Commonwealth v. AmCan Enterprises, Inc.

712 N.E.2d 1205, 47 Mass. App. Ct. 330, 1999 Mass. App. LEXIS 793
CourtMassachusetts Appeals Court
DecidedJuly 21, 1999
DocketNo. 97-P-476
StatusPublished
Cited by21 cases

This text of 712 N.E.2d 1205 (Commonwealth v. AmCan Enterprises, Inc.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. AmCan Enterprises, Inc., 712 N.E.2d 1205, 47 Mass. App. Ct. 330, 1999 Mass. App. LEXIS 793 (Mass. Ct. App. 1999).

Opinion

Dreben, J.

Between 1990 and 1994, the defendants, using the name “The New England Yellow Pages” and the logo “walking fingers,” mailed approximately 2,345,000 advertising solicitations to businesses in Massachusetts. Alleging violations of G. L. c. 93A, § 2,2 and 940 Code Mass. Regs. §§ 3.05(1) and 3.16(2) (1993),3 by sending misleading and deceptive solicitations to consumers for listing in a yellow page directory unconnected with a telephone company, the Attorney General brought [332]*332an action against the defendants under c. 93A, § 4. On the Commonwealth’s motion for summary judgment, a judge of the Superior Court determined that the defendants had violated c. 93A, § 2(a), at least 2,345,000 times and granted partial summary judgment in favor of the Commonwealth on the issue of liability.4 Following an assessment of damages hearing, a final judgment entered which included a permanent injunction against the defendants’ solicitations, an award of restitution to those persons (nine) who had filed affidavits setting forth the amount paid to the defendants, an assessment of civil penalties of $1,000,000 jointly and severally against the defendants, and an award of attorney’s fees to the Commonwealth of $26,415.

In their appeal, the defendants claim that (1) the Attorney General’s regulations and the judge’s decision are not in accord with current interpretations of the Federal Trade Commission, contrary to the requirements of c. 93A, §§ 2(b) and 2(c), see note 2, supra; (2) the granting of summary judgment was error in the face of the minimal number of complaints and an affidavit from the defendants’ expert stating that the defendants’ conduct was not deceptive; (3) the civil penalty was improperly assessed as the Commonwealth presented no evidence of actual harm from the defendants’ deceptive acts; and (4) the award of [333]*333attorney’s fees was unsupported by the evidence. We affirm the judgment, as modified in accordance with this opinion, for substantially the reasons set forth by the judge in his careful and well-reasoned memoranda of decision.

1. Summary judgment materials. In support of its motion, the Commonwealth submitted the solicitation packages of the defendants,5 decisions of the United States Postal Service finding that the defendants had engaged in conduct violating Federal law by seeking money by means of false representations through the mail,6 interrogatories answered by the defendants, and affidavits, including nine from persons who stated that they had believed that the solicitation had come from the local phone company and would not have returned the solicitation had they known its source. The defendants produced affidavits and other material showing that other companies publish directories which are not affiliated with any telephone company, that both the term “yellow pages” and the “walking fingers” logo are in the public domain, and that the defendants had obtained from the Massachusetts Secretary of State trademarks for “The Massachusetts Yellow Pages,” “The New England Yellow Pages,” and “The Yellow Pages of Massachusetts.” They also presented an affidavit of Edward T. Popper, a business school dean and a former consumer research advisor to the Federal Trade Commission, which stated that he had “conducted and reviewed results of a survey of potential mailing . . . recipients” of the defendants — the affidavit gives no further details as to this survey — and concluded that “[Reasonable recipients of th[e]se [334]*334mailings are likely to understand the nature of those mailings, the source of the mailings, and the nature of the directory listing being promoted” and, hence, are not deceived.

a. Proper standard for determining deception. The defendants base their argument that summary judgment was improperly granted on two grounds. We treat first their claim that the standard for determining deception set forth in the Attorney General’s regulations, see note 3, supra, is contrary to the mandate contained in c. 93A, § 2(b) and (c), see note 2, supra, and that this incorrect standard was applied by the judge. Section 2(b) of c. 93A states the legislative intent that courts, in construing which acts are deceptive, are to be “guided by the interpretations given by the Federal Trade Commission and the Federal Courts” to the analogous Federal statute, and § 2(c) provides that the rules and regulations of the Attorney General “shall not be inconsistent with the rules, regulations and decisions of the Federal Trade Commission and the Federal Courts.” See note 2, supra.

The defendants argue that 940 Code Mass. Regs. § 3.05(1), see note 3, supra, which prohibits a representation which “has the capacity or tendency or effect of deceiving buyers,” establishes an outmoded standard in view of the new criteria set forth in Cliffdale Assocs., Inc., 103 F.T.C. 110, 164-165 (1984). That case found “this approach to deception [tendency or capacity to deceive] and violations of Section 5 [the Federal analogue to c. 93A, § 2,] to be circular and therefore inadequate to provide guidance on how a deception claim should be analyzed.” Id. at 164. The Federal Trade Commission then articulated what it believed to be “a clear and understandable standard for deception.” Ibid. An act or practice will be found deceptive “if, first, there is a representation, omission, or practice that, second, is likely to mislead consumers acting reasonably under the circumstances, and third, the representation, omission, or practice is material.” Id. at 165.

The decision, however, noted that these elements articulate the factors actually used in most earlier cases even if couched in terms of “a tendency and capacity to deceive.” Id. at 165 (citation omitted). Thus, the “likely to mislead” requirement, the Federal Trade Commission noted, reflects the long-established principle that actual deception need not be proved. That the effect be on “consumers acting reasonably under the circumstances” is likewise not a new requirement; an advertise[335]*335ment would not have been considered deceptive if unreasonably misunderstood by an unrepresentative class of persons. Ibid. Similarly, the third element, materiality, that is, a representation or omission that “involves information that is important to consumers and, hence, likely to affect their choice of, or conduct regarding, a product,” was usually one of the factors considered in the deception cases. Id. at 165-166.7

In refuting the defendants’ argument that the two regulations, see note 3, supra, were inconsistent with the standard articulated in Cliffdale, the motion judge correctly concluded, based on Massachusetts law, that the newly articulated standard “did not represent a radical change in policy” and that the “new test is rooted in established precedent and does not affect the validity of the Attorney General’s regulations.” He pointed to Leardi v. Brown, 394 Mass. 151, 156 (1985),8 which requires the “tendency to deceive” standard to be construed in the context of a reasonable consumer, and that the misrepresentation be material. See Purity Supreme, Inc. v. Attorney Gen., 380 Mass. 762, 111

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Bluebook (online)
712 N.E.2d 1205, 47 Mass. App. Ct. 330, 1999 Mass. App. LEXIS 793, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-amcan-enterprises-inc-massappct-1999.