1554 Corporation

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

Complaint 123 F.T.C.

IN THE MATTER OF

1554 CORPORATION, ET AL.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT

Docket C-3733. Complaint, April 14, 1997--Decision, April 14, 1997

This consent order prohibits, among other things, the California company, doing business as The Mellinger Company, and its president from making any unsubstantiated success, profitability, performance, benefits, efficacy or success rate claims with regard to a business opportunity product or service. The consent order also prohibits the respondents from using testimonials or endorsements that make deceptive or unsubstantiated representations.

Appearances

For the Commission: Justin Dingfelder, Lemuel Dowdy and Jonathan Cowen.

For the respondents: Shirley Johnson, Washington, D.C.

COMPLAINT

The Federal Trade Commission, having reason to believe that 1554 Corporation, a corporation, and Brainerd L. Mellinger, III, individually as an officer of 1554 Corporation ("respondents"), have 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. Respondent 1554 Corporation is a California corporation, with its office and principal place of business located at 6100 Variel Ave., Woodland Hills, CA. Respondent 1554 Corporation has traded and done business as The Mellinger Company.

Respondent Brainerd L. Mellinger, III, is president of the corporate respondent. Individually, or in concert with others, he formulates, directs and controls the acts and practices of the corporate respondent, including the acts and practices alleged in this complaint. His principal office or place of business is the same as that of the corporate respondent.

PAR. 2. Respondents have, individually or in concert with others, created and disseminated advertisements for the Mellinger World Trade Mail Order Plan ("Mellinger Plan"), and have offered for sale

1554 CORPORATION, ET AL. 1109

1108 Complaint

and sold the Mellinger Plan to consumers who respond to their advertisements.

PAR. 3. The acts and practices of respondents 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. Respondents' advertisements for the Mellinger World Trade Mail Order Plan include, but are not necessarily limited to, the attached Exhibits A-D. These advertisements contain the following statements:

A. A program-length television advertisement for the Mellinger Plan, identified as "Mellinger's Secret Treasures" (Exhibit A):

(1) Announcer: "How would you like to earn substantial income right from the comfort of your own home? . . . Living a luxurious lifestyle with long-term security for you and your family." (P. A1)

(2) Endorser: "Doesn't matter what age, what your background is, what your education is. The sooner you get started, the sooner you start making money." (P. A2)

(3) Host: "His name is Brainerd Mellinger III, and he makes it easier than ever for people to make riches they've only dreamed of." (P. A3)

(4) Endorser: "On my first customer my first day with the World Traders I made twelve thousand dollar profit." (P. A4)

(5) Host: "Brainerd, these folks are making a lot of money, and enjoying every minute of it." (P. A13)

(6) Brainerd Mellinger, III: "If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now." (P. A17)

(7) Endorser: "You will be successful. It's been proven time and time again." (P. A17)

(8) Endorser: "I started off with $250 that my husband gave me, and last year I earned over $35,000, and I did it all with the help of the Mellinger Company." (P. A21)

(9) Endorser: "Get involved with Mellinger, and if you stick with them they have the support team there for you, they can make something like this possible for you." (P. A23)

(10) Endorser: "Anybody today that really wants to work, and has the initiative to get out and try something new, this plan definitely makes it about as easy as pie." (P. A25)

(11) Announcer: "Kirk may not be a rocket scientist, but with the help of the Mellinger World Trade Plan he has launched a company with sky-rocketing profits. Today is a typical business day, and Kirk is shipping out more than 400 hats. The profits are all his." (P. A36)

(12) Endorser: "[A]nyone that gets involved with this is gonna really find [it] exciting, interesting, and create an income for themselves. It's fantastic." (P. A38)

(13) Host: "The Mellinger Plan makes it so easy to achieve financial independence. Why isn't everyone doing it?" (P. A42) Brainerd Mellinger, III: "Good question. Well -- it's just that they don't know about the Mellinger Plan yet. They aren't aware that this fabulous opportunity for success

Complaint 123 F.T.C.

and riches is waiting for them. And that's why I'm here today. I want to tell everyone that they can make money, like some of the folks you've seen on our show. The Mellinger company shows you how, step by step. And we make it simple and fun . . . ." (P. A43) B. A magazine advertisement for the Mellinger Plan (Exhibit B): 2 valuable New Reports Can Make You Rich! I'll send both to you FREE! You've seen me on T.V.! Now I'm ready to help you get a fast start! Discover How to Be Independent -- Be Your Own Boss -- Make Big Money in your own IMPORT/EXPORT MAIL ORDER BUSINESS! . . . Enjoy earnings probably far greater than you ever dreamed any job could pay. * * * Join these successful Men and Women! . . . "Mellinger has the answers! I'm looking at $25,000. year's income -- just 2 hours a day part-time." [endorser] "Just one world trade transaction paid me $5,000 profit! Yes...follow the Mellinger Plan!" [endorser] C. Mellinger Internet site (http://www.tradezone.com) (Exhibit C): SUCCESSFUL INTERNATIONAL TRADERS MEMBERS[.] HOW PLAN BROUGHT SUCCESS TO THEM! . . . Having trouble sleeping one night, [endorser] turned on his TV and became enthralled by a Mellinger infomercial. A phone call brought him full details about the Mellinger Plan. "I was so impressed with what I saw, I immediately began following the Mellinger Plan and became a Member of International Traders. I began putting the Plan into practice and started showing Import products. In less than two months, I had generated well over $2,000 in business." . . . The Mellinger Plan provided exactly what [endorser] needed. . . . "I would tell you this works for you. It's very good for beginners like myself." She reported sales of $1200. right away and with her early momentum she says she is looking now at earnings of $6000. a month! D. A pamphlet mailed to consumers who request information about the Mellinger Plan (Exhibit D): START AT HOME...make money your very first day! * * * MEN & WOMEN--Welcome to your exciting, high-income, full-or part-time future in Import/Export/Mail Order. Follow the Mellinger Plan as it guides your every step. Nothing has been left to chance. Each easily followed step is based 100% upon many years of successful business experience! * * * SUCCESS STORIES in World Trade! Read these ACTUAL REPORTS of MONEY-MAKING . . . . Concentrating on imported sports equipment, [endorser] took in $35,000.00 the first year, devoting only a few hours a day.

PAR. 5. Through the use of the statements contained in the advertisements and promotional materials referred to in paragraph four, including but not limited to the advertisements attached as Exhibits A-D, respondents have represented, directly or by implication, that:

1554 CORPORATION, ET AL. 1111

1108 Complaint

A. Consumers who use the Mellinger Plan typically succeed in readily starting and operating profitable businesses; B. Consumers who use the Mellinger Plan typically earn substantial income; and C. Endorsements appearing in Exhibits A-D reflect the typical or ordinary experience of members of the public who have used the Mellinger Plan.

PAR. 6. Through the use of the statements contained in the advertisements referred to in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A-D, respondents have represented, directly or by implication, that at the time they made the representations set forth in paragraph five, respondents possessed and relied upon a reasonable basis that substantiated such representations.

PAR. 7. In truth and in fact, at the time they made the representations set forth in paragraph five, respondents did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, the representation set forth in paragraph six was, and is, false and misleading.

PAR. 8. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A1 Final On Air Script

DISCLAIMER GRAPHIC Narrator:

FONT: TESTIMONIALS The following program is a paid USED IN THIS PROGRAM REPRESENT BEST CASE advertisement for the Mellinger World RESULTS. RESULTS WILL VARY DEPENDING ON Trade Mail Order Plan, by The Mellinger INDIVIDUAL EFFORTS AND PRODUCT SELECTION. Company.

TEASE:

Narrator:

COVER:

CU WOMAN COUNTING MONEY How would you like to earn substantial income right from the comfort of your COUPLE, WORKING AT TABLE IN THEIR KITCHEN own home? Working the hours you want--part time or full time. Enjoying YACHT the freedom of not having to answer to a boss.

DREAM SHOTS: Living a luxurious lifestyle with MAN TAKING GOLF SWING long-term security for you and your FAMILY & DOG IN POOL family. ZOOM OUT FROM CU: Well, you don't have to discover a SHOT OF TREASURE CHEST OVERFLOWING WITH secret treasure to make your dreams JEWELS, PEARLS AND GOLD. come true. Stay tuned because DISS. TO SHOT OF we're going to reveal a modern day TREASURE CHEST OVERFLOWING WITH treasure...that can put you on the road MELLINGER IMPORTS.

ZOOM IN TO CU. to success and happiness. It's a CU PAN ACROSS CHEST OF time-tested formula that's been used by IMPORTS.

hundreds of thousands of people all over the world.

GRAPHIC We'll also tell you how you can receive FONT: GET A FREE an exciting personal import absolutely [illegible] free just for watching [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Final On Air Script p. A2

Flash FREE TESTIMONIAL FONT:

CAROLYN KAPLAN INTERNATIONAL TRADER

Carolyn Kaplan:

Doesn't matter what age, what your background is, what your education is. The sooner you get started, the sooner you start making money.

TESTIMONIAL FONT:

ROY HANSON INTERNATIONAL TRADER

Roy Hanson:

The Mellinger Company has a plan set up. Step one, two, three, four, it's, it's so simple.

SHOW TITLE SEQUENCE:

CU TREASURE CHEST OF IMPORTS

Narrator:

It's all next on "Mellinger's Secret Treasures."

INTRO

PAN ACROSS EURASIA MAP

Richard V/O:

700 years ago, a brave young merchant, named Marco Polo

SUPERIMPOSE VARIOUS PICTURES OF MARCO POLO OVER MAP

traveled 15,000 miles to discover the riches of the Orient.

PICTURE OF MARCO RETURNED HOME W.

TREASURE

He came home with exotic treasures and opened up trade routes that helped merchants build untold fortunes.

RICHARD ANDERSON ON KOWLOON LOCATION FONT:

RICHARD ANDERSON FILM AND TELEVISION STAR

Richard:

Hello I'm Richard Anderson, here in the fabled city of Hong Kong to introduce to you a modern day Marco Polo

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A3 Final On Air Script

PAN ACROSS HONG KONG SKYLINE

BRAINERD WALKS DOWN A LANE OF STANLEY MARKET

Richard V.O.:

His name is Brainerd Mellinger the III,

and he

COVER OF BRAINERD IN STANLEY MARKET STORE, LOOKING AT CLOTHES HANGERS

makes it easier than ever for people to make riches they've only dreamed of.

BRAINERD W/ FAN

He goes on global product tours

FONT:

HONG KONG STANLEY MARKET

searching the world over for sources of exciting, low priced imports.

FONT:

ALL PRICES QUOTED ARE BASED ON QUANTITY FROM AN OVERSEAS SUPPLIER AND ARE SUBJECT TO CHANGE AND AVAILABILITY.

Then shows you how to market them from your home, at selling prices up to 13 times their cost and more!

BRAINERD AT STANLEY MARKET FINDING MAGIC RAZOR.

Richard V/O:

Look at what Brainerd's already found!

CU ON MAGIC RAZOR

First - a really handy item: The Magic

FONT:

BUY FOR....... $1 SELL FOR...... $13 GROSS PROFIT $12

Razor. It's great for travel or at home and sells in leading catalogs for as much as thirteen dollars, but you

FONT: PROFIT MAY VARY DUE TO OPERATING COSTS.

pay only a dollar. That's a 13-1 markup.

BRAINERD IN STANLEY MARKET W POTPOURRI SACHETS

Richard V/O:

Then look at these lovely potpourri

CU ON POTPOURRI SACHETS

sachets. International Traders members

CU FROM DIFFERENT ANGLE

buy these scented closet hangers for

FONT:

BUY FOR [illegible] RETAIL FOR [illegible]

only sixty-five cents per set of six and sell them for $10 a set

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger & Secret Treasures" NEXT-1 P A4 Final On Air Script

GROSS PROFIT $135 That's an 18 to 1 markup?

FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

TESTIMONIAL Prince Ogunbawo:

FONT: On my first customer my first day with PRINCE ADEMOLA OGUNBAWO the World Traders I made twelve INTERNATIONAL TRADER thousand dollar profit.

BRAINERD W/ SAMURAI Richard V/O: SWORDS And finally these detailed replicas of FONT:

BUY FOR...... $40 SELL ancient Samurai swords. Intriguing FOR.... $175 GROSS PROFIT $135 conversation pieces that people will

FONT: PROFIT MAY VARY gladly pay $175 for. But Mr. DUE TO OPERATING COSTS. Mellinger's International Traders

members buy these for only $40. That's a $135 gross profit on each set!

END OF OPENING

MELLINGER SIX - SEGMENT ONE

RICHARD IN CHAIRMAN'S Richard: SUITE, GRAND HYATT HONG HONG. You know, we all dream of being

wealthy, and I'm here today with Brainerd Mellinger the third, to show you just how to make that dream come true in your own import export mail order business.

FULL CUT TO TWO SHOT Richard to Brainerd: FONT:

Page 1

Complaint 123 F.T.C.

EXHIBIT A

'Mellinger & Secret Treasures' MST-1 Final On Air Script P A5

HONG KONG Well Brainerd, everyone assumes that starting a business is a big risk. What's different about the Mellinger World Trade Mail Order Plan? And why do so many people do so well? Brainerd:

BRAINERD FONT:

BRAINERD L. MELLINGER III, PRESIDENT/C.E.O.

THE MELLINGER COMPANY SHOTS OF 4 GENERATIONS OF MELLINGERS FONT: THE MELLINGERS The main thing is that my family's company has developed and perfected this formula over four generations. And we show you how to start with very little, just like my grandfather did, and make money right from the start. So there's virtually no down side.

BRAINERD & RICHARD You don't need any special business experience or education. We make it simple and fun.

RICHARD Richard:

Okay. So, let's get started. What's the first secret of your Business Success Formula? BRAINERD Brainerd:

FONT: MELLINGER BUSINESS SUCCESS SECRET #1:

SELL PRODUCTS AT HIGH MARKUPS, YOU KEEP ALL THE PROFITS Well, number one is finding really hot products you can mark up for profits You know markup is the key. RICHARD AND BRAINERD IN STANLEY MARKET

1554 CORPORATION, ET AL.

Complaint EXHIBIT A 'Mellinger's Secret Treasures' MST-1 p A6 Final On Air Script Richard:

Which is why we're made in Hong Kong right.

Brainerd:

Exactly.

ARIEL OF HONG KONG Hong Kong is just one of the many IMPORTS ON TABLE international markets where my global product scouts find fascinating, low cost products.

CU ON PUPPY Brainerd:

Like this lifelike, plush puppy. Puppy Barks Richard:

It barks when you pet it! RICHARD AND BRAINERD W.

PUPPY Brainerd:

This retails for as much as twenty four FONT:

BUY FOR........$6.50 dollars, and you only pay $6.50 SELL FOR.....$24.00 GROSS PROFIT $17.50 That's an easy $17.50 profit. FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

RICHARD Richard:

That's incredible! BRAINERD Brainerd:

FONT: OVER 14,000 It is incredible! We offer you over QUALITY PRODUCTS 14,000 hand picked, easy-to-sell, CRAWLING COMMANDO quality products to choose from! All CAROUSEL this without having to leave your home AQUA SHOES Full step by step guidance

Complaint 123 F.T.C.

EXHIBIT A

'Mellinger's Secret Treasures' MST-1 [illegible] AT Final On Air Script

RICHARD Richard:

So you can do everything in the comforts of your own home.

RICHARD & BRAINERD Brainerd: Precisely! And many people prefer working from home without any travel. But if you've ever dreamed of world travel, this is a golden opportunity. With your own import/export mail order EXOTIC TRAVEL COVER business you can explore exotic markets SHOTS:

RIVER AT SUNSET around the world. And, in many cases, INTERNATIONAL TRADERS IN STANLEY MARKET your travel is tax deductible as a LOOKING AT SCARVES business expense.

INTERNATIONAL TRADERS IN STANLEY MARKET LOOKING AT BIRD CAGES FONT: CONSULT YOUR ACCOUNTANT FOR ALLOWABLE DEDUCTIONS.

RICHARD Richard:

Brainerd, aren't some Mellinger World Trade members here with us in Hong Kong? IT MEMBERS W SUPPLIERS Brainerd V.O.: & PRODUCTS Yes, and they're learning first hand from my global DIFFERENT SHOT OF IT product scouts how to find the very MEMBERS W SUPPLIERS best deals on beautiful oriental imports

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger & Secret Treasures" MST-1 F A3 Final On Air Script

BRAINERD SHAKING HANDS WITH ALBERT CHAN And meeting with some of our leading Asian suppliers.

RICHARD & BRAINERD Richard:

You know, Brainerd, this is such an exciting, glamorous business. Do you have to invest a lot of money to get started?

BRAINERD Brainerd:

Not at all, Richard.

RICHARD Richard:

How's that possible?

BRAINERD Brainerd:

MELLINGER EMPLOYEE SORTING PRODUCT INTO BOXES Well, it's secret number 2 of the Mellinger Business Success Formula.

FONT:

MELLINGER BUSINESS SUCCESS SECRET #2:

DROP SHIPPING. NO NEED TO STOCK PRODUCTS.

called Drop Shipping.

RICHARD & BRAINERD Richard:

Drop shipping?

Brainerd:

Yes, that's how my father started, in a garage with less than $100 and went on to make millions.

RICHARD Richard:

Well, how does this drop shipping work?

RICHARD & BRAINERD Brainerd:

CU ON CAMERA Well for example take this 35mm Sports Camera from the Orient

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 : A9 Final On Air Script

It automatically takes four quick shots in a row.

Richard:

Boy, this would be great for capturing any action like sports or the kids at play.

BRAINERD Brainerd:

RICHARD & BRAINERD W/ Yes, and it costs only two dollars, but CAMERA you don't pay a cent until after you CU ON CAMERA sell it. You simply run an ad offering FONT: it for $15. Then when the checks come BUY FOR......$ 2.00 pouring in you put the $13 gross profit SELL FOR......$15.00 right in your pocket--send the orders GROSS PROFIT.$13.00 and the $2 cost per camera to the FONT: supplier. Then the supplier sends the $2 COST DOES NOT cameras directly to your customers for INCLUDE SHIPPING AND you.

DUTY CHARGES.

RICHARD Richard:

That's amazing! So you don't pay for anything until it is sold? BRAINERD Brainerd:

That's right. No inventory to buy, no employees to pay. Before you know it your business is expanding beyond your wildest dreams.

BRAINERD & RICHARD Richard: Like successful International Traders Frances Fred and Jacquis Wang.

1554 CORPORATION, ET AL. 1121

1108 Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A10 Final On Air Script

Brainerd:

Exactly- FEATURE #1: FRED AND JACQUIE WENZ

WIDE SHOT, FRED AND JACQUIE WALKING ON THE BEACH FACING CAMERA.

FONT: MELLINGER SUCCESS PROFILE

Narrator:

For over 30 years, 58 year old Fred Wenz was on the road. His business kept him away from home and his wife Jacquie.

Jacquie Wenz:

Besides the financial rewards that we've gained from the Mellinger Plan, and using it, I have my husband home again.

DISSOLVE TO TWO SHOT OF FRED AND JACQUIE

FONT:

FRED AND JACQUIE WENZ INTERNATIONAL TRADERS

Fred Wenz:

It's really great being at home, but, you know, all the travelling I used to do puts a lot of wear and tear on the body, and now I'm now able to spend more quality time with my wife. Narrator:

From his home in Marshfield, Massachusetts, Fred has taken the Mellinger Plan and has added his own special twist that has been quite successful.

FRED AND JACQUIE WORKING TOGETHER AT DESK

Fred Wenz:

Several years ago when we first started exhibiting at the Mellinger show in Las

FRED CU BY HIMSELF MCU

COVER OF LAS VEGAS TRADE SHOW

[illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P All Final On Air Script

FRED AND JACQUIE DISPLAYING JEWELRY AT TRADE SHOW BOOTH

Vegas, was where we noticed that a lot of customers were asking how they can get started in buying merchandise without capital expenditure of large inventories. We said, lets take the Mellinger Plan and couple it with our Product group.

FRED AND JACQUIE WORKING AT DESK TOGETHER

Narrator:

Well, it worked. In fact, it was so successful that they decided to come up with a sure fire system to ensure success for their distributors.

CU ON PERFECT STARTER KIT, PAN DOWN

Fred Wenz:

We then developed what we call the Perfect Starter Kit, for lack of a better name. The Starter Kit, there are two types. There's one that's got 40 pieces of jewelry. Another one's got 70 pieces of jewelry. And everything in there has been a proven factor that for mail order or distributors, party plans, you name it.

FRED, JACQUIE AND DAUGHTER W/ DISPLAY AT TRADE SHOW BOOTH

CU PAN ACROSS KITS

ECU PAN ACROSS JEWELRY

Narrator:

Fred and Jacquie's success grew to the point where they joined into

FRED AND JACQUIE PACKING PRODUCT

partnership with Henry Palliser. Together they now own an efficient

FRED AND HENRY LOOKING AT MAP ON OFFICE WALL

PAN OVER WORKERS IN PLANT

assembly plant and a successful showroom where they display their

PAN ACROSS SHOWROOM

1554 CORPORATION, ET AL.

Complaint EXHIBIT A 'Mellinger's Secret Treasures' MST-1 p. A12 Final On Air Script CU ON JEWELRY stunning jewelry. What's really convenient, Fred and Jacquie actually FRED AND JACQUIE WORKING TOGETHER AT DESK run the business right out of their home.

Fred Wenz:

FRED AND JACQUIE ON COUCH TOGETHER One of the beauties about running a business out of your home is that you can do what you want, when you want, where you want, and how you want. CU ON CALCULATOR The profit margins are absolutely CU TAKING PRODUCT OUT OF BOX fantastic, especially if you're directly importing. You can expect profits of up to 10:1, which is FRED O/C absolutely phenomenal. One of the best FONT: FRED WENZ INTERNATIONAL TRADER things about the Mellinger World Trade Plan is that you do not have to have any experience whatsoever. There is no formal education required. You can do FRED RECEIVING FAX it in the privacy of your own home, either full time or part time. And FRED O/C then the amazing part is, is that by putting all of this effort in, you can then go to your post office box or mail box, and get all sorts of checks coming in.

Jacquie Wenz:

FRED AND JACQUIE WALKING ON BEACH FRED AND JACQUIE ON COUCH TOGETHER I'm really thrilled at the fact that I have my husband home now and we're FONT: JACQUIE WENZ

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A13 Final On Air Script

INTERNATIONAL TRADER working together at home, and I don't have to wait every night for a telephone call in order to communicate with him. If I have a question or a problem I can now turn to him and just ask it.

RICHARD & BRAINERD Richard: Brainerd, these folks are making a lot of money, and enjoying every minute of it.

BRAINERD Brainerd:

FONT:

BRAINERD L. MELLINGER The Mellinger World Trade Mail Order III, PRESIDENT/C.E.O., THE MELLINGER COMPANY Plan shows you how, every single step of the way.

TESTIMONIAL Carolyn Kaplan:

FONT: CAROLYN KAPLAN This has given me life. It's made me, INTERNATIONAL TRADER happy and I feel good, and I'm making money.

TESTIMONIAL Kathy Land:

FONT: KATHY LAND See my smile? I'm just really excited INTERNATIONAL TRADER about it, cause I know that there's nothing but money ahead.

TEASE:

RICHARD Richard: Stay tuned for Mellinger's

FONT: THIS PROGRAM IS third moneymaking secret and learn how A PAID ADVERTISEMENT FOR THE MELLINGER you can buy fascinating products at COMPANY catch wholesale prices

AERIAL OF HONG KONG SKYLINE

1554 CORPORATION, ET AL.

Complaint EXHIBIT A 'Mellinger's Secret Treasures' MST-1 p. A14 Final On Air Script FONT: STAY TUNED FOR MELLINGER'S 3RD MONEY MAKING SECRET! END OF SEGMENT 1 COMMERCIAL #1 (2:30):

800# DISPLAYED OVER ANIMATED GRAPHIC.

DISSOLVE IN FLASHING FONT:

CALL NOW FOR YOUR FREE INFORMATION! Narrator:

Call this toll free number right now and we'll send you DVE IN DISPLAY SHOT OF MATERIAL FROM MAILING "A"

FONT: CALL FREE everything you need to know about how to get started with the Mellinger World Trade Mail Order Plan.

SHOT OF "IMPORT/EXPORT MAIL ORDER BUSINESS"

BOOKLET Including, absolutely free, this fascinating guide on the import/export mail order business...

SHOT OF "HOW TO START IN MAIL ORDER" BOOKLET"

a special, condensed mini mail order course...

FONT:

CALL NOW FOR YOUR FREE SAMPLE IMPORT! Plus, your exciting free sample import.

DISPLAY SHOT OF MATERIAL FLASHING FONT:

FREE!!! You get all three of these absolutely free, with no obligation, if you call now! TESTIMONIAL DVE BOX WITH GLOBE FONT:

MELLINGER FONT:

1-800-000-0000 Fred Wengi:

To be very honest with you, I swear by the Mellinger Plan, really. It has given us everything that we wanted. PRODUCT SHOT Narrator:

FONT:

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F A15 Final On Air Script

CALL FOR COMPLETE DETAILS ON COST OF THE MELLINGER PLAN

Once you receive the complete Mellinger World Trade Mail Order Plan, you automatically become a member

IT LOGO FLIES IN

of International Traders with immediate access to

CATALOG SHOTS over 24,000 products

FONT:

OVER 24,000 QUALITY PRODUCTS

from around the world.

CUE IN SHOTS OF IMPORTS.

FONTS:

UNIQUE! EXCITING! INCREDIBLE PROFIT MAKERS!

Unique and exciting products that you can market at substantial profits.

WENZ'S WORKING TOGETHER AT DESK

Be your own boss. Working in the comfort of your own home. Making extra

FONT:

BE YOUR OWN BOSS! CAROLYN KAPLAN COUNTING MONEY

income -- spare time or full time.

FONT:

MAKE EXTRA INCOME!

CURRENT FOOTAGE OF MELLINGER BUILDING WITH PEOPLE WAVING.

Mr. Mellinger's talented, dedicated team of experts brings you

FONT:

OVER 45 YEARS OF EXPERIENCE

MELLINGER PEOPLE AT WORK

over 45 years of experience in the import export mail order business.

MELLINGER PEOPLE WORKING WITH IT MEMBERS IN PERSON AND OVER PHONE

They'll give you the personal step by step guidance you need to succeed.

FONT:

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A16 Final On Air Script

HELP YOU EVERY STEP OF THE WAY.

PAN OVER PRODUCT FILLED help you select hot new products that CHEST can generate substantial profits...

FONT: HELP YOU SELECT NEW PRODUCTS

PAN ACROSS ADS IN BOOK show you how to advertise at little or FONT: ADVERTISE AT no cost... LITTLE OR NO COST

ANSON W/ PRODUCT and how to market your products FONT: effectively.

AND MARKET YOUR PRODUCTS EFFECTIVELY

MELLINGER PRINTING They'll even print your business cards PRESS TURNING OUT STATIONARY & BUSINESS and stationary. CARDS. FONT:

PRINT BUSINESS CARDS

BRAINERD MEETING IT And gladly answer any questions you may MEMBER IN OFFICE have, in person or over the phone. IT MEMBER ON PHONE FONT:

ANSWER ANY QUESTIONS YOU HAVE!

SHORT CUTS OF IT People all over the United States and MEMBERS FROM FEATURES Canada have used the plan successfully, FONT: CALL NOW FOR starting with very little, with no YOUR FREE SAMPLE IMPORT FONT: special education or background. 1-800-000-0000

MAN OR WOMAN WALKS TO Get started now, learn how to cut out MAIL BOX, OPENS IT, AND the middleman... THUMBS THROUGH PILE OF ENVELOPES SMILING.

FONT:

CUT OUT THE MIDDLEMAN!

IT'S LOOKING AT CATALOG deal direct with the source...

FONT: DEAL DIRECT WITH THE SOURCE

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F. A17 Final On Air Script

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS ON and make money right from the start... CALCULATOR

FONT: MAKE MONEY RIGHT FROM THE START

IT'S ON COUCH READING part time or full time. BROCHURES

BRAINERD FROM VICTORIA Brainerd: PEAK.

If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE: Narrator:

GET YOUR FREE SAMPLE IMPORT! Call the toll free number on your CALL OR WRITE:

screen now.

Or write to us at: The Mellinger THE MELLINGER CO.

6100 VARIEL AVE. DEPT 3 Company, 6100 Variel Avenue, Woodland WOODLAND HILLS, CA 91367 Hills, California. There's no obligation.

No salesman will call.

Take advantage of this incredible IF PHONE LINES ARE BUSY, KEEP TRYING. opportunity, NOW!

1-800-000-0000 TESTIMONIAL Roy Hansen:

OVE BOX W/ GLOBE You will be successful. It's been FONT:

1-800-000-0000 proven time and time again.

SEGMENT 3:

RICHARD & BRAINERD Richard:

FONT:

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Final On Air Script P A18

HONG KONG Oh, we've learned two secrets of the Mellinger success formula. What's the third?

FONT:

MELLINGER BUSINESS SUCCESS SECRET #3:

CUT OUT MIDDLE MEN.

BUY DIRECTLY FROM SOURCE.

Brainerd:

Well, the third secret--and listen carefully, this is really important-you've got to cut out all the middle men.

FONT: PRICE COMPARISONS ARE BASED ON COMPARABLE QUANTITIES.

Richard:

Middle men.

Brainerd:

They can easily eat up most of your profits. So we show you how to buy directly from the source at below wholesale prices.

RICHARD Richard:

How can you find the source?

RICHARD & BRAINERD Brainerd:

We do it for you by searching the world over for new product ideas. When you receive the Mellinger Plan and join International Traders you immediately have access to over 24,000 exciting products.

Richard:

24,000 products?

BRAINERD Brainerd:

All carefully chosen for their

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p.A19 Final On Air Script

CU WONDER KNIFE quality, FONT: QUALITY

CU TOY JEEP easy salability, FONT: SALABILITY

CU PUPPY mark-up FONT: MARK UP

CU AQUA SHOES and profit.

FONT: PROFIT

BRAINERD And every month you'll receive information on many new product opportunities.

DROP SHIP DIRECTORY Plus, International Traders Members FONT: DIRECTORY OF also receive a confidential directory FOREIGN SUPPLIERS listing hundreds of foreign suppliers.

BRAINERD You easily contact them direct. There FONT: are no middle men. And we collect no BRAINERD L. MELLINGER commission. III, PRESIDENT/C.E.O., THE MELLINGER COMPANY

RICHARD Richard:

FONT: RICHARD Now, wait a minute, the Mellinger ANDERSON, FILM AND Company gets nothing? TELEVISION STAR

BRAINERD Brainerd:

FONT: FURTHER No commission to us. You get the INFORMATION ON THE COST suppliers' below wholesale prices OF THE MELLINGER PLAN Nobody takes a cut. IS AVAILABLE WHEN YOU CALL.

RICHARD & BRAINERD Richard: O.K. So now you have your product. How do you turn this into a quick profit?

FONT: Brainerd:

MELLINGER BUSINESS Well [illegible] SUCCESS SECRET #4:

FREE ADVERTISING

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 9 A20 Final On Air Script

that brings us to Success Secret Number 4. Free advertising.

We show you how to advertise your product at little or no cost.

LISA IN OFFICE Lisa Garcia: FONT: LISA GARCIA For example, one International Trader ADVERTISING MANAGER member received a THE MELLINGER CO.

CU ARTICLE ON FREE free ad worth over $2,000 in a national ADVERTISING magazine.

LISA GARCIA As an International Trader, I may be able to do the same for you. RICHARD & BRAINERD Richard: (to camera) Talking to people who have used the Mellinger Plan has shown me over and over again that dreams do come true, and almost anything is possible. Watch this...

FEATURE #2: CAROLYN KAPLAN CAROLYN WALKING THROUGH Carolyn: GIFT SHOP This is African Gift shops. This is my baby.

CAROLYN WALKING ONTO Narrator: HER BALCONY Not long ago, 40 year old Carolyn FONT: MELLINGER Kaplan of Atlanta Georgia had her SUCCESS PROFILE entire life turned upside down when she was diagnosed with severe recurring migraine headaches and officially rendered disabled

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A21 Final On Air Script

CAROLYN Carolyn:

FONT: CAROLYN KAPLAN I was unemployable with the migraine INTERNATIONAL TRADER headaches because I wasn't dependable. I didn't know when they were going to strike or how long they were going to last, so it put me in a situation where no employer would employ me, and I had to do something.

CU PERFUME BOTTLES IN I started off with $250 that my husband STORE gave me, and last year I earned over CU CHESS SET IN STORE $35,000, and I did it all with the help of the Mellinger Company. I'm real proud of that.

CLIFFORD Clifford:

FONT: CLIFFORD HUGHES Once we found out she had learned about INTERNATIONAL TRADER the Mellinger program, we saw how quickly she, her spirit picked up and CAROLYN WORKING IN how she just became, she had a zest for STORE CLIFFORD life. I think that one of the best programs out today is the Mellinger program through what it has done for her, my aunt, as brought her morale back up.

COVER OF AFRICAN GIFT Narrator: STORE Carolyn started with one gift shop in Atlanta, but her business grew so CAROLYN IN STORE WITH rapidly that she needed to open up CUSTOMER another shop in a different part of town.

1554 CORPORATION, ET AL. 1133

1108 Complaint

EXHIBIT A

"Mellinger's Barter Treasures" MST-1 : A22 Final On Air Script

COVER OF INTERNATIONAL Carolyn: GALLERIES STORE This is my newest shop, International Galleries, which is just recently opened.

CAROLYN It's amazing to me how all this has come together in such a short time. CAROLYN COUNTING MONEY I make money. I sell. No matter what the economy is like, I sell. Narrator:

CU ARTICLES: "US FAMILIES DRIFTING Keeping families together in such APART" "UNEMPLOYMENT ON THE RISE" uncertain times is not an easy task. But Carolyn, with help from the CAROLYN WITH PRODUCT FROM STORE Mellinger company, has been able to do just that by bringing her nephew CLIFFORD WORKING Clifford and her son Patrick into her CLIFFORD AND PATRICK thriving business. Clifford:

CLIFFORD HUGHES I don't think people really understand, actually, how easy the Mellinger Plan has been to learn about basic business functions. Since I started working here I learned, I've been learning a lot about just the import/export business a lot. My aunt showed me the plan and I just have, just really kind of fallen in love with it. It's taught me a lot

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A23 Final On Air Script

CU ON JEWELRY ON DISPLAY, TILT UP TO CAROLYN

Carolyn:

I would advise anyone who's sitting there thinking well, I have a job or you know, I'm disabled or I'm confined to a wheelchair, or whatever reason. I'm a single mother. Listen. Get involved with Mellinger, and if you stick with them they have the support team there for you, they can make something like this possible for you.

FONT: YOUR RESULTS MAY VARY.

RICHARD & BRAINERD

Richard:

Carolyn Kaplan demonstrates just what we're attempting to say today. Brainerd, your company's doing something very special. Allowing people to do things that they've dreamed of doing all their life.

BRAINERD

FONT: BRAINERD L.

MELLINGER III, PRESIDENT/C.E.O., THE MELLINGER COMPANY

Brainerd:

Yes, and it's the wonderful freedom that comes from being your own boss, the master of your own destiny. And we show you exactly how to do it, step by step.

MELLINGER CO. WAVE OUTSIDE HEADQUARTERS

Brainerd (voice over):

With The Mellinger Mail Order Plan you're never alone.

You automatically become a member of International Traders--"

BRAINERD

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A24 Final On Air Script WORLD MAP W TRADE ROUTES IT LOGO our huge world wide organization of importers, exporters, and direct FONT: ORGANIZATION OF IMPORTERS, EXPORTERS AND DIRECT MARKETERS.

marketers.

BRAINERD Once you've joined this exclusive BRAINERD AND STAFF IN OFFICE group, top notch experts help you in every phase of your business. CHRIS HARDENBROCK AND CO-WORKER FONT: WE HELP YOU EVERY STEP OF THE WAY LISA ON PHONE Brainerd:

FONT: WE HELP YOU EVERY STEP OF THE WAY You can call, write, or visit. BRAINERD WITH CLIENT IN OFFICE And we'll give you prompt, personalized assistance.

ANSON IN OFFICE Anson Jackson:

FONT:

ANSON JACKSON WORLD TRADE CONSULTANT THE MELLINGER COMPANY Any member of International Traders can pick up the phone and call me. I'm here to work with them and help them find the big money making products and market them effectively and inexpensively.

RICHARD & BRAINERD Richard:

And how much time and effort does it take to be a success at this? Brainerd:

It's up to you. You can work full time or start off in your spare time. TESTIMONIAL Jim [illegible]:

ONE ON ONE W/ [illegible] The Mellinger Plan has enabled me to

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A29 Final On Air Script

FONT: JIM GEIGLER INTERNATIONAL TRADER

move in a total career change from working for a large corporation to being my own boss.

Mark Miller:

TESTIMONIAL

OVE IN BOX W/ GLOBE FONT: MARK MILLER INTERNATIONAL TRADER

Anybody today that really wants to work, and has the initiative to get out and try something new, this plan definitely makes it about as easy as pie.

FONT: RESULTS VARY DEPENDING ON HOW MUCH TIME INVESTED AND OTHER FACTORS.

TEASE:

RICHARD

Richard:

FONT: THIS PROGRAM IS A PAID ADVERTISEMENT FOR THE MELLINGER COMPANY

Don't go away. When we come back Brainerd will reveal one of the most important moneymaking secrets.

ARIEL SHOT OVER HONG KONG SKYLINE

FONT: STAY TUNED FOR MORE MONEY MAKING SECRETS.

END OF SEGMENT 2

COMMERCIAL TWO

800# DISPLAYED OVER ANIMATED GRAPHIC DISSOLVE IN FLASHING FONT:

CALL NOW FOR YOUR FREE INFORMATION!

Narrator:

Call this toll free number right now and we'll send you

DVE IN DISPLAY SHOT OF MATERIAL FROM MAILING "A"

FONT: CALL FREE

everything you need to know about how to get started with the Mellinger World Trade Mail Order Plan.

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A26 Final On Air Script

SHOT OF "IMPORT/EXPORT MAIL ORDER BUSINESS"

BOOKLET including, absolutely free, this fascinating guide on the import/export mail order business...

SHOT OF "HOW TO START IN MAIL ORDER" BOOKLET"

a special, condensed mini mail order course...

FONT:

CALL NOW FOR YOUR FREE SAMPLE IMPORT! Plus, your exciting free sample import.

DISPLAY SHOT OF MATERIAL FLASHING FONT:

FREE!!! You get all three of these absolutely free, with no obligation, if you call now!

TESTIMONIAL EYE BOX WITH GLOBE FONT:

MELLINGER FONT:

1-800-000-0000 Ron Barki I'm creating my own job security. That's what this is all about. This is a way that you can control your own destiny.

PRODUCT SHOT FONT: CALL FOR COMPLETE DETAILS ON COST OF THE MELLINGER PLAN Narrator:

Once you receive the complete Mellinger World Trade Mail Order Plan, you automatically become a member

IT LOGO FLIES IN.

of International Traders with immediate access to

CATALOG SHOTS FONT: OVER 24,000 QUALITY PRODUCTS over 24,000 products

from around the world.

CUE IN SHOTS OF IMPORTS FONTS:

UNIQUE EXCITING Unique and exciting products that you can market at substantial profits

[illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 = A27 Final On Air Script

INCREDIBLE PROFIT MAKERS!

TESTIMONIAL Toni Mahon:

LIVE BOX W CLOSE I'm having a delightful time. I have FONT: MELLINGER learned, I have learned so much more than I could had I gone to college for 4 years.

WENZ'S WORKING TOGETHER Narrator: AT DESK Be your own boss. Working in the FONT: comfort of your own home. Making extra BE YOUR OWN BOSS! CAROLYN KAPLAN COUNTING income -- spare time or full time. MONEY

FONT:

MAKE EXTRA INCOME!

CURRENT FOOTAGE OF Mr. Mellinger's talented, dedicated MELLINGER BUILDING WITH team of experts brings you PEOPLE WAVING.

FONT:

OVER 45 YEARS OF EXPERIENCE

MELLINGER PEOPLE AT over 45 years of experience in the WORK. import/export mail order business.

MELLINGER PEOPLE They'll give you the personal, step by WORKING WITH IT MEMBERS step guidance you need to succeed... IN PERSON AND OVER PHONE.

FONT:

HELP YOU EVERY STEP OF THE WAY,

PAN OVER PRODUCT FILLED help you select hot new products that CHEST can generate substantial profits...

FONT: HELP YOU SELECT NEW PRODUCTS

PAN ACROSS ADS IN BOOK show you how to advertise at little or FONT: ADVERTISE AT no cost LITTLE OR NO COST

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Final On Air Script P- A29

ANSON W: PRODUCT and how to market your products

FONT:

AND MARKET YOUR PRODUCTS EFFECTIVELY! effectively.

MELLINGER PRINTING PRESS TURNING OUT STATIONARY & BUSINESS CARDS.

They'll even print your business cards and stationary.

FONT:

PRINT BUSINESS CARDS

BRAINERD MEETING IT MEMBER IN OFFICE And gladly answer any questions you may have, in person or over the phone.

IT MEMBER ON PHONE

FONT:

ANSWER ANY QUESTIONS YOU HAVE!

SHORT CUTS OF IT MEMBERS FROM FEATURES People all over the United States and Canada have used the plan successfully,

FONT: CALL NOW FOR YOUR FREE SAMPLE IMPORT starting with very little, with no

FONT:

1-800-000-0000 special education or background.

MAN OR WOMAN WALKS TO MAIL BOX, OPENS IT, AND THUMBS THROUGH PILE OF ENVELOPES SMILING.

Get started now. Learn how to cut out the middleman...

FONT:

CUT OUT THE MIDDLEMAN!

IT'S LOOKING AT CATALOG deal direct with the source...

FONT: DEAL DIRECT WITH THE SOURCE

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS IN CALCULATOR and make money right from the start...

FONT: MAKE MONEY RIGHT FROM THE START

IT'S IN COUCH READING BROCHURES part time or full time

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p A29 Final On Air Script

BRAINERD FROM VICTORIA Brainerd: PEAK: If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE: Narrator:

GET YOUR FREE SAMPLE Call the toll free number on your IMPORT! CALL OR WRITE: screen now.

THE MELLINGER CO. Or write to us at: The Mellinger 6100 VARIEL AVE. DEPT 5 Company, 6100 Variel Avenue, Woodland WOODLAND HILLS, CA 91367 Hills, California.

There's no obligation, No salesman will call.

IF PHONE LINES ARE Take advantage of this incredible BUSY, KEEP TRYING.

1-800-000-0000 opportunity, NOW!

SEGMENT 3

RICHARD AND BRAINERD Richard: Welcome back to Mellinger's Secret Treasures. I'm here in Hong Kong with Brainerd Mellinger the Third, our modern day Marco Polo, on one of his global product tours.

RICHARD & BRAINERD And he's revealing

CU PAN ACROSS DISPLAY his secret formula in the OF PLAN BOOKS import export mail order business.

RICHARD AND BRAINERD Now Brainerd, let's talk about products How do you know what's going to sell and what's not?

[illegible]

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P-A30 Final On Air Script

BRAINERD Brainerd:

FONT:

Well, Richard, that's very important. MELLINGER BUSINESS SUCCESS SECRET #5 The fifth secret of the Mellinger FINDING PRODUCTS THAT SELL EASILY AND Success Formula is finding really hot QUICKLY.

products.

RICHARD & BRAINERD Brainerd V/O:

CU ON HAND AND GOLD We look for quality products that are SNAKE BRACELET unique.

CU CAROLYN HOLDING VASE novel,

CU HANDS HOLDING GOLD and appealing to many people. CLOCK

BRAINERD Brainerd:

CU ON AQUA SHOE Like these aqua shoes. They're one of the hottest new items.

FONT:

Richard:

BUY FOR...... $3 You know, I've seen shoes like these in SELL FOR..... $25 GROSS PROFIT $22 stores and they sell up to $40.

FONT:

Brainerd:

PROFIT MAY VARY DUE TO OPERATING COSTS.

But International Traders can sell them for $25 because they get them for only $3.

RICHARD Richard:

FONT:

Tell me, how do you find products like RICHARD ANDERSON FILM AND TELEVISION that? STAR

BRAINERD Brainerd:

FONT: BRAINERD L.

All you have to do is follow the MELLINGER PRESIDENT, C.E.O.

Mellinger World Trade Mail Order Plan. THE MELLINGER COMPANY FONT:

We give you everything you need to get started fast

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F- A31 Final On Air Script

RESULTS MAY VARY DEPENDING ON TIME INVESTED AND OTHER FACTORS.

CHRIS AT SUPPLIER'S LUNCHEON, HONG KONG

FONT:

CHRIS HARDENBROOK IMPORT MANAGER THE MELLINGER CO.

BRAINERD LOOKING AT JEWELRY IN STANLEY MARKET

BRAINERD LOOKING AT MAGIC RAZOR IN STANLEY MARKET

RICHARD

FONT: LAS VEGAS

ESTABLISHING SHOT DOWN BRIGHT LIGHTS OF VEGAS STREET

WIDE SHOT OF TRADE SHOW

The products, and step by step

guidance.

Chris Hardenbrook:

Hong Kong is just one of the great

international trade centers we travel

to in our search for reputable

suppliers of new moneymaking products. We check it out for you - make sure the

supplier is reliable, has readily

available product, it's of the highest

quality, and is easily sellable.

Richard: (To Camera)

Now, we're going to jump from Hong Kong

to the United States because I want to

show you success in action.

Richard V/O:

At this annual trade show convention,

the Mellinger Company puts the whole

world of exciting products under one

roof.

LAS VEGAS FEATURE: BRAINERD & RICHARD ROAM THE FLOOR LOOKING AT PRODUCTS, SPEAKING TO VENDORS. IT MEMBERS COMMENT ON THEIR SUCCESSES

RICHARD

GRAPHIC OF TURNING GLOBE W OVER'D NAMES OF COUNTRIES FLYING OUT FROM BEHIND IT

Richard V.O.:

International Traders can pick up

exotic new money makers from

Asia Africa Europe Bali, South

America Ireland Egypt

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 Final On Air Script 5 A32 BRAINERD & RICHARD AT LAS VEGAS TRADE SHOW AT EGYPTIAN PAPYRUS DISPLAY Brainerd:

Richard, look at this. Beautiful Egyptian papyrus! CU ON PAPYRUS Richard:

Oh! That's beautiful! That's King Tut and his wife on a hunting party. FONT:

BUY FOR...... $4 SELL FOR......$50 GROSS PROFIT $46 Brainerd:

That's right. You can buy this for three dollars and ninety cents and sell it for as much as fifty dollars. FONT:

PROFIT MAY VARY DUE TO OPERATING COSTS.

Richard:

Well that's a thirteen to one mark-up! BRAINERD AND RICHARD AT TRADE SHOW DISPLAY FOR CALYPSO CUP Richard:

Brainerd, What in the world is this? Brainerd:

Spill Buster.

Richard:

Spill...? Brainerd:

Buster.

Richard:

Buster.

Brainerd:

That's right. It's the best mobile beverage holder on the market. CU SPILLBUSTER Richard:

This is amazing!

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P Final On Air Script A33

Brainerd:

Yeah. It keeps beverages from spilling in mobile homes, BRAINERD AND RICHARD AT cars and boats. TRADE SHOW DISPLAY FOR CALYPSO CUP

Richard:

Is it easy to install? Brainerd:

A child could install it.

FONT: Richard:

BUY FOR......$ 9.00 SELL FOR....$20.00 Cost? GROSS PROFIT.$11.00 FONT: PROFIT MAY VARY Brainerd: DUE TO OPERATING COST. $9.00 Richard:

And, well, what do you sell it for? Brainerd:

$20.00 RICHARD AND BRAINERD Richard: Obviously, the Mellinger Trade Show in Las Vegas was hugely successful and fun. But you don't have to travel beyond your mail box if you don't want to. Isn't that right Brainerd? BRAINERD Brainerd:

FONT: BRAINERD C. Right! You can do absolutely MELLINGER, PRESIDENT, C.E.O. everything in the comfort of your own THE MELLINGER COMPANY home ...

COUPLE ON SOFA W/ PLAN Brainerd V.O.:

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A34 Final On Air Script

CU ON CATALOG - HAND TURNING PAGES

The Mellinger Company puts the treasures of the world right at your finger tips.

FONT: OVER 24,000 QUALITY PRODUCTS

Every member of International Traders has access to over 24,000 profit making products.

PAN UP PAGE OF NEW PRODUCTS

And we continually give you new ones each month.

BRAINERD & RICHARD RICHARD PICKS UP A COPY OF "TRADE OPPORTUNITIES"

MAGAZINE.

Richard:

Plus, International Trader Members also receive "Trade Opportunities Magazine".

FAN SPREAD OF T.O.

MAGAZINES

Brainerd:

That's right Richard. You find out about the hottest new products every

CU PAGE OF T.O.

MAGAZINE

month in our magazine. And you won't find this on any newsstand. It's an

FONT: AN EXCLUSIVE PUBLICATION FOR MEMBERS ONLY

exclusive publication with all kinds of money making information, for members only.

RICHARD

Richard:

So you simply pick a product, run an ad if you choose mail order, and you're on your way.

And anyone can do it?

BRAINERD

Brainerd:

Anyone who is willing to follow our simple step by step plan.

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. A35 Final On Air Script

FONT:

MELLINGER BUSINESS SUCCESS SECRET #6:

LEARN FROM THE EXPERTS.

SAVE TIME AND MONEY.

BRAINERD & RICHARD

FONT:

1-800-000-0000

And that's our 6th secret of the Mellinger Success Formula. Learn from the experts, not from your own mistakes.

Richard:

Well, mistakes can be expensive and time consuming.

Brainerd:

They sure can. And with our plan you don't need to start from scratch. All you have to do is pick up the phone and call us right now.

We'll show you how to make money right from the start.

FEATURE #3: KIRK YAGER

JAG LEAVING DRIVEWAY

FONT: MELLINGER SUCCESS PROFILE

Rodney Benny V/O:

So, Kirk, you started your business at the age of nineteen. Now, let's be honest. Were you some kind of a whiz kid or something in school?

INTERIOR SHOT - KIRK AND RODNEY DRIVING IN JAG

Kirk Yager:

No, not really. I played sports and had a good time, and nothing, just went to school.

Rodney:

Now be honest. How were your grades like? Kirk:

Average. Average grades.

FONT: RODNEY BENNY

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A36 Final On Air Script Rodney:

Amazing. What made you start the business in the first place? Kirk:

Well, I was looking for a good business program, and I ran across the Mellinger program with imported items, and mailed off for it, and was able to get into some real easy businesses with imported items.

Rodney:

Let's talk about the Mellinger Plan itself. So, what was it like? Did you think it was easy, that something just about anybody could follow? Kirk:

Oh, definitely.

You know, I have one year of college and I'm no genius.

JAG TURNING INTO DRIVEWAY Rodney:

No rocket scientist.

Kirk:

No, no rocket scientist.

Narrator:

Kirk may not be a rocket scientist, but with the help of the Mellinger World Trade Plan he has launched a company with sky-rocketing profits. Today is a typical business day, and [illegible]

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 F- AJ7 Final On Air Script

FONT: YOUR RESULTS MAY VARY

RODNEY AND KIRK GOING TO BOXES OF HATS

RODNEY AND KIRK BY BOXES OF PRODUCT

ZOOM INTO CU ON HAT

RODNEY AND KIRK

CU HAT

CU RODNEY

Kirk is shipping out more than 400 hats. The profits are all his.

Rodney:

Well, this must be the product.

Kirk:

Yeah, we have the pitch or the solar fan hat has a solar voltic cell on top.

Rodney:

So this is a solar cell that collects the sun's rays and turns it into electricity?

Kirk:

Yeah, exactly. Or you have a battery backup for shade or night time. Yeah, and what it does is with a moistened sponge here, it works just like an induct cold system on your head. It's fantastic.

Rodney:

Ah ha. It's a great idea.

Kirk:

Oh yeah.

It's one of the best items I've found, I've found, you know, just basically through one of the Mellinger programs.

Rodney:

Really? What was it like when the [illegible]

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 # A38 Final On Air Script

RODNEY AND KIRK BY POOL Kirk:

FONT: THIS PROGRAM IS Oh, it was fantastic. You know, I'm A PAID ADVERTISEMENT able to spend a lot more time with my FOR THE MELLINGER COMPANY family, and go on vacations...

KIRK AND FAMILY and enjoy outings, and dinners, and SWIMMING IN POOL swimming, and boating, you know...

Rodney:

Having a fuller life.

Kirk:

Exactly. Enjoying a lot of, you know,

activities.

CU KIRK Brainerd Mellinger's World Trade

FONT: KIRK YAGER Program has been very beneficial to INTERNATIONAL TRADER myself and my family, and I think that

anyone that gets involved with this is

gonna really find exciting,

interesting, and create an income for

themselves. It's fantastic. So, my

advice would be to give it a try. You

know. That's all I can say is give it a

try.

END OF SEGMENT 3

COMMERCIAL THREE

800# DISPLAYED OVER Narrator: ANIMATED GRAPHIC DISSOLVE IN FLASHING Call this toll free number right now FONT:

CALL NOW FOR YOUR FREE and we'll send you INFORMATION!

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 [illegible] AJ9 [illegible] Final On Air Script [illegible]

DVE IN DISPLAY SHOT OF everything you need to know about how MATERIAL FROM MAILING "A" to get started with the Mellinger World FONT: CALL FREE Trade Mail Order Plan.

SHOT OF "IMPORT/EXPORT Including, absolutely free, this MAIL ORDER BUSINESS"

BOOKLET fascinating guide on the import export

mail order business...

SHOT OF "HOW TO START a special, condensed mini mail order IN MAIL ORDER" BOOKLET" course...

FONT: Plus, your exciting free sample CALL NOW FOR YOUR FREE SAMPLE IMPORT! import.

DISPLAY SHOT OF You get all three of these absolutely MATERIAL FLASHING FONT: free, with no obligation, if you call FREE!!! now!

TESTIMONIAL Bernard Alexander: DVE BOX WITH CLOSE FONT: It's very easy, everything is spelled MELLINGER FONT: 1-800-000-0000 out from A to Z. You just follow the

information and direction they give

you.

PRODUCT SHOT Narrator:

FONT: CALL FOR Once you receive the complete Mellinger COMPLETE DETAILS ON COST OF THE MELLINGER World Trade Mail Order Plan, you PLAN automatically become a member

IT LOGO FLIES IN of International Traders

with immediate access to

CATALOG SHOTS over 24,000 products

FONT:

OVER 24,000 QUALITY PRODUCTS

from around the world

1554 CORPORATION, ET AL.

Complaint EXHIBIT A "Mellinger's Secret Treasures" MST-1 p. A40 Final On Air Script CUE IN SHOTS OF IMPORTS.

FONTS:

UNIQUE! EXCITING! INCREDIBLE PROFIT MAKERS! Unique and exciting products that you can market at substantial profits. TESTIMONIAL CUE BOX W. GLOBE FONT: MELLINGER Nabil Assad:

The Mellinger Program, it changed my life. It made a professional out of me. It taught me one thing, to work smart, don't work hard.

WENZ'S WORKING TOGETHER AT DESK FONT:

BE YOUR OWN BOSS! Narrator:

Be your own boss. Working in the CAROLYN KAPLAN COUNTING MONEY comfort of your own home. Making extra income -- spare time or full time. FONT:

MAKE EXTRA INCOME! CURRENT FOOTAGE OF MELLINGER BUILDING WITH PEOPLE WAVING.

Mr. Mellinger's talented, dedicated team of experts brings you FONT:

OVER 45 YEARS OF EXPERIENCE MELLINGER PEOPLE AT WORK.

over 45 years of experience in the import/export mail order business. MELLINGER PEOPLE WORKING WITH IT MEMBERS IN PERSON AND OVER PHONE.

They'll give you the personal, step by step guidance you need to succeed... FONT:

HELP YOU EVERY STEP OF THE WAY.

PAN OVER PRODUCT FILLED CHEST help you select hot new products that can generate substantial profits... FONT: HELP YOU SELECT NEW PRODUCTS PAN ACROSS ADS IN BOOK show you how to advertise at little or no cost

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 5- A41 Final On Air Script

FONT: ADVERTISE AT LITTLE OR NO COST

ANSON W/ PRODUCT and how to market your products

FONT: effectively.

AND MARKET YOUR PRODUCTS EFFECTIVELY

MELLINGER PRINTING They'll even print your business cards PRESS TURNING OUT STATIONARY & BUSINESS and stationary. CARDS.

FONT:

PRINT BUSINESS CARDS

BRAINERD MEETING IT And gladly answer any questions you may MEMBER IN OFFICE have, in person or over the phone. IT MEMBER ON PHONE

FONT:

ANSWER ANY QUESTIONS YOU HAVE!

SHORT CUTS OF IT People all over the United States and MEMBERS FROM FEATURES Canada have used the plan successfully, FONT: CALL NOW FOR YOUR FREE SAMPLE IMPORT starting with very little, with no FONT:

1-800-000-C000 special education or background.

MAN OR WOMAN WALKS TO Get started now, learn how to cut out MAIL BOX, OPENS IT, AND THUMBS THROUGH PILE OF the middleman... ENVELOPES SMILING.

FONT:

CUT OUT THE MIDDLEMAN!

IT'S LOOKING AT CATALOG deal direct with the source...

FONT: DEAL DIRECT WITH THE SOURCE

CU CATALOG buy below wholesale...

FONT: BUY BELOW WHOLESALE

CU ADDING CHECKS ON and make money right from the start CALCULATOR

FONT:

1554 CORPORATION, ET AL.

Complaint

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 p. 442 Final On Air Script

MAKE MONEY RIGHT FROM THE START

IT'S ON COUCH READING part time or full time. BROCHURES

BRAINERD FROM VICTORIA Brainerd: PEAK If you've ever dreamed of riches and living a luxurious lifestyle, give us a call right now.

TAG PAGE: Narrator:

GET YOUR FREE SAMPLE IMPORT! Call the toll free number on your CALL OR WRITE: screen now.

THE MELLINGER CO. Or write to us at: The Mellinger 6100 VARIEL AVE. DEPT B Company, 6100 Variel Avenue, Woodland WOODLAND HILLS, CA 91367 Hills, California.

There's no obligation, No salesman will call.

IF PHONE LINES ARE BUSY, KEEP TRYING.

1-800-600-3000

CLOSE

RICHARD AND BRAINERD AT Richard: KOWLOON LOCATION You know, this is an exciting opportunity. Now Brainerd, you have told us the six secret treasures of the Mellinger Business Success Formula. I've got just one last question for you. The Mellinger Plan makes it so easy to achieve financial independence.

Complaint 123 F.T.C.

EXHIBIT A

"Mellinger's Secret Treasures" MST-1 Ex A43 Final On Air Script

Why isn't everyone doing it? Brainerd:

Good question.

Well... it's just that they don't know about the Mellinger Plan yet. They aren't aware that this fabulous opportunity for success and riches is waiting for them. And that's why I'm here today.

I want to tell everyone that they can make money, like some of the folks you've seen on our show. The Mellinger Company shows you how, step by step.

And we make it simple and fun, but the first step is up to you.

Pick up the phone and dial the toll free number on your screen now. There's absolutely no obligation. As soon as you call, the Mellinger Company is behind you every step of the way. And we'll get you started on the roads to riches--fast. Our operators are standing by 24 hours a day for your convenience. So call now! Roy Hansen:

If you want medical advice you go to a doctor. If you want legal advice you go to an attorney

BRAINERD

CAROLYN AND CLIFFORD IN STORE

JACQUIE AND FRED ON BEACH

FONT:

1-800-000-0000

TESTIMONIAL

FONT:

1-800-000-0000

1554 CORPORATION, ET AL.

Complaint EXHIBIT A

"Mellinger's Secret Treasures" MST-1 P. A44 Final On Air Script

If you want mail order advice you go to the Mellinger Company.

Carolyn Kaplan:

TESTIMONIAL The Mellinger Company really has opened FONT:

1-800-000-0000 up many new avenues of my life. My family is the world, and it's just great.

Rick Yager:

TESTIMONIAL Anyone that gets involved with this is FONT:

1-800-000-0000 gonna really find it exciting, interesting and create an income for themselves that's fantastic, so, my advice would be to give it a try. Narrator:

DISCLAIMER GRAPHIC The preceding program was a paid advertisement for The Mellinger World Trade Mail Order Plan by The Mellinger Company.

Complaint 123 F.T.C.

EXHIBIT B

2 valuable New Reports Can Make You Rich! I'll send both to you FREE!

HOW TO START in MAIL ORDER

Discover How to Be Independent — Be Your Own Boss — Make Big Money in your own IMPORT/EXPORT MAIL ORDER BUSINESS!..

Deal Direct with leading suppliers and keep ALL profits!

Buy Below Wholesale Rock-bottom prices pay fantastic markups!

BRAINERD L. MELLINGER III President/CEO, The Mellinger Co. Fourth generation of internationally respected World Trade/Mail Order family. The Mellinger Co. started by our founder in a rented garage with barely $100. Our 45 years of successful World Trade/Mail Order experience is your time-proven guide to profits. Follow Mellinger methods, global contacts, and profit secrets to a prosperous business of your own. Mail coupon for all facts...discover how to start quickly, surely!

Profit big with exciting import products! MEN-WOMEN...you'll never get rich working for somebody else! Your answer is being your own boss in your own business! World Trade/Mail Order is the one business you can still "start on shoestring"! Enjoy earnings probably far greater than you ever dreamed any job could pay. The Mellinger World Trade/Mail Order home business plan guides you step by step. Plan based and backed by four generations of Mellinger family global success! We travel the world, discovering dazzling new import product and handicraft values you'll turn into quick, steady profits. Start with choice of 24,221 of today's hottest import moneymakers. Always deal direct—no middlemen—keep all profits!

Join these successful - Men and Women! "My biggest day's sales has been $1,535.50 and the largest single sale was $1,122." This Plan has made a change in my life."

Ana M. Morecky "Mellinger has the answer! I'm looking at $23,000 year's income —just 2 hours a day part-time!" Alan Passmore "Just one world trade transaction paid me $3,000 profit! Yes...follow the Mellinger Plan!"

Glen Campbell "Following the Mellinger Plan I opened my own gift shop. Plus, made $12,000 Mail Order profit!" Mattie Gibson [illegible]

START WITH CHOICE OF 24,221 HIGH PROFIT IMPORTS!

START FAST FROM HOME...Full-Time or Part-Time! No employees! No rent! Almost no overhead! Actually make first import transaction 10 minutes after Plan arrives. Can operate without product investment. Plan reveals exactly how to sell by Mail Order or many other high profit ways. Receive free membership in International Traders organization...immediately puts you in direct contact with suppliers overseas. Age, past experience not important. Ideal for husband and wife team or retirement!

FIND OUT! I'll send 2 reports, Free Sample Import and Condensed Mail Order Course—all free! Discover how to turn imports we find into really big money. Read my 2 complete reports. Marvel at free sample import I'll send! No obligation. No salesman will call. Mail certificate today!

Personal Guidance You're never alone! Mellinger Personal Consultants help at every step. Be invited to regional Mellinger Seminars for extra [illegible]

ADDED EARNINGS Now make even more money with Mellinger Plan. Deal direct in U.S. made products at lowest rock-bottom prices...keep all profits! No "buying fees"!

This Certificate Good for ONE SAMPLE IMPORT—FREE B. L. MELLINGER III, THE MELLINGER CO. 6100 VARIEL AVE., Dept. Q2089 WOODLAND HILLS, CA 91367-3779 Send FREE Sample Import, FREE Report and FREE Condensed Mail Order Course. Show me how I can start a profitable home-based business. No obligation.

Name [illegible] Address [illegible]

E MELLINGER CO Dept. Q2089 6100 Variel Ave., Woodland Hills, CA 91367-3779

1554 CORPORATION, ET AL. 1157

1108 Complaint

EXHIBIT C

Mellinger Company http://www.noboss.com/mellingr.html

PRIME-CATEGORY: Consumer Services CATEGORY: Import/Export

SOURCE: The Mellinger Company OFFER: become a member of International Traders, gain introduction and access to hundreds of carefully screened foreign suppliers carrying over 20,000 imports plus gain information regarding profit potential as export agent for domestic manufacturers. COST: $198 or payments of $15 to start. $18.90 for 12 months. THE PACKAGE: Receive 20 Section Mellinger World Trade/Mail Order Plan, Supplement and 11-piece Visualizer Kit. When paid in full, receive 3 Year International Traders Membership, Free sample Imports, Trade Agreements, Drop Ship Directory, Trade Opportunities Magazine for 3 years (published bimonthly) and sample portfolio of business forms. Free personal telephone consultation available to members. Visa/Mastercard payment accepted. In addition, the Platinum Profession Training includes round-trip air fare transportation and hotel accommodations at a 4-star hotel while attending 3 days of factory training and Master Certificate as a Professional Glass Repair Technician. Bonus Book "How To Run Mail Order Advertising" for orders within 14 days of receipt of information. MARKETING TECHNIQUE: sell imports by mail. Members-only Drop-Ship Plan enables you to start without product investment. MISCELLANEOUS: Mellinger family active in world trade and mail order for over 90 years. You deal directly with overseas suppliers, cut out middlemen and keep all profits. International Traders Trade Show Convention in Las Vegas held annually for International Traders members. TYPICAL EARNINGS: Examples of earnings of individual members (1) borrowed $500 to start, made $45,000 after 6 months, (2) first year brought $30,000: recently had sales of $41,920 in a single day, (3) first year sales of $55,000; now serve 250 customers are 'trying for a million'. GEOGRAPHIC AVAILABILITY: USA ADDITIONAL INFORMATION: For full details on this Business Opportunity simply.

REQUEST TO BE SENT DETAILED INFORMATION

or you can write :

The Mellinger Company 6100 Variel Avenue, Dept NOBOSS Woodland Hills, CA 91367 6100 Variel Avenue, Dept NOBOSS Woodland Hills, CA 91367

NOTE: this "Listing" has NOT been reviewed-for-accuracy by the Source

TO TOP

Complaint 123 F.T.C.

EXHIBIT D

THE MELLINGER WORLD TRADE/ MAIL ORDER BUSINESS PLAN

START AT HOME...

[illegible]

International Traders

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

Start fast in your own profitable HOME IMPORT/EXPORT MAIL ORDER BUSINESS

MEN & WOMEN—Welcome to your exciting, high-income, full or part time future in Import/Export/Mail Order! Follow the Mellinger Plan as it guides you every step. Nothing has been left to chance. Each step followed is based upon many years of successful experience, family Import/Export/Mail Order business for [illegible] person, family or retirement operation. [illegible] location [illegible] past Trade/Mail Order business can be started at home in spare time with almost no overhead — and with tiny capital. The Mellinger Plan opens this exceptional opportunity to you... now!

Start with choice of 24,221 fantastic Import bargains!

BUY BELOW WHOLESALE Always deal direct—keep ALL profits!

MELLINGER PRODUCT SCOUTS scour the world, open doors to hundreds of carefully screened foreign suppliers. Members of International Traders (Membership is free to you when you follow the Mellinger Plan) immediately have access to over 20000 of today's most startling import values. The Mellinger Plan guides you in marketing your import selections by Mail Order as well as many other ways for quick, easy profitable Deal in one Import item or many. Even buy one at a time. Always buy below wholesale. Always deal direct, cutting out all middlemen... so you keep all profits!

Start without product investment! The Mellinger family developed and refined a unique, largely risk-free method for use by today's discriminating men and women. Ideal for the international trader with limited capital. The Mellinger Plan shows you exactly how to start without inventory. You receive the Mellinger Plan Money Map, Ship suppliers, and overseas [illegible].

GOLD CHAINS FOR PROFITS

[illegible] DOLLS FROM MANY COUNTRIES

MAXIMUM PROFITS WITH MULTI-PURPOSE RADIO LIGHT

WATCHES— LOW IMPORT PRICES— ALL STYLES

KING TUT PAPYRUS SCROLL "A timeless art treasure of the ancients"

Now you may share personally in this remarkable discovery. An exact replica of the treasured King Tut Golden Mask. This limited edition is hand-painted scroll is a fabulous import to be enjoyed for all time!

4 Generations of Mellinger experience guide you to Success and Fortune!

The Mellinger family has been directly active in World Trade/Mail Order for nearly 90 years! Starting with Great Grandfather Louis Mellinger, our family has directed the flow of millions upon millions of dollars of goods to buyers through the mails. The Mellinger family offers you a key to making World Trade/Mail Order a profitable career for ambitious men and women. You enjoy the full benefit of this vast experience as you follow Mellinger guidance. As you begin following the Mellinger Plan, you become a Member of International Traders... we put you all at once in direct contact with fast-selling suppliers overseas offering you thousands of fast-selling imports below wholesale. We show you how to cut middlemen so you keep all profits. And we guide you step-by-step in marketing your imports for big profits in Mail Order and many other ways. This is the International Traders way to business success!

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

The most respected Mail Order business family in the world leads you to security and independence

B.L. MELLINGER JR.

[illegible] Mellinger Plan. Marketing [illegible] Order. To help you learn fast, [illegible] dollar business. He will profit by [illegible] guidance, established by this World [illegible] Trade/Mail Order pioneer.

B.L. MELLINGER SR.

In the 20s and 30s, Mr. Mellinger built and operated one of America's most prosperous Mail Order/Direct Selling firms. Retiring wealthy at a price-less fund of experience from which newcomers benefit greatly today.

LOUIS G. MELLINGER Early in this century, he foresaw a prosperous future in World Trade/Mail Order. He built a career in this field where he is recognized as one of the globally respected leaders of trade expansion and international business.

B.L. Mellinger III President/CEO, The Mellinger Co. In the pages of this book, I invite you to discover how the Mellinger World Trade/Mail Order Business Plan can help bring you independence, security and prosperity by more money than you [illegible] global Mail Order Organization. [illegible] has made this dream a reality for so many ambitious men and women, of all ages and backgrounds. I look forward to helping you get your fair, profitable start in World Trade/Mail Order!

[illegible]

Complaint 123 F.T.C.

EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

Priceless Mellinger worldwide supplier contacts help you CASH IN FAST!

Men and women enjoying greatest success in World Trade/Mail Order are those offering new products FIRST! A valuable benefit of the Mellinger Plan is free Membership in International Traders. This exclusive worldwide organization immediately puts you in direct touch with leading innovative suppliers abroad ready to do business with you! Mellinger Executives and Scouts travel widely, visiting suppliers, factories and handicraft centers, negotiating best below-wholesale prices! I.T. Members get news of product discoveries directly! You turn over the job of product searching to the experts!

Membership starts you at once with free import samples plus everything needed to turn your samples into profitable orders. Next, you get exclusive Trade Agreements with top overseas suppliers, offering hundreds of fast-moving exports you can deal in right away. You receive Trade Opportunities magazine (published bi-monthly) ... available only to I.T. Members. Each issue reveals brand new products it covers! You contact suppliers directly. Every penny of profits yours to keep! Fantastic bargains to be turned at once into big profits! With the global organization working night and day, International Trade Members have almost unlimited sources of dazzling new imports.

[illegible] this remarkable opportunity [illegible] with the rest of [illegible] business in [illegible] Start Small [illegible] Big in World Trade/Mail Order!

The Woman's Role In World Trade/Mail Order Import/Export offers success and profit to anyone with ambition and ability to make good. Women have a very special "sixth sense" about choosing products to offer by Mail Order and other ways we show you - especially imports needing the "feminine touch." Husband/wife teams have created many highly successful businesses.

Enjoy all the benefits of being your own boss in your own part-time or fulltime home business

START WITH CHOICE OF 24,221 TODAY'S HOTTEST NEW PRODUCTS! Hundreds more discovered every month!

PROFITS... SECURITY... INDEPENDENCE! How often have you talked about getting into your own business? Now think seriously about your opportunity to start ... quickly ... in your own home Import/Export/Mail Order business. No employees to hire or pay. Little or no investment in products. Even keep your present job while operating in spare hours. No store or warehouse to rent. For you handle possible start. The Mellinger Plan reveals how to handle orders without putting up a penny of your own money. Everything you do is based 100% on positive, proved, practical "doing." Our founder authored ambitious, determined to "make it on his own." He drew on experience of his successful forebears ... hard-earned methods are yours to follow in the Mellinger Plan! You can avoid in the garage or in the kitchen table. Your family did start usual newcomer ... costly mistakes thanks to the Mellinger Plan! Remember ... dealing DIRECT means you keep all the profits. More money to save and work with! Carefully screened suppliers in Africa, Italy, Austria, Germany, Latin America, Asia, Australia and many other lands. Prefer to do business with International Traders Members. We find the imports. You pick them. The Mellinger Plan shows how to sell by mail and many other ways. You can't get rich working for someone else. You CAN make it big being your own boss in your own business as so many I.T. Members have proved!

Your bi-monthly Trade Opportunities magazine brings contacts with hundreds of suppliers. Many can be sources for personal use. Save on outlays of watches, cameras, furniture, tools, electronics, etc. Always save the International Traders way! Products like these you buy DIRECT:

COMPUTERS DIAMONDS SECURITY PRODUCTS BEER STEINS AUTO ACCESSORIES DINNERWARE CHRISTMAS GIFTS GERMAN CLOCKS COSMETICS TELESCOPES CUTLERY SETS FISHING RODS ELECTRONIC GAMES SPINNING REELS ATHLETIC GEAR WATCHES CERAMICS RADIOS

Turn Import Values Like These Into Immediate Big Profits!

TRAVEL OPPORTUNITY Go abroad if you like! Travel to product trade fairs on your own. Plan includes complete details. Combine business with pleasure. Ask for Europe, South America, Asia. Membersupplier contacts. I.T. Recognition, ship a warm welcome for The assures a warm welcome. The can be contacted for advice regarding individual cases. IRS [illegible] They provide useful information.

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

Take a tour of the vast International Traders WORLD HEADQUARTERS Your guide: famed motion picture/TV star and I.T. Member Richard Anderson [illegible]

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN You are never alone when you follow the Mellinger Plan [illegible]

LAURA SELBERG [illegible] PITI COLLARS [illegible] ALBERTA KURRAN [illegible] KRISTIN LARSON [illegible] JOHN MORGAN [illegible] JOHN OZBANKO [illegible] HAL TAYLOR [illegible] LISA M. GARCIA [illegible] R. J. MELLINGER III [illegible] CHRIS HARDENBROOK [illegible]

Complaint 123 F.T.C.

EXHIBIT D

SUCCESS STORIES in World Trade! Read these ACTUAL REPORTS of MONEY MAKING... told by Members of INTERNATIONAL TRADERS

WORLD TRADE MAIL ORDER BUSINESS PLAN

[illegible] product or service. There is only one way to judge a product or service — that is to tell the way our customers. These original letters are on file in our offices. They are continuously testimonials. They show the confidence Mellinger World Trade/Mail Order Plan. The same Individual Consultation Service that guided these Members of International Traders is available to you!

International Traders

Bob and Margaret Evans [illegible] recovering from a job related injury, Mr. Evans [illegible] more than a year because he could not stand on a [illegible] leg for more than a few minutes. In the Mellinger [illegible] Plan he found the answer. He devoted his one [illegible] free hour a day to Mellinger and in a single [illegible] year he was able to report a continuing and report- [illegible] ed net sales of $25,000.00 in 100% commissions. [illegible] for student $5,000.00 for a single [illegible] customers that are crying for a million!

Ademola Ogunbanwo Using advice from the Mellinger Plan and expanding his Nigerian Shows, this Nigerian born inventor has turned his hobby of success in the U.S. $30,000 a year brought in a sale and recently had a sale of $41,820.00 in a single day! About International Traders he states, "It is the best organization in the business world."

David Stollenberg After eleven years as an executive for a steamship line, Mr. Stollenberg learned much about World Trade. Using Mellinger advice, one of his first orders was a wholesale $13,000.00 order. In than spending on advertising. His single-day sales have run as high as $32,000.00 and annual sales of more than $450,000.00 in the coming year.

C. Richard Carpenter "Learned more as a Mellinger Sound Trade/Mail Order Seminar than I did at local college! Since the Seminar I have made a point before I make any important decision, to look to the Mellinger Plan."

Brian Winch Mr. Winch and the Mellinger Product Research program to locate a source for the hard to Catch," a cleaning tool used in his business. Using Mellinger techniques taught by "Mellinger," he marketed "LitterCatch"

and International Sales "Cleaning for Cash". The result? $500,000.00 annual sales!

Stewart Heater & Tony Schwartz These two gentlemen received Free Advertising by following Mellinger advice. This publicity brought profit of $12,000 in only 10 days! About the Mellinger Plan, they state "The World Trade/Mail Order Plan has given us a very real sense that dreams can be had as reality. It is the most comprehensive plan of its kind. We are truly grateful for not only the Plan itself, but to the staff at Mellinger also."

Kirk Yager Mr. Yager states, "My business helped me buy my own home when I was just 23. I took in $10,000.00 in one weekend selling toys now available direct from abroad. Thank you Mr. Mellinger for your help and guidance."

Fred Olivo Concentrating on imported sports equipment, Mr. Olivo looks in $25,000.00 the first year, devoting only a few hours a day away from his fulltime men's hair salon. At age 61, Fred Olivo now knows his future is secure and profitable!

Nicole Allen This 26 year old former private secretary knew exactly what she wanted when she contacted The Mellinger Co., "I wanted my own business and I wanted to make money." In two months after starting with a borrowed $500.00, she had paid off her previous bills and made $45,000.00 in sales. She owes it all to the Mellinger World Trade/Mail Order Plan and her Membership in International Traders for great credit for her rapid success. Do it this way, she says, and anything can be done!

Pat Almong Marketing her own creation, the "Wacky Umbrella," Pat reports a single day's sales as high as $1,700.

Estimated earnings in the next 12 months: $250,000.

to $500,000.

MEN—WOMEN Each of these successful I.T. Members started as a World Trade/Mail Order newcomer. The Mellinger Plan changed their lives... bringing success, money, security. We invite you to examine the Mellinger Plan for your full days. Discover what The Plan holds for You!

Why Imports are best for Mail Order!

Imported products bring you two vital requirements for Mail Order success... low cost and distinctive appeal. Many imports come from countries where people work for $4 a day. Costs are low. You make giant profits marking up prices many times. Imports come from countries of different backgrounds and cultures. They offer newness and unique appeal. Their low prices, fresh ideas and top quality are snapped up by Mail Order buyers.

Mail Order is the ideal business to start in spare hours... with only a tiny investment. You can go after orders from anywhere... in hours you choose. Go after orders from coast to coast... which unlike your prospect for profit is just about unlimited. Discover the thrill of opening piles of envelopes containing orders and money!

1554 CORPORATION, ET AL.

Complaint EXHIBIT D

COMPARISON PROVES MELLINGER WORLD TRADE/ MAIL ORDER BUSINESS PLAN Gives you everything you need for quick start to profits.

The Mellinger Plan comes from four highly successful generations of one family... a name instantly associated with World Trade and Mail Order. When you look at the facts... when you ask questions... you discover why so many ambitious men find wealth succeed by following the Mellinger Plan. Compare... then decide. ASK THESE QUESTIONS—INSIST UPON ANSWERS—THEN DECIDE | QUESTIONS | [illegible] | [illegible] | [illegible] | [illegible] | [illegible] | | Can you start with at least 24,000 products? | No | No | No | No | Yes | | Can you choose from 1000's of new products every other month? | No | No | No | No | Yes | | Will you have global contacts (product availability)? | No | No | No | No | Yes | | Will you have full-time consultants to answer your questions? | No | No | No | No | Yes | | Will you be invited to personal World Trade and Mail Order Seminars? | No | No | No | No | Yes | | Will you be invited to an annual Trade Show supported each year (last, partially with air support)? | No | No | No | Yes | Yes | | Will you have to pay a fee for the "privilege" of buying products? | Yes | No | Yes | Yes | No | | Will your name be given to leading overseas suppliers, opening doors to exclusive products you can get selling materials to drink? [illegible] | No | No | [illegible] | [illegible] | Yes | | Will get photos, sales copy [illegible] | No | No | [illegible] | [illegible] | Yes | | Will you get free Membership in International Traders organization? | No | No | No | No | Yes | | Will you get actual sample imports for full test? | No | No | No | No | Yes | | Can you order supplies in special low cost [illegible] interesting, brochures, envelopes, order forms? | No | No | No | Yes | Yes | | Can you get FREE Mail Order ads in national [illegible]? | No | [illegible] | [illegible] | [illegible] | Yes | | Can you get FREE publicity [illegible]? | No | [illegible] | [illegible] | No | Yes | | Will you get a private city directory [illegible] overseas manufacturers and [illegible] products made and [illegible] prices [illegible]? | No | [illegible] | [illegible] | No | Yes | | Will it be easy to lend directly [illegible] [illegible] to buy [illegible]? | No | [illegible] | [illegible] | No | Yes | | Will you be able to buy personal products at special, direct prices? | No | No | No | No | Yes | | Can you start without investment in products? | No | No | No | No | Yes | Dramatic world changes open amazing opportunities for Exporters. From flower seeds to bulldozers... from a few dollars to millions! The Mellinger Plan shows how to handle Exporters and manufacturers of products needed in other countries. We tell you what products are needed... with names... from Exporters... [illegible] ... could be fun... [illegible] EXPORTS BOOMING! Get your [illegible]

Your very first day The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN Start Importing— Start Making Money A Complete Business Plan— How it Works for You...

The day you open the Mellinger World Trade/Mail Order Plan, you can make your first import transaction. Do it within 10 minutes! That's a fact! Instantly, you get the feel of this exciting business. You get everything you need to make money fast, including free Membership in International Traders. At once, you are in direct contact with suppliers all over the world. We show you how to get high-profit orders by mail... from stores and individual, at sweep meets... many ways to make money. THE MELLINGER PLAN is a complete business plan you put to work from the day the mail carrier delivers it! Personal Step-by-Step guidance It's like having experienced friends at your side! If you have a question about suppliers, products, advertising, printing, shipping... anything about your business... just pick up the phone. A skilled counselor is ready to help. Also you will be invited to come to conducted Mellinger Seminars near your home for individual guidance! FREE Specialty Merchandise Catalogs As your business grows, you may want to expand your lines. One way is to profit with products offered by local merchandise jobbers... merchandise catalogs... get sources for direct-mail catalogs... free... You will deal directly with the sources... without paying a fee for the privilege of buying wholesale. Sources for U.S. Manufacturers As a Member of International Traders, you may contact domestic manufacturers of products in which you can deal. Products like cosmetics, vitamins, clothing, tools, auto and garden supplies... take in many millions of dollars annually in Mail Order. Cash in on this bonanza with Mellinger contacts. We show you how to set up shop without paying rent or employees... how you can use the very same Plan that developed Mellinger World Trade/Mail Order business bringing in many millions of dollars!

Complaint 123 F.T.C.

EXHIBIT D

The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN

Everything you need to know to Start Fast for Big Profits —all this is yours the day you join INTERNATIONAL TRADERS

PLUS... all these additional Mellinger aids for a quick, easy start in your business!

How to Start in World Trade [illegible]

Profitable Marketing of Imports [illegible]

* Membership in International Traders * [illegible]

11-Piece World Trade Visualizer Kit [illegible]

* Invitation to Trade Show/Convention * [illegible]

* World Trade Membership Certificate * [illegible]

How to Export for Big Profits [illegible]

* Big Portfolio of Business Forms * [illegible]

Your Personal I.T. Member Subscription to TRADE OPPORTUNITIES Magazine Every other month as an International Traders Member, you receive your own personal copy of your official magazine. Features trade leads for hundreds of newest import products, helpful articles by Mellinger World Trade/Mail Order experts and names and addresses of overseas firms seeking export products. Trade Opportunities magazine is available only to I.T. Members for their exclusive benefit and profit.

Yours FREE as a member of International Traders

Many imports we discover are available to you in small quantities even one at a time. You can try ordering samples of just a few imports. As the money rolls in, you can expand, ordering larger quantities at even lower, direct, below-wholesale prices. Compare your import bargains with department store prices. Think of the giant markup! You can start your small business at home, supplying stores, friends and others seeking exciting new products but don't know where to find them!

6 Valuable Exclusive Trade Agreements You don't have to invest a penny in merchandise

FREE SAMPLE IMPORTS with I.T. Membership. Show and start taking orders the day they arrive! These actual sample imports are Mr. Mellinger Plan PLUS. We send them to you for one important reason — to give you an instant start to profit. Show your samples and take orders right away. Let people see these unusual imports from faraway places. Get their reaction of delight and wonder! With each import comes full supplier-ordering directions which help you introduce other imports in the high-profit lines from which they are selected. These imports give you a quick start in your newly established World Trade/Mail Order business.

Make DROP SHIPMENTS from abroad without investing in stock [illegible]

Personal Consultation and Guidance [illegible]

You are invited TO MR. MELLINGER'S PERSONAL SEMINARS NEAR YOUR HOME [illegible]

1554 CORPORATION, ET AL.

Complaint EXHIBIT D The MELLINGER WORLD TRADE MAIL ORDER BUSINESS PLAN MR. MELLINGER ANSWERS YOUR QUESTIONS These are questions most often asked when I meet with International Traders Members at my Seminars. Perhaps you have questions like these. I believe my answers will help you . . .

Brehard L. Mellinger III President/CEO The Mellinger Co.

Chairman, International Traders Q: You say I can start immediately. How? A: The day you receive the Mellinger Plan, you get exactly, easily followed instructions for making your first import transaction. You could be marking your initial supplier contact within 10 minutes.

Q: How soon can I start making money? A: The minute you become a Member of International Traders. For example, the minute I introduce you to a supplier, you can immediately place your order at a big Distributors' prices. You can prepare on my Drop Ship Plan. You can collect your profit even before paying for products. Q: How do I hear about new products? A: Every other month you receive Trade Drops, unique magazine (exclusively for I.T. Members) revealing trade leads for hundreds of products, plus moneymaking news, ideas and export leads. Q: Do I need previous experience? A: Not at all! The Mellinger Plan is a complete home business plan. It shows you and you have everything you need to plan and operate your business. Successful I.T. Members come from all walks of life . . . all ages . . . all kinds of backgrounds. Your sincere ambition to make money is what's really important. Q: Does Mellinger Import and export? A: Indeed! Our warehouse receives almost daily shipments from abroad, filling orders for decades. Our have depended upon us for an enviable position to inform I.T. Members about what's really going on. Q: Is my I.T. Membership renewable? A: Yes, you can renew Membership. We have many Members with I.T. service records of 25 years or more.

Q: Do I need a lot of capital to start? A: Probably no other business can be started with so little . . . and pay off so big! Following the Mellinger Plan, you actually need no investment in products. Later, as you grow bigger, you can stock your products for quick delivery. Q: Can I start without quitting my job? A: Yes, most newcomers start at home in spare hours. Keep present income while building your World Trade/Mail Order business. Consider going full-time only when you are ready. Q: What if I have questions? A: It's unlikely because The Plan is so up-todate and revised constantly. Still, if a question will come up, the Mellinger Consultation Staff will promptly answer your question by phone or in person.

Q: Do you check suppliers personally? A: Mellinger Executives and Product Scouts visit suppliers and factories in overseas trade centers. We spend large amounts of money doing this. When you see a product offered in Trade Opportunity, you know the supplier has been carefully checked first. Q: Can I deduct foreign travel from my taxes? A: As an active I.T. Member, you are in business. The tax laws permit deduction of businessrelated travel for the purpose of meeting and dealing with overseas suppliers . . . or any expense having to do with your Import/Export business. Remember, the Mellinger Plan does the hard work of product searching for you. Q: What are the opportunities for women? A: Exactly the same as for men! I.T. Membership includes a large proportion of women, and husbands/wives teams earning fine part-time and full-time incomes! Now—let us send you this 5-Volume World Trade/Mail Order Plan Examine the Plan 7 Full Days Before You Decide In these pages, you have read many facts about exciting opportunities for starting your own Import/Export/Mail Order business from home. You have read about ambitious men and women who profited spare-time and full-time following the Mellinger Plan. You learned how we help you get started . . . how we invite you to join International Traders for exclusive direct below wholesale import offers. But we do not ask you to make a decision on this information alone. See The Plan for yourself . . . again discover how complete and easy it is to follow. We invite you to send for the Mellinger World Trade/Mail Order Plan (all 5 volumes) for examining for 7 full days in the quiet of your home. Then, and only then, decide if this is the opportunity for profits, security and personal success you have been looking for. We know from generations of experience we can help you win fortune in your own business. But it is for you who must win. Seeing is believing . . . and understanding! That's why we will send you the Mellinger Plan on a 7-day examination. Examine The Plan . . . find out what it can do for you! Here is just a partial list of subjects and guidance you'll discover in the Mellinger Plan. We invite you to inspect the complete Plan . . . see everything for yourself • WELCOME TO WORLD TRADE/MAIL ORDER • TURNING IMPORTS INTO PROFIT • HOW TO IMPORT BY DEALING DIRECT • STARTING AN IMPORT MAIL ORDER BUSINESS • HOW TO MAKE UP LOW-COST MAIL ORDER ADS • HOW AND WHERE TO RUN MAIL ORDER ADS • HOW TO SELL DIRECT THROUGH DIRECT SALES • SELLING IMPORTS THROUGH MAIL • REPRESENTATIVES • OTHER PROVEN WAYS TO MARKET IMPORTS • HOW TO EXPORT WITHOUT PRODUCT INVESTMENT • EASY TO START AN EXPORT AGENT • WORLD TRADE CORRESPONDENCE • AVOID BUSINESS SECOND KEEPING • HOW TO TRADE BANKING PROCEDURE • HOW TO HANDLE MAIL ORDERS • FREE ADVERTISING IN NATIONAL AD HELP FREE • HOW TO GET PROFESSIONAL TAX FREE • MEETING WITH SUPPLIERS FROM OVERSEAS • HOW TO TRAVEL ABROAD TAX FREE • COMPLETE WORLD TRADE REFERENCE SECTION Mail 7-Day Home Inspection Request . . . Now

Complaint 123 F.T.C.

EXHIBIT D

Follow The Mellinger Plan to World Trade/ Mail Order Profits

We are ready now to help you get your fast start in your own profitable business... THIS IS YOUR DAY OF DECISION

There comes a time when success hinges on a decision... a change in life's direction. Perhaps you are at that turning point now... How often have you heard people say—"IF only I had gone into real estate before prices started shooting up" Or "IF I had only known how well this or that would sell... I could have made a fortune." Usually decisions like that call for risk and big investment that may not turn out at all. I am ready to remove the risk from your decision today. It's like having your cake and eating it, too. Your decision... today... to enter the world of World Trade/Mail Order is ONLY TO LOOK AT THE MELLINGER PLAN. I do not want you to obligate yourself in any way whatsoever. Just look and consider. This could be your opportunity to look back in years to come and

say, "I got my start the right way... struck it rich... not only in money, but in all the good things of life!"

You will be taking your first all-important step by filling out and mailing the enclosed Home Inspection Request. In return, I will send the Mellinger World Trade/Mail Order Business Plan to inspect and discuss for seven full days. We take the risk... you have a whole world of opportunity to gain. All that stands between you and an active role in this great and exciting business... is your decision to look at the Mellinger Plan. Make that decision today. Mail your Home Inspection Request now!

[illegible]

Start small at home... as others did... move ahead when you are ready

MAIL HOME INSPECTION REQUEST NOW ... IMMEDIATE ATTENTION ASSURED Only Mellinger gives you this MONEY-BACK AGREEMENT

It's only fair and right! Purchase of a product or service should come with an agreement to refund your money if you are not satisfied. The Mellinger Co. does this without question... for a very important reason. We want you to be sure you are not only pleased with the Mellinger Plan but that you know you can be a success. Read the Money-Back Guarantee. It is offered for your protection.

THE MELLINGER CO.

6100 Variel Avenue, Woodland Hills, CA 91367-3779 U.S.A.

POSITIVE MONEY-BACK GUARANTEE Order your Mellinger World Trade/Mail Order Plan with the understanding that you can examine it in your home for 7 days after it has been delivered. If, within that time, you decide for some reason —any reason—that you do not wish to keep The Plan, simply mail it back to us by insured parcel post and we will refund your inspection deposit in full.

The Mellinger Co.

1554 CORPORATION, ET AL. 1167

1108 Decision and Order

DECISION AND ORDER

The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents having been furnished thereafter with a copy of a draft complaint that the Bureau of Consumer Protection proposed to present to the Commission for its consideration and that, if issued by the Commission, would charge the respondents with violation of the Federal Trade Commission Act, 15 U.S.C. 45 et seq.; and

The respondents, their attorney, and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondents 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 respondents that the law has been violated as alleged in such complaint, and waivers and other provisions as 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 respondents have violated the said Act, and that a 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 issues its complaint, makes the following jurisdictional findings and enters the following order:

1. Respondent 1554 Corporation is a California corporation, with its office and principal place of business located at 6100 Variel Ave., Woodland Hills, CA. Respondent 1554 Corporation has traded and done business as The Mellinger Company. Respondent Brainerd L. Mellinger, III, is president of the corporate respondent. Individually, or in concert with others, he formulates, directs and controls the acts and practices of the corporate respondent, including the acts and practices alleged in the draft complaint. His principal office or place of business is the same as that of the corporate respondent.

2. The Federal Trade Commission has jurisdiction over the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

Decision and Order 123 F.T.C.

ORDER

DEFINITIONS

For purposes of this order, the following definitions shall apply:

1. "Mellinger Plan" shall mean the Mellinger World Trade Mail Order Plan.

2. "Business opportunity" shall mean an activity engaged in for the purpose of making a profit.

3. "Competent and reliable scientific evidence" shall mean tests, analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.

I.

It is ordered, That respondents 1554 Corporation, a corporation, its successors and assigns, and its officers, and Brainerd L. Mellinger, III, individually and as an officer of said corporation, and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of the Mellinger Plan, or any other product or service concerning business opportunities, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from making any representation, in any manner, directly or by implication:

A. That consumers who use such product or service typically succeed in readily starting and operating profitable businesses;

B. That consumers who use such product or service typically earn substantial income; or

C. Otherwise concerning the performance, benefits, efficacy or success rate of any such product or service,

unless, at the time of making such representation, respondents possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates the representation.

1554 CORPORATION, ET AL. 1169

1108 Decision and Order

II.

It is further ordered, That respondents 1554 Corporation, a corporation, its successors and assigns, and its officers, and Brainerd L. Mellinger, III, individually and as an officer of said corporation, and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of any product or service, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from:

A. Using, publishing, or referring to any endorsement (as "endorsement" is defined in Section 255(b), Part 255, Title 16, Code of Federal Regulations) unless respondents have good reason to believe that at the time of such use, publication, or reference, the endorsement reflects the honest opinions, findings, beliefs, or experience of the endorser and contains no express or implied representations which would be deceptive or unsubstantiated if made directly by the respondents; or

B. Representing, directly or by implication, that any endorsement of the product or service represents the typical or ordinary experience of members of the public who use the product or service unless such representation is true and unless, at the time of making the representation, respondents possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates such representation. Provided, however, respondents may use such endorsements if the statements or depictions that comprise the endorsements are true and accurate, and if respondents disclose clearly, prominently, and in close proximity to the endorsement:

1. What the generally expected performance would be in the depicted circumstances; or 2. The limited applicability of the endorser's experience to what consumers may generally expect to achieve; i.e., that consumers should not expect to experience similar results.

Decision and Order 123 F.T.C.

III.

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

1. All advertisements and promotional materials setting forth any representation covered by this order; 2. All materials that were relied upon to substantiate any representation covered by this order; and 3. All test reports, studies, surveys, demonstrations or other evidence in their possession or control, or of which they have knowledge, that contradict, qualify, or call into question such representation or the basis upon which respondents relied for such representation, including complaints from consumers or governmental entities.

IV.

It is further ordered, That:

A. Respondent 1554 Corporation shall notify the Federal Trade Commission at least thirty (30) days prior to any proposed change in the corporation 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 which may affect compliance obligations arising under this order; and B. Respondent Brainerd L. Mellinger, III, shall, for a period of three (3) years from the date of service of this order, promptly notify the Commission of the discontinuance of his present business or employment, or his affiliation with a new business or employment, with each such notice to include his new business address and a statement of the nature of the business or employment in which the respondent is newly engaged as well as a description of the respondent's duties and responsibilities in connection with the business or employment.

1554 CORPORATION, ET AL. 1171

1108 Decision and Order

V.

It is further ordered, That respondents, their successors and assigns, shall forthwith distribute a copy of this order to each of their operating divisions and to each of their officers, agents, representatives, or employees engaged in the preparation and placement of advertisements, promotional materials, product labels or other such sales materials covered by this order, and shall obtain from each such person or entity a signed statement acknowledging receipt of the order.

VI.

It is further ordered, That this order will terminate on April 14, 2017, or twenty years from the most recent date that the United States or the Federal Trade Commission files a complaint (with or without an accompanying consent decree) in federal court alleging any violation of the order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of:

A. Any paragraph in this order that terminates in less than twenty years;

B. This order's application to any respondent that is not named as a defendant in such complaint; and

C. This order if such complaint is filed after the order has terminated pursuant to this paragraph.

Provided further, that if such complaint is dismissed or a federal court rules that the respondent did not violate any provision of the order, and the dismissal or ruling is either not appealed or upheld on appeal, then the order will terminate according to this paragraph as though the complaint had never been filed, except that the order will not terminate between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

VII.

It is further ordered, That respondents, their successors and assigns, shall, within sixty (60) days after service of this order, file with the Commission a report, in writing, setting forth in detail the manner and form in which they have complied or intend to comply with this order.

Complaint 123 F.T.C.

IN THE MATTER OF

HERB GORDON AUTO WORLD, INC., ET AL.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT, THE TRUTH IN LENDING ACT, REGULATION Z, THE CONSUMER LEASING ACT AND REGULATION M

Docket C-3734. Complaint, April 15, 1997--Decision, April 15, 1997

This consent order prohibits, among other things, the Maryland company and its seven dealerships from obscuring important cost information in fine or unreadable print, from advertising financed purchase or leasing terms that are not available to consumers, and from misrepresenting the terms of financing or leasing any vehicle, the existence of the amount of any balloon payment, or the existence, number or amount of payments for financed purchases. The consent order requires the respondents to make all the disclosures required by the Truth in Lending Act, Regulation Z, Consumer Leasing Act, and Regulation M, and to ensure that the disclosures are noticeable, readable, and comprehensible to an ordinary customer.

Appearances

For the Commission: Carole L. Reynolds. For the respondents: Charles M. English, Jr., Ober, Kaler, Grimes & Shriver, Washington, D.C.

COMPLAINT

The Federal Trade Commission, having reason to believe that Herb Gordon Auto World, Inc. dba Herb Gordon Auto World, Herb Gordon Dodge, Herb Gordon Mercedes-Benz, Herb Gordon Nissan, Herb Gordon Oldsmobile, Herb Gordon Volvo, and Herb Gordon Used Cars, a corporation, ("respondent") has violated the Truth in Lending Act ("TILA"), 15 U.S.C. 1601-1667, as amended, and its implementing Regulation Z, 12 CFR 226, as amended, the Consumer Leasing Act ("CLA"), 15 U.S.C. 1667-1667e, as amended, and its implementing Regulation M, 12 CFR 213, as amended, and the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 45-58, as amended, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, hereby issues this complaint and alleges:

PARAGRAPH 1. Herb Gordon Auto World, Inc. dba Herb Gordon Auto World, Herb Gordon Dodge, Herb Gordon Mercedes- Benz, Herb Gordon Nissan, Herb Gordon Oldsmobile, Herb Gordon