System, with an office and principal place of business at 639 New York Avenue, N. W., Washington, D. C. Respondent, Esther Kressin, is the wife of respondent, Maurice Kressin, and is inactive and actual charge of the business carried on by her husband under the name United Delivery System.

PAR. 2. Respondents are now, and have been for more than three years last past, engaged in the business of selling and distributing postcards, envelopes and forms designed and intended to be used by creditors and collection agencies in obtaining information concerning debtors. Respondents cause the said postcards, envelopes and forms to be transported from their aforesaid place of business in the District of Columbia, to purchasers thereof in various States of the United States. Respondents maintain, and at all times mentioned herein have maintained, a course of trade in said postcards, envelopes and forms in commerce between and a:qwng the various States of the United States and in the District of Columbia.

PAR. 3. The said cards sold and distributed by respondents are in the form exemplified by a photostatic copy thereof marked Exhibit A, attached hereto and by this reference incorporated herein and made a part hereof; the said forms so sold and distributed are in the forms exemplified by photostatic copies thereof marked Exhibits B and C, attached hereto, and by this reference incorporated herein and made a part hereof. PAR. 4. In the space for "Package Reference No." on the cards, as exemplified by Exhibit A, 1 when they are delivered to purchasers thereof, respondents have placed numbers which are their serial numbers for identifying their customers to them.

Respondents' purchasers cause the said cards to be placed in envelopes, in the upper left hand corners of which appear: If not delivered return to United Delivery System Merchandise Distributors 639 New York Avenue, N. W.

Washington, D. C., 1 See opposite page.

UNITED DELIVERY SYSTEM ET AL. 411 409 Complaint attach the necessary' postage and cause them to be deposited in the United States mail.

Such of the return cards as are filled out and mailed are received by respondents and sent by them to the proper customers who are identified by the serial numbers.

Respondents then send to the debtors about whom information has been sought 6 inch rulers made of cardboard.

[Exhibit A] PLACE A ONE CENT STAMP HER !I THIS SIDE FOR ADDRESS ONLY UNITED DELIVERY SYSTEM Distribution bepa~tment 639 NEW YORK AVENUE, N. W.

WASHINGTON, D. C.

i "{ :II I I I:I I I I I I I I I I'I I ., ·~ a' (J .z . Complaint 38 F. T. C. PAR. 5. Upon the forms as exemplified by Exhibit B1 when they are delivered to purchasers thereof, respondents have placed numbers which are their serial numbers and identify the customers to them. The purchasers insert opposite the word "Consignee" the name of the person concerning whom information is sought, and insert his last known address in the spaces opposite "Street," "City," and "State." Said purchasers then insert the forms in envelopes, purchased by them from said respondents, which they cause to be addressed to the persons concerning whom information is sought. Upon these envelopes in the upper left hand corner appears:

If not delivered return to United Delivery System Merchandise Distributors 639 New York Avenue, N. W., Washington, D. C.

With the said fotms are also enclosed envelopes, also purchased from said respondents, to which said purchasers have attached the necessary postage; these envelopes are addressed to United Delivery System Distribution Department 639 New York Avenue, N. W.

Washington, D. C.

Said purchasers then cause the said envelopes, properly stamped, and their enclosures, to be delivered to respondents at their place of business aforesaid, and respondents cause them to be deposited in the United States mail. Such replies as are ret11rned are received by respondents, . who identify the customers by the code numbers heretofore mentioned, and send the replies to the proper customers. Respondents also send to each of the persons concerning whom the desired information has been received, a 6 inch cardboard ruler.

In the space opposite "File No." on the forms exemplified by Exhibit C,2 when they are delivered to purchasers thereof, respondents have placed numbers which are their serial numbers, and identify the customers to them. These forms are used when information concerning an alleged debtor is sought from some person other than the debtor, and they are used and handled in a manner substantially identical with that in which the forms exemplified by Exhibit Bare handled as hereinabove set forth. PAR. 6. By means of the aforesaid cards, envelopes and forms, re~ spondents have falsely represented, and placed in the hands of their customers means of falsely representing, directly and by implication, to customers' debtors, and others from ·whom information concerning such debtors is sought, that such debtors are consignees of packages sent by someone other than respondents, and in the hands of respondents in the usual course of their business; that the packages were of more than the trivial value of a 6 inch pasteboard ruler, and that delivery could not be made by reason of change in the address of the consignee. PAR. 7. Through the use of the name "United Delivery System" !respondents have represented, directly and by implication, that they are m some capacity connected with the movement and transportation of goods and their delivery to the proper consignees. The said name is merely a disguise for the true nature of respondents' business. ' 1 See opposite page.

See page 414.

UNITED DELIVERY SYSTEM ET AL. 413 409 Complaint PAR. 8. The said representations were false and misleading. In truth and in fact respondents' businesfl has, so far as the recipients of said cards and forms are concerned, nothing whatever to do with the movement or transportation of goods or their delivery to the proper consignees. The persons with respect to whom the said cards and forms are intended to elicit information are not consignees of packages sent by others than respondents and in the hands of respondents. The packages to which the [Exhibit B] UNITED DELIVERY SYSTEM Distribution Department EXECUTIVE OFFICES Phone Connections Specialists in Package 639 NEW YORK AVENUE, N. W. Cable Addrese Deliveries Waahiagtoa, D. C. •• Arrange'' Contracts made for Consignee ---------·-·---------------·--------------the distribution of all kinds of Street --------------------------·------------------advertising nu~.tter, trade papers, City-------------------------------State -----------publications, and general merchandise We have a package for you which we would like to comby uniformed force plete delivery of, but due to some change in address we will appreciate it if you will send us your present and correct address in order to make immediate and proper delivery. * * We are inclosing herewith a self-addressed and stamped STORAGE AND envelop~ for your reply. We would appreciate it if you fill SHIPPING in the following and return at your earliest convenience. Very truly yours, * * UNITED DELIVERY SYSTEM. Merchandise and For the purpose of complete identification all of the data advertising matter below is required. received In carload or less than carload lots stored, broken Name ----- •• __ • ___ -------------·----.---------- •• --up and delivered or reshipped by Address _----------- _-----------·------------------- -parcel poet, Fermer Address _------------ ____ --- ____ ----------- __ . freight or express Pool oar distributing Name of present employer ---------------------------- and forwarding. Address • ________ - _.- __ --•• - __ ----.----.------------- Always at Your Service Bank ----------------------------------------------- MERCHANDISE Address __ --------------.-------------------------- •• DISTRIBUTORS Name of reference for identification ----------------~- -- The World's Largest Problem Today Is Distribution-Getting .Goods From Where They Are To Wlzere They Ought To Be--System! Exhibit "B"

~MAIL BACK IN ENCLOSED ENVELOPE~ Complaint 38F. T. C.

[Exhibit C] Phone ConnectionMAURICE KRESSIN UNITED DELIVERY SYSTEM General Mgr. EXECUTIVE OFFICES 639 NEW YORK AVENUE, N. W. MERCHANDISE W ASHJNGTON, D. C. Distribution Department Unclaimed Package Division Specialties in Package File No. -------------- Deliveries Name ---------------------------------------------- Contracts made for Address ----· ---------------- ------~- -------------- __ the distribution of all kinde of Can you inform us as to the present address or whereadvertising matter, trade papers, abouts of-------------------------------------------publications, and general merchandise who formerly lived at--------------------------------by uniformed force.

* * We have a package addressed to the above party and we STORAGE AND understand that there has been some change in their address. SHIPPING We are desirous of making proper delivery and would appreciate your kindness in advising us of their present loca- * * tion.

We are enclosing a self addressed and stamped envelope Merchandise and and we would appreciate any information you can give us advertising matter regarding this party's present address or place of employreceived in carload ment so we can make prompt delivery of this package. or Ieee than carload' 1 Thanking you for an early reply, we are Iota stored, broken up and delivered Very truly yours, or reshipped by UNITED DELIVERY SYSTEM. parcel·poet, freight or express.

Pool car distributing Name of party--------------------------------------and forwarding.

Present address _____ ---------- _-------------------- -· Always at Your City _____________________ --- _________________ -.- __ Service.

Present employment ----------------------------· ----- MERCHANDISE DISTRIBUTORS Remarks-----·------------------------------------·· The World's Largest Problem Today Is Distribution-Getting Goods From Where They Are ' To Where Tiley Ought To Be-System! Exhibit "C"

Gf> MAIL BACK IN ENCLOSED ENVELOPE ~ UNITED DELIVERY SYSTEM ET AL. 415 409 Findings said cards and forms refer are those made up by respondents containing the rulers referred to above. The whole scheme is merely an attempt to obtain information by subterfuge, and the information sought was not for the purpose of locating the whereabouts of and identifying the persons concerning whom information was sought as consignees of packages but was sought solely for the purpose of assisting respondents' customers in collecting alleged delinquent accounts.

PAR. 9. The use as hereinabove set forth of the foregoing false and misleading statements and representations has had the tendency and capacity to, arid has, misled and deceived many persons to whom the said cards and forms. were sent into the err.oneous and mistaken belief that said statements and representations were true, and by reason thereof to give information which they would not otherwise supply. . PAR. 10. The aforesaid acts and practices of respondents, as herein alleged, are all to the prejudice and injury of tho public and constitute unfair and deceptive acts and practices within the intent and meaning of the Federal Trade Commission Act.

REPORT, FINDINGS AS TO THE Facts, AND Onder Pursuant to the provisions of the Federal Trade Commission Act, the Federal Trade Commission on November 24, 1942, issued and subsequently served its complaint in this proceeding upon Maurice Kressin, an individual, trading as United Delivery System, and Esther Kressin, an individual, charging them with the usc of unfair and deceptive acts and practices in commerce in violation of the provisions of said act. After the issuance of said complaint and the filing of respondents' answer thereto, testimony and other evidence in support of and in opposition to the allegations of said complaint were introduced before an examiner of the Commission theretofore duly designated by it, and said testimony and other evidence '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, report of the trial examiner and exceptions thereto, briefs in support of and in opposition to the complaint, and.the oral arguments of counsel; and the Commission, having duly considered the matter and ?cing 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 con· elusion drawn therefrom.

FINDING AS TO THE FACTS PARAGRAPH 1. Respondent, lVIaurice Kressin, is an individual, trading as United Delivery System, with his office and principal place of business at 639 New York Avenue, N. W., Washington, D. C. Respondent, Esther Kressin, is the wife of Maurice Kressin and aids, assists, and is active in the conduct of the business carried on by both respondents as a family enterprise under the name "United Delivery System." PAn. 2. Respondents arc now, and for more than three years last past have been, engaged in the sale and distribution of post cards, envelopes, and form letters designed and intended to be used by creditors and collection agencies in obtaining information concerning debtors. Respond· ents cause said post cards, envelopes, and form letters, when sold, to be 416 FEDERAL TRADE COMMISSION DECISIONS ' Findings 38 F. T. C.

transported from their place of business in the District of Columbia to purchasers thereof in various States of the United States, and maintain, and have maintained, a course of trade in said post cards, envelopes, and form letters in commerce between and among various States of the United States and in the District of Columbia.

PAR. 3. In advertising and promoting the sale of their cards, envelopes, and form letters respondents have represented to merchants, collection agencies, and other customers or prospective customers, with reference to "Locating persons commonly called 'skips' and obtaining information as to their employment," in part as follows:

Have you any persons upon your books commonly called "skips"who try to evade payment of honest debts clue your firm, or persons who are deliberately refusing to answer your letters or purposely returning mail to make you believe that they have moved, thus leading you off your track in the collection of accounts? "\Ve can help you locate these persons and their addresses and get you information as to their present employment, and thus make it more convenient for you to obtain judgment against them and issue garnishment proceedings against the employer as to money in their possession belonging to the debtor.

We are in the business of delivering packages and messages in all of the principal cities in the United States, with executive offices in the city of Washington, D. C.

Our plan briefly stated, in obtaining this information is as follows: (a) A letter is sent by you on our letterhead to the party you wish to locate, stating that the United Delivery System has a package for him that we have been unable to deliver on account of a change of address. (b) This letter is mailed out by you in which there is an additional envelope printed with our name and address thereon fo"r their reply. After receiving this letter the party is naturally anxious to know what kind of a package we may have for him, and consequently he fills in the lines printed on the attached letter which shows name, address and present employer, and in the event the party happens to be an employer himself, a bank reference will be requested. The return replies are received at our executive offices and we in turn return them to you for your information, mailing· to the person replying a box of paper cups in order to comply with the Post Office Regulations. . · This system is now being successfully used by the leading credit houses throughout the United States. By using these letters you can accomplish the following:

1. Obtain the correct addresses of persons who have moved and who are trying to evade payment of their debts to you. 2. Obtain the name of their employer whose name you might use to great advantage in either bringing garnishment proceedings against debtor or compelling him to pay his account by threatening to do so. 3. Obtain bank references of employers who are debtors. 4. Locate persons who have purchased goods from you under assumed names.

P ,m. 4. T?e cards sold by respondents are addressed to: UNITED DELIVERY SYSTEM DISTRIBUTION DEPARTMENT 639 NEW YORK AVENUE, N. W.

WASHINGTON, D. C.

UNITED DELIVERY SYSTEM ET AL. ·417 409 Findings and upon the reverse side bear the following: Return this notice promptly UNITED DELIVERY SYSTEM DISTRIBUTION DEPARTMENT UNCLAIMED PACKAGE DIVISION Washington, D. C.

On Hand Dept.

Locating Agent ____ •• ___ • _______ • __ - Package Reference Number Checked by • _ --- _____________ • _ ---- Charges __ - ___ • __________ -------. __ A package bearing your name and address is held at your risk subject to your forwarding directions below.

CONSIGNEE MUST BE IDENTIFIED DELIVER THE ABOVE PACKAGE TO ~aine -----------·--------------------------------------------------------- Address ------------------------------------------------------------------- City _________________________________________ state ------------------------- FOR IDENTIFICATION I REFER YOU TO MY EMPLOYER AND BANK Employer __ • _. ___________ -___________ .---.--.---------------------·_-------- ' Address ------------------------------------------------------------------- Bank·-------------------------------------------~------------------------- All shipments subject to storage chai·gcs ten days after receipt by consignee of this notice.

In the space marked "Package Reference Number" appears a number assigned by respondents to the customer who purchases the particular cards. With this card is furnished an unaddressed envelope bearing respondents' return address and a notation, "POSTMASTER-Important: if this letter can not be delivered to address shown please forward to last address." Respondents' customers address these envelopes to the last-known address of the debtor about whom information is sought, return them in bulk to respondents, who mail them in Washington, D. C. When cards thus sent to debtors and others are returned to respondents with the information desired, the original purchaser is identified by the numbering process above mentioned and respondents thereupon send the cards to such purchaser.

Findings 38 F. T. C.

The form letters sold by respondents for use by their customers in locating debtors, when addressed to other than debtors, read: Unlimited Facilities Courtesy and Efficiency MAURICE KRESSIN UNITED DELIVERY SYSTEM Unclaimed Package General Mgr. EXECUTIVE OFFICES Division 639 NEW YORK AVENUE, N. W.

WASHINGTON, D. C.

MERCHANDISE Distribution Department File No.---------- Specialties in Package Deliveries Name ---------------------------------------------- Contracts made for Address ____________________________________________ _ the distribution of all kinds of advertising matter, Can you inform us as to the present address or whereabouts trade papers, publications, and of ·---------- 7 -------------------------------------general merchandise by uniformed force. who formerly lived at--------------------------------- * * STORAGE AND We have a package addressed to the above party and we SHIPPING understand that there has been some change in their address. We are desirous of making proper delivery and would ap- * * preciate your kindness in advising us of their present location.

Merchandise and We are enclosing a self addressed and stamped envelope and advertising matter we would appreciate any information you can give us regardreceived in carload ing this party's present address or place of employment so or leas than carload we can make prompt delivery of this package. lots stored, broken Thanking you for an early reply, we are up and delivered Very truly yours, or reshipped by UNITED DELIVERY SYSTEM. parcel post, freight or express.

Pool oar distributing and forwarding.

Name of party--------------------------------------- Always at Your Present address -------------------------------------- Service City------------------------------------------------ MERCHANDISE DISTRIBUTORS Present employment -------------------------------- __ Remarks-------------------------------------------- The World's Largest Problem Today Is Distribution-Getting Goods From Where Tiley Are· To Wllere Tiley Ougllt To Be-System! ~ MAIL BACK IN ENCLOSED ENVELOPE~ UNITED DELIVERY SYSTEM ET AL. 419 409 Findings The form letters addressed to debtors 1 are upon a letterhead similar to the above, and read:

Unlimited Facili tie a UNITED DELIVERY SYSTEM Courteoy and Efficiency EXECUTIVE OFFICES 639 NEW YORK A VENUE, N. W.

Distribution Department WASHINGTON, D. C. Phone Connections Specialists in Package Cable Addreea Deliverieo 11 Arra.ngen Consignee ------------·----------------------------- __ Contracts made for the distribution of Street ---------------------------------------------all kinds of advertieing matter, City-------------------------- 7-.State -------------trade papers, publications, and We have a package for you which we would like to complete general merchandise delivery of, but due to some change in address we will apby uniformed force. preciate it if you will send us your present and correct address in order to make immediate and proper delivery. * * We are inclosing herewith a self-addressed and stamped enveloP,e for your reply. We would appreciate it if you fill in STORAGE AND the following and return at your earliest convenience. · SHIPPING Very truly yours, • • UNITED DELIVERY SYSTEM . For the purpose of complete identification all of the data Merchandise and below is required. advertising matter received in carload or leas than carload lots eoored, broken Name· ------------ ________ ------------------------ __ up and delivered or reahipped by Address ------------------------------------------- __ parcel post, freight or express. Former Address ---------·--------------------------- __ Pool car diatributing and forwarding. Name of present employer ---------------------------- Address ------------------------------------------- __ Always at Your Service Bank ----------------------------------------------- MERCHANDISE Address ------------------------------------------- •• DISTRIBUTORS Name of reference for identification -------------------- The World's Largest Problem Today Is Distribution-Getting Goods Frotn Where They Are To Where ThfY Ought To Be-System/ tar MAIL BACK IN ENCLOSED ENVELOPE~ 1 Error in inadvertently UBing word "creditors" instead of "dcbtora" WRB corrected by nunc pro tunc order of the Commission dated May 31, 1944.

Order 38 F. T. C.

With these letters is furnished an addressed en..:elope directed to United Delivery System, Distribution Department, at respondents' Washington address, and also an unaddr'essed envelope, similar to that furnished to purchasers of cards, for use in mailing the letter and reply envelope. When addressed by the purchasers thereof, they are returned to respondents, who mail them in Washington, D. C., receive the replies, and send such replies to the original purchaser of the form letter: When a card or letter containing the information requested for the use of their customers is returned to respondents by the person about whom the information is desired, they mail to him a few paper cups or a six-inch ruler made of cardboard, or some similar article of trivial value. These articles are furnished by respondents and sent out by them "in order to comply with the Post Office Regulations." In some instances replies have been received to as high as 90 percent of the inquiries sent out, but the average returns approximate 30 percent of the inquiries. Respondent Maurice Kressin testified that in some instances in the past, prior to mailing such inquiries, the packages containing the small articles of merchandise mentioned were addressed to persons to whom inquiries were sent, but this is not currently being done and was never the general practice. It is customary to make up and address these packages after a reply is received. Respondents in fact are not seeking to make ddivery of merchandise to the debtors of their customers but only to request information for the use of their customers. Respondent Maurice Kressin also testified that the business of United Delivery System had two phases: one devoted to the delivery of merchandise and advertising matter; and the other devoted to the sale and handling of cards and form letters used in locating and securing information concerning delinquent debtors. PAR. 5. Through the use of the name "United Delivery System" in the manner above set forth, respondents falsely represent to the debtors and others from whom information concerning debtors is sought that the information is desired for use in connection with the movement and transportation of goods and the delivery thereof to the proper consignees, and the name as thus used is merely a disguise to conceal from such addressees the true nature of respondents' business. The use of said name and the false representations made to debtors and to others from whom information is sought concerning debtors, as aforesaid, have the capacity and tendency to mislead and deceive the persons addressed and cause them to furnish respondents with information which would not be furnished if the true purpose of respondents' inquiry were known. Through the use of the cards, form letters, and envelopes heretofore described respondents place in· the hands of others means of making the aforesaid false representations.· CONCLUSION The acts and practices of respondents as herein found are all to the prejudice and injury of the public and constitute unfair and deceptive acts and practices within the intent and meaning of the Federal Trade Commission Act.

ORDER TO CEASE AND DESIST · This proceeding having been heard by the Federal Trade Commission upon the complaint of the Commission, the answer of respondents, testimony and other evidence in support of and in opposition to the allegations UNITED DELIVERY SYSTEM ET AL. 421 409 Order of said complaint, report of the trial examiner and exceptions thereto, briefs filed herein, and the oral arguments of counsel; and the Commission having made its findings as to the facts and its conclusion that said respondents have violated the provisions of the Federal Trade Commission Act.

It is ordered, That respondent, Maurice Kressin, an individual, trading as United Delivery System or under any other name, and respondent, Esther Kressin, an individual, jointly or severally, their representatives, agents, and employees, directly or through any corporate or other device,· in connection with the offering for sale, sale, and distribution in commerce, as "commerce" is defined in the Federal Trade Commission Act, of cards, form letters, envelopes, or any other printed or written material for use in obtaining information concerning debtors or alleged debtors, do forthwith cease and desist from:

1. Representing, or placing in the hands of others means of representing, directly or by implication, that persons concerning whom information is sought arc the consignees of merchandise or other property being held for delivery to them. :

2. Using the name "United Delivery System," or any other name which imports or implies the shipment, transportation, or distribution of merchandise, to designate, describe, or refer to respondents' business insofar as said business is concerned with obtaining information to be used in the collection of debts.

3. Using, or placing in the hands of others for use, cards, form letters, envelopes, or other printed or written material by means of which respondents' business of obtaining information for the purpose of facilitating the collection of debts is represented as a business of some other nature or char~cter. .

It is further ordered, That respondents shall, within 60 days after the 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. · 422, FEDERAL TRADE COMMISSION DECISIONS Syllabus 38F. T. C.