Conair Corporation

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IN THE MATTER OF CONAIR CORPORATION CONSENT ORDER, ETC., INREGARD TO ALLEGED VIOLATION OF SECS. 5 AND 12 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3431. Complaint, June 14, 1993--Decision, June 14, 1993 This consent order prohibits, among other things, a Connecticut-based manufacturer of personal health care and consumer electronic products from representing that sound waves emitted by the California Facial Skin Rejuvenating System, or by any substantially similar product that uses sound waves with a frequency of no more than 20 kilohertz, will firm and tone facial muscles or improve the efficacy of a facial skin clarifying toner or scrub. The order requires the respondent to have competent and reliable scientific evidence to support certain future representations it makes regarding sound waves emitted from any product.

Appearances For the Commission: Sylvia Kundig and Jeffrey Klurfeld. For the respondent: Andrew Krulwich, Wiley, Rein & Fielding, Washington, D.C.

COMPLAINT The Federal Trade Commission, having reason to believe that Conair Corporation ("respondent"), a corporation, has violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges:

PARAGRAPH 1. Conair Corporation is a Delaware corporation, with its principal office or place of business at 1 Cummings Point Road, Stamford, Connecticut.

PAR. 2. Respondent is a manufacturer of personal health care products and consumer electronic and kitchen appliances. It has CONAIR CORPORATION 415 414 Complaint advertised, labelled, offered for sale, sold, and distributed the California5 1 3 1 2 2 862 665 118 35 96.573082 Facial5 1 3 1 2 3 997 665 87 35 96.596581 Skins 1 3 1 2 4 1099 665 263 45 96.682564 Rejuvenating5 1 3 1 2 5 1378 665 161 45 96.408394 System ("the System"). PAR. 3. The acts and practices of respondent alleged in this complaint have been in or affecting commerce, as commerce is defined in Section 4 of the Federal Trade Commission Act. PAR. 4. The System consists of a hand-held, sound wave device, a clarifying toner, an exfoliating scrub, and a moisture lotion. The individual uses the sound wave device to apply the clarifying toner and the exfoliating scrub. The System also includes instructions for facial exercises to be performed with the sound wave device. .

PAR. 5. As advertised, the sound wave device referenced in paragraph four is a “device” within the meaning of Sections 12 and 15 of the Federal Trade Commission Act. As advertised, the clarifying toner, the exfoliating scrub, and the moisture lotion are cosmetics within the meaning of Sections 12 and 15 of the Federal Trade Commission Act.

PAR. 6. Respondent has disseminated or has caused to be disseminated advertisements for the System including, but not necessarily limited to, a telephone promotion, a transcription of which is attached hereto as Exhibit A, a magazine advertisement which is attached hereto as Exhibit B, and a program-length television commercial, excerpts of which are attached hereto as Exhibit C. The advertisements contain the following statements: A. Surfaces 1 4 1 1 3 906 2056 166 31 96.578575 treatments5 1 4 1 1 4 1085 2057 69 38 96.437141 only5 1 4 1 1 5 1168 2062 47 33 96.978691 gets 1 4 1 1 6 1228 2056 115 30 96.760010 surfaces 1 4 1 1 7 1354 2057 113 29 96.509659 results.5 1 4 1 1 8 1492 2057 73 35 95.547852 [Thes 1 4 1 1 9 1578 2056 128 38 96.529655 System]5 1 4 1 1 10 1722 2055 23 30 96.994049 is5 1 4 1 1 11 1759 2055 142 38 96.402397 designed5 1 4 1 1 12 1912 2060 31 24 97.005371 to4 1 4 1 2 0 623 2103 1320 40 -1 5 1 4 1 2 1 623 2107 83 30 96.951492 works 1 4 1 2 2 719 2116 39 20 96.842194 on5 1 4 1 2 3 772 2106 57 30 96.602730 ands 1 4 1 2 4 841 2106 125 30 96.496552 beneath5 1 4 1 2 5 980 2106 48 29 97.006058 thes 1 4 1 2 6 1042 2106 116 29 96.854553 surfaces 1 4 1 2 7 1171 2105 36 29 96.865112 of5 1 4 1 2 8 1216 2106 49 28 96.865112 thes 1 4 1 2 9 1278 2105 75 34 96.843445 skin,5 1 4 1 2 10 1367 2110 30 24 96.699997 to5 1 4 1 2 11 1409 2105 69 38 96.415688 helps 1 4 1 2 12 1492 2105 148 29 96.644218 stimulates 1 4 1 2 13 1654 2104 65 30 96.730804 skins 1 4 1 2 14 1733 2104 138 33 96.234520 renewal,5 1 4 1 2 15 1885 2103 58 30 96.684898 anda 1 4 1 3 0 624 2151 1317 40 -1 5 1 4 1 3 1 624 2155 136 29 96.508698 maintains 1 4 1 3 2 772 2154 111 30 96.833580 muscles 1 4 1 3 3 894 2160 75 23 92.224106 tone.5 1 4 1 3 4 984 2178 25 5 88.289871 ...5 1 4 1 3 5 1022 2154 85 29 96.890846 More5 1 4 1 3 6 1120 2154 193 37 96.885773 importantly,5 1 4 1 3 7 1326 2154 93 28 96.929062 sounds 1 4 1 3 8 1431 2162 98 20 92.410690 waves5 1 4 1 3 9 1551 2153 68 38 92.410690 helps 1 4 1 3 10 1630 2152 67 30 96.296234 firms 1 4 1 3 11 1708 2152 58 29 96.296234 ands 1 4 1 3 12 1777 2157 67 24 96.349709 tones 1 4 1 3 13 1855 2151 86 30 96.306717 facial4 1 4 1 4 0 624 2201 849 38 -1 5 1 4 1 4 1 624 2203 128 29 96.734344 muscles5 1 4 1 4 2 765 2203 60 29 96.591141 that5 1 4 1 4 3 837 2202 75 29 96.600082 have5 1 4 1 4 4 926 2202 57 29 96.600082 lost5 1 4 1 4 5 995 2202 75 29 96.976089 theirs 1 4 1 4 6 1081 2202 172 37 88.021713 elasticity. (Exhibit A).

B. Best5 1 4 2 1 3 869 2250 36 29 96.366196 of5 1 4 2 1 4 919 2250 48 34 96.468803 all,5 1 4 2 1 5 988 2250 59 35 96.066895 [thes 1 4 2 1 6 1065 2250 131 37 96.472740 System]5 1 4 2 1 7 1216 2249 83 30 96.972008 firms5 1 4 2 1 8 1318 2249 175 38 96.308914 underlying5 1 4 2 1 9 1511 2249 88 29 96.819145 facial5 1 4 2 1 10 1618 2249 131 29 96.765419 muscles5 1 4 2 1 11 1767 2248 46 30 96.737778 for5 1 4 2 1 12 1829 2253 114 33 97.000229 greater4 1 4 2 2 0 622 2298 390 39 -1 5 1 4 2 2 1 622 2299 171 38 84.412529 elasticity. (Exhibit B).

C. [I]ntrasound5 1 4 3 1 3 982 2355 99 20 96.618729 waves5 1 4 3 1 4 1092 2352 145 31 96.181000 penetrates 1 4 3 1 5 1248 2351 29 24 96.837784 to5 1 4 3 1 6 1287 2346 68 37 96.837784 helps 1 4 3 1 7 1366 2351 67 24 96.076889 tones 1 4 3 1 8 1444 2346 57 28 96.076889 ands 1 4 3 1 9 1511 2346 68 28 96.663696 firms 1 4 3 1 10 1589 2354 49 29 96.253822 my5 1 4 3 1 11 1650 2345 90 29 92.803780 face. (Exhibit C). D. [thes 1 4 4 1 3 859 2394 95 30 96.644547 sounds 1 4 4 1 4 969 2403 85 21 96.069977 waves 1 4 4 1 5 1069 2394 118 35 96.646072 device]5 1 4 4 1 6 1205 2394 84 37 96.646072 helps5 1 4 4 1 7 1305 2394 49 29 96.877762 thes 1 4 4 1 8 1369 2394 130 29 96.659081 muscles5 1 4 4 1 9 1514 2394 60 28 96.874954 that5 1 4 4 1 10 1589 2402 59 29 96.876984 you5 1 4 4 1 11 1665 2402 48 20 97.013611 ares 1 4 4 1 12 1729 2392 166 38 96.508408 exercising5 1 4 4 1 13 1911 2389 30 33 96.710556 to4 1 4 4 2 0 623 2442 717 34 -1 5 1 4 4 2 1 623 2443 122 29 96.086029 achieves 1 4 4 2 2 758 2443 47 29 96.707329 thes 1 4 4 2 3 819 2443 164 29 96.105713 maximum5 1 4 4 2 4 995 2443 138 28 63.473858 benefit. (Exhibit C).

PAR. 7. Through the use of the statements contained in the advertisements referred to in paragraph six, including but not Complaint 116 F.T.C.

necessarily limited to the attached Exhibits A, B, and C, respondent has represented, directly or by implication, that the sound waves emitted by the sound wave device will firm and tone the user's facial muscles.

PAR. 8. In truth and in fact, the sound waves emitted by the sound wave device will not firm and tone the user's facial muscles. Therefore, the representation set forth in paragraph seven was, and is, false and misleading.

PAR. 9. Through the use of the statements contained in the advertisements referred to in paragraph six, including but not necessarily limited to the advertisements attached as Exhibits A, B and C, respondent has represented, directly or by implication, that at the time it made the representation set forth in paragraph seven, respondent possessed and relied upon a reasonable basis that substantiated the representation.

PAR. 10. In truth and in fact, at the time respondent made the representation set forth in paragraph seven, respondent did not possess and rely upon a reasonable basis that substantiated the representation. Therefore, the representations set forth in paragraph nine was, and is, false and misleading.

PAR. 11. The advertisements attached hereto as Exhibits A and B contain the following statements:

A. In5 1 4 1 1 3 789 1947 140 34 95.761833 addition,5 1 4 1 1 4 946 1946 57 29 96.773636 this5 1 4 1 1 5 1019 1944 111 39 96.746452 unique5 1 4 1 1 6 1146 1944 149 29 96.736969 skin-cares 1 4 1 1 7 1310 1947 112 33 96.651039 systems 1 4 1 1 8 1438 1949 103 21 96.992432 comes5 1 4 1 1 9 1557 1939 70 30 96.848114 with5 1 4 1 1 10 1643 1939 81 29 93.256966 three5 1 4 1 1 11 1740 1936 159 37 93.134567 sonically-4 1 4 1 2 0 582 1983 1320 45 -1 5 1 4 1 2 1 582 1998 144 30 96.666290 activated5 1 4 1 2 2 738 1997 107 29 96.914955 lotions5 1 4 1 2 3 857 2001 30 24 96.945961 to5 1 4 1 2 4 898 1994 150 33 96.944267 exfoliate,5 1 4 1 2 5 1062 1998 77 28 94.204330 tone,5 1 4 1 2 6 1153 1992 56 29 94.204330 ands 1 4 1 2 7 1222 1990 150 30 96.095520 minimizes 1 4 1 2 8 1385 1990 48 29 96.095520 thes 1 4 1 2 9 1446 1996 179 31 96.949013 appearances 1 4 1 2 10 1638 1986 35 30 96.983116 of5 1 4 1 2 11 1682 1986 61 29 96.544006 fines 1 4 1 2 12 1757 1985 84 32 96.607269 lines,5 1 4 1 2 13 1855 1983 47 31 96.875214 fora 1 4 1 3 0 583 2037 885 46 -1 5 1 4 1 3 1 583 2056 16 20 91.017578 a5 1 4 1 3 2 611 2046 121 33 91.017578 radiant,5 1 4 1 3 3 745 2042 271 41 93.070999 younger-looking5 1 4 1 3 4 1030 2039 218 39 88.086227 complexion. (Exhibit A).

B. Sonically-activated5 1 4 2 1 3 1067 2088 109 31 96.989021 lotions5 1 4 2 1 4 1190 2088 64 29 96.351021 also5 1 4 2 1 5 1269 2087 68 37 96.351021 helps 1 4 2 1 6 1351 2084 165 31 96.899414 California5 1 4 2 1 7 1529 2082 98 31 96.909355 Facial5 1 4 2 1 8 1642 2082 83 30 96.871849 works 1 4 2 1 9 1740 2082 35 28 96.949074 its5 1 4 2 1 10 1790 2080 111 38 92.816048 magic-4 1 4 2 2 0 583 2129 1318 50 -1 5 1 4 2 2 1 583 2142 160 37 96.946671 cleansing,5 1 4 2 2 2 756 2139 172 38 96.833977 exfoliating5 1 4 2 2 3 940 2139 58 29 96.919144 ands 1 4 2 2 4 1010 2136 186 39 96.585526 minimizing5 1 4 2 2 5 1208 2136 48 29 96.384209 thes 1 4 2 2 6 1268 2142 180 31 96.384209 appearances 1 4 2 2 7 1462 2133 35 30 96.978989 of5 1 4 2 2 8 1506 2133 62 29 95.516647 fines 1 4 2 2 9 1581 2131 101 30 85.449059 lines. (Exhibit B).

PAR. 12. Through the use of the statements contained in the advertisements referred to in paragraph eleven, including but not necessarily limited to the advertisements attached as Exhibits A and B, respondent has represented, directly or by implication, that the sound waves emitted by the sound wave device improve the efficacy of the lotions.

CONAIR CORPORATION 417 414 Complaint PAR. 13. In truth and in fact, the sound waves emitted by the sound wave device will not improve the efficacy of the lotions. Therefore, the representation set forth in paragraph twelve was, and is, false and misleading.

PAR. 14. Through the use of the statements contained in the advertisements referred to in paragraph eleven, including but not necessarily limited to the advertisements attached as Exhibits A and B, respondent has represented, directly or by implication, that at the time the respondent made the representation set forth in paragraph twelve, it possessed and relied on a reasonable basis that substantiated the representation.

PAR. 15. In truth and in fact, at the time the respondent made the representation set forth in paragraph twelve, respondent did not possess and rely on a reasonable basis that substantiated the representation. Therefore, the representation set forth in paragraph fourteen was, and is, false and misleading. PAR. 16. The acts or practices of respondent, as alleged in this complaint constitute unfair or deceptive acts or practices and the making of false advertisements in or affecting commerce in violation of Sections 5(a) and 12 of the Federal Trade Commission Act. EXHIBITA Welcome to the world of California Facial. The only sound wave skin rejuvenating system. Surface treatments only get surface results. California Facial is designed to work on and beneath the surface of the skin, to help stimulate skin renewal, and maintain muscle tone. California Facial uses sound wave vibrations to help improve blood flow, brining a rich, nutritive oxygen supply to skin and muscle cells. More importantly, sound waves help firm and tone facial muscles that have lost their elasticity. In addition, this unique skin care system comes with three sonic activated lotions to exfoliate, tone and minimize the appearance of fine lines, for a radiant, younger-looking complexion. California’s Facial brings out what’s hidden deep in your face, the potential to look your youthful best. To hear a location near you, press |. To speak to a representative, press 2. To end this call, press 3. ("3" pressed).

California Facial is available at the following local stores: K-Mart, Wal Mart, Target, JC Penny, Sears, Price Club, and Costco. Thank you for calling! Complaint 116 F.T.C.

EXHIBIT B The Secret ”

of Youthful Skin 1S Hidden Deep in Your Face f Now there's a skin care system that penetrates 2 : H deeply, & gr where even advanced It's the Californua Fact nating System.

By using sound waves that work layers below the | surface of your skin, Calfoni Pacial simulztes sion renewal and brings 3 rich source of oxygen to plump up musdes and skin Best of all, is firms undstying fecal muscles for greater otasticiry Sonically-activated lotions also help California Facial work its magic—ceansing exfoliating and mrumizing the appearance of fine kines.

So before you buy another ‘miracle’ skin cream, hidden deep @ your face. Your youth.

ICONS"? CALIFORNIA FACIAL’ 7 Sou AVE Skin Rejuvenating System Ad Code WMD ‘ CONAIR CORPORATION 419 414 , Complaint EXHIBIT C Excerpts from the program-length commercial “Conair Presents: Innovations in Health and Beauty.”

[SUBSCRIPT] 1-800-527-5800 UNIDENTIFIED WOMAN: I'm 30-something! I used to spend a fortune and tons of time on professional facials to look younger, until I found California Facial. Love it! Feels more effective. The intra sound waves penetrate to help tone and firm my face. My skin looks younger. Imagine what a lifetime of facials would cost! [SUBSCRIPT] INTRASOUND WAVES NARRATOR: California Facial from Conair, the at-home professional facial. UNIDENTIFIED WOMAN: And he thinks I’m 20-something! NARRATOR: To order, call now. Your California Facial includes the sound emitter, two attachments, three special lotions, instruction book and application pad, equal to $1,000 in salon facials, an incredible value for only $49.95 plus shipping and handling. Order today and receive our free video on how to give yourself a California Facial. For fastest delivery, call now, or send check or money order to the address shown. Your California Facial comes with a 30-day money back guarantee.

PRINTED: 49.95 plus $9.95 S&H Add applicable sales tax (No CODs) 1-800-527-5800 Or send Check or Money Order to:

California Facial PO Box 10472 Waterbury, CT 06725-0472 30 day money back guarantee MARIO GONZALEZ, Director of Marketing, Conair: Yes. The tone and firmness of your face not only depends on the skin, but also on the underlying facial structure, the muscles.

COLLEEN GALIGHER, Host: Right, right.

Complaint 116 F.T.C.

GONZALEZ: Those muscles need to be kept in shape. They need to be worked out. California Facial provides a series of very simple and easy exercises highlighted in this booklet that are done in conjunction with the unit and this attachment.

In doing the exercises, you simply place the unit GALIGHER: [unintelligible] GONZALEZ: - - in place -- yes, you leave it in place, uh, and it helps the muscles that you are exercising to achieve the maximum benefit. GALIGHER: Through the intrasound waves, is that what happens? GONZALEZ: That is correct. Yes. So there you have it. California Facial is really very simple to use, it is a common sense system, and it is the combination of the sound waves, the creams and the exercises that make it so unique. CONAIR CORPORATION 42] 414 Decision and Order DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondent named in the caption hereof, and the respondent having been furnished thereafter with a copy of a draft of complaint which the San Francisco Regional office proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondent with violation of the Federal Trade Commission Act; and The respondent, its attorney, and counsel for the Commission having thereafter executed-an agreement containing a consent order, an admission by the respondent of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondent that the law has been violated as alleged in such complaint, and waivers and other provisions aa required by the Commission's Rules; and The Commission having thereafter considered the matter and having determined that it had reason to believe that the respondent has violated the said Act, and that complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of sixty (60) days, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby makes the following jurisdictional findings and enters the following order:

1. Respondent Conair Corporation is a Delaware corporation. Its principal office or place of business is at 1 Cummings Point Road, Stamford, Connecticut.

2. The acts and practices of respondent alleged in this complaint have been in or affecting commerce, as commerce is defined in the Federal Trade Commission Act.

3. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is in the public interest.

Decision and Order 116 F.T.C.

ORDER It is ordered, That respondent Conair Corporation, its successors and assigns, and its officers, representatives, agents, and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the manufacturing, labelling, advertising, promotion, offering for sale, sale, or distribution of Thea 1 4 1 6 0 589 1101 1318 50 -1 5 1 4 1 6 1 589 1101 199 35 96.557602 California5 1 4 1 6 2 804 1101 118 36 96.746521 Facial5 1 4 1 6 3 942 1102 87 35 96.762466 Skins 1 4 1 6 4 1048 1103 262 46 96.693130 Rejuvenating5 1 4 1 6 5 1330 1104 161 45 96.582176 System or any substantially similar product, in or affecting commerce, as commerce is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication that: (1) sound waves can or will firm or tone an individual's facial muscles, and (2) sound Waves will improve the efficacy of a facial skin clarifying toner or exfoliating scrub. For purposes of this order, “substantially similar product" shall mean any skin care product, or combination of products that includes a skin care product, that use sound waves emitting a frequency of no more than 20 (twenty) kilohertz.

I].

It is further ordered, That respondent Conair Corporation, its successors and assigns, and its officers, representatives, agents, and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the manufacturing, labelling, advertising, promotion, offering for sale, sale, or distribution of any product or combination of products that use sound waves, including but not limited to intrasound or ultrasound, in or affecting commerce, as commerce is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication that sound waves can or will firm or tone an individual's muscles, unless at the time of making the representation, respondent possesses and relies upon competent and reliable scientific evidence that substantiates the CONAIR CORPORATION 423 414 Decision and Order representation. For purposes of this order, competent5 1 3 1 1 8 1684 610 68 34 95.703537 ands 1 3 1 1 9 1777 610 146 34 96.358307 reliable4 1 3 1 2 0 607 663 1317 49 -1 5 1 3 1 2 1 607 663 175 36 96.493431 scientific5 1 3 1 2 2 796 664 189 37 90.915100 evidence shall mean tests, analyses, research, studies, or other evidence, conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the relevant profession to yield accurate and reliable results. Hil.

It is further ordered, That respondent Conair Corporation, its successors and assigns, and its officers, representatives, agents, and . employees, directly or through any corporation, subsidiary, division, or other device, in connection with the manufacturing, labelling, advertising, promotion, offering for sale, sale, or distribution of any product or combination of products that use sound waves, including but not limited to intrasound or ultrasound, in or affecting commerce, as commerce is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication that sound waves can or will improve the efficacy of a topically applied product, unless at the time of making the representation, respondent possesses and relies upon competent and reliable scientific evidence that substantiates the representation. For purposes of this order, competent5 1 5 1 14 9 1842 1830 68 34 96.970543 anda 1 5 1 15 0 592 1883 1318 48 -1 5 1 5 1 15 1 592 1883 148 35 96.157112 reliable5 1 5 1 15 2 762 1884 176 35 96.777664 scientific5 1 5 1 15 3 961 1884 193 36 92.169075 evidence shall mean tests, analyses, research, studies, or other evidence, conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the relevant profession to yield accurate and reliable results.

IV.

It is further ordered, That the provisions of this order shall not apply to the printing on approximately 40,000 tubes of Deep4 1 7 1 3 0 588 2465 1317 48 -1 5 1 7 1 3 1 588 2465 223 45 96.297714 Penetrating5 1 7 1 3 2 830 2466 104 44 97.001785 Body5 1 7 1 3 3 954 2466 149 35 93.129608 Creme and 40,000 tubes of Muscles 1 7 1 3 9 1729 2468 176 45 96.710182 Soothing4 1 7 1 4 0 587 2522 1317 49 -1 5 1 7 1 4 1 587 2522 121 35 86.286407 Gelle which were manufactured prior to July 1, 1992, and shipped by respondent to distributors or retailers prior to January 10, 1993. Decision and Order 116 F.T.C, V.

It is further ordered, That for five (5) years after the last date of dissemination of any representation covered by this order, respondent, or its successors and assigns, shall maintain and upon request make available to the Federal Trade Commission for inspection and copying:

A. All materials that were relied upon in disseminating such representation; and B. All tests, reports, studies, surveys, demonstrations or other evidence in its possession or control that contradict, qualify, or call into question such representation, or the basis relied upon for such representation, including complaints from consumers. VI.

It is further ordered, That the respondent shall, for ten (10) years from the date of entry of this order, distribute a copy of this order to each current and future officer, employee, agent, and/or representative engaged in the preparation or placement of advertising or other promotional materials covered by this order and shall obtain from each such person a signed and dated statement acknowledging receipt of the order.

VIl.

It is further ordered, That respondent shall notify the Commission, at least thirty (30) days prior to the proposed change, of any proposed change in the respondent such as dissolution, assignment, or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries, or any other change in the corporation that may affect compliance obligations arising out of the order.

CONAIR CORPORATION 425 414 Decision and Order Vill.

It is further ordered, That respondent shall within sixty (60) days after the date of service of this order upon it and at such other times as the Commission may require, file with the Commission a report, in writing, setting forth in detail the manner and form in which it has complied with this order.

Complaint 6 E.T.C.