Spiegel, Inc. v. Federal Trade Commission

494 F.2d 59, 26 A.L.R. Fed. 783, 1974 U.S. App. LEXIS 9626, 1974 Trade Cas. (CCH) 74,971
CourtCourt of Appeals for the Seventh Circuit
DecidedMarch 18, 1974
Docket73-1233
StatusPublished
Cited by14 cases

This text of 494 F.2d 59 (Spiegel, Inc. v. Federal Trade Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spiegel, Inc. v. Federal Trade Commission, 494 F.2d 59, 26 A.L.R. Fed. 783, 1974 U.S. App. LEXIS 9626, 1974 Trade Cas. (CCH) 74,971 (7th Cir. 1974).

Opinions

KILEY, Senior Circuit Judge.

The Federal Trade Commission ordered petitioner, Spiegel, Inc., to cease and desist from engaging in deceptive trade practices and unfair competition1 in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(c).2 Spiegel petitions to have the order reviewed and set aside. We deny the petition and direct enforcement of the Commission’s order.

Spiegel is a catalogue retailer of, among other things, clothing, household appliances and kitchenware, with principal office and place of business in Chicago, Illinois. During the relevant period prior to November, 1971, it shipped its merchandise, when sold, from Chicago into several of the United States. In its sales efforts it advertised for credit customers in circulars to “established” and “new” customers, and seasonal cata-logues to “new” customers. The Commission’s complaint, issued November 8, 1971, alleged that Spiegel’s advertising practices were deceptive and unfair in violation of the Act, and that the complaint was “in the public interest.”

The cease and desist order followed upon Spiegel’s answer denying deception, a pre-hearing stipulation of facts, a limited evidentiary hearing before a Commission hearing officer, appeals to the Commission by both parties,3 and the Commission’s adoption, with modifications, of the hearing officer’s decision.

The complaint alleged that the statements contained in circulars and seasonal catalogues which offered “free trial” or “percent off” of merchandise represented directly or by implication that the offers were available “without condition of restriction;” that “in truth and in fact” the offers of shipment to the “new” customers were conditioned upon the offerees qualifying for credit under Spiegel criteria; and that no shipments were made under the offers to the “established . . . credit customers” unless the amount of the purchases, added to the pre-existing credit charges of the purchaser, was less than the total credit amount Spiegel had previously allowed the customer.

The complaint charged that Spiegel’s use of these alleged “false, misleading and deceptive statements” had the “capacity and tendency” to mislead the public into purchasing Spiegel’s merchandise in reliance upon the truth of the statements “all to the prejudice and injury of the public and of [Spiegel’s] competitors,” and constituted unfair and deceptive practices and unfair competition in violation of the Act.

Spiegel’s answer denied that the complaint was in the public interest, stated that the advertising followed the custom and usage of the trade, stated the alleged unlawful practices had been abandoned, and denied deception and injury to customers or competition.

The Commission’s Final Order4 directed Spiegel to desist from its “free [62]*62trial” or “percent off” advertising practices as to prospective and established customers, unless it “conspicuously disclose [d] in immediate conjunction” with the offers that they are subject to Spie-gel’s credit approval; disclosed at the top of questionnaires requesting information about credit that the questionnaire is an application for credit; and disclosed any condition or restriction rendering an offeree ineligible to qualify for the offer. Finally, the order directed Spiegel to desist from representing directly or by implication that a free trial offer or price reduction is without condition when such condition exists.

I.

There is no merit in Spiegel’s contention that the order should be set aside as too trivial for Commission attention because there was no proof of injury to the public or to Spiegel’s competitors.

Protection of the public is essential to justify filing a Section 5 complaint. FTC v. Klesner, 280 U.S. 19, 27, 50 S.Ct. 1, 74 L.Ed. 138 (1929). However, proof of actual injury is unnecessary to support a Commission cease and desist order.

Significant in the examiner’s decision, adopted by the Commission, are the statements that “an advertisement must be truthful .... To comply with the Federal Trade Commission Act, an advertisement must be akin to a passport for the complete truthfulness of the statements contained therein;” and that where, as here, the offers are conditioned, “unsophisticated clues to the conditions should be as obvious on the face of the advertisement as the inducing offers themselves.”

The moral tone of those statements is implicit in Justice Cardozo’s language in FTC v. Algoma Co., 291 U.S. 67, 78-79, 54 S.Ct. 315, 320, 78 L.Ed. 655 (1934):

Fair competition is not attained by balancing a gain in money against a misrepresentation of the thing supplied. The courts must set their faces against a conception of business standards so corrupting in its tendency. The consumer is prejudiced if upon giving an order for one thing, he is supplied with something else. Federal Trade Comm’n v. Royal Milling Co., 288 U.S. 212, 216, [53 S.Ct. 335, 77 L.Ed. 706]; Carlsbad v. W. T. Thackeray & Co., 7 Cir., 57 F. 18. In such matters, the public is entitled to get what it chooses, though the choice may be dictated by caprice or by fashion or perhaps by ignorance. Nor is the prejudice only to the consumer “A method inherently unfair does not cease to be so because those competed against have become aware of the wrongful practice.” Federal Trade Comm’n v. Winsted Hosiery Co., 258 U.S. 483, 494, [42 S.Ct. 384, 385, 66 L.Ed. 729], The careless and the unscrupulous must rise to the standards of the scrupulous and diligent. The Commission was not organized to drag the standards down. (Footnote omitted.)

The primacy of truthfulness in advertising was made explicit in FTC v. Colgate-Palmolive, 380 U.S. 374, 85 S.Ct. 1035, 13 L.Ed.2d 904 (1965), wherein the Supreme Court held that it was a deceptive practice to convey to television viewers the impression that they were watching an actual experiment when they were viewing only a simulation, notwithstanding the fact that the experiment had been conducted off-camera and the product had performed as represented. The Court stated, at 388-389, 85 S.Ct. at 1044:

We find an especially strong similarity between the present case and those cases in which a seller induces the public to purchase an arguably good product by misrepresenting his line of business, by concealing the fact that the product is reprocessed, or by misappropriating another’s trademark. In each the seller has used a misrepresentation to break down what he regards to be an annoying or irrational habit of the buying public — the preference for particular manufacturers or known brands regardless of a prod[63]*63uct’s actual qualities, the prejudice against reprocessed goods, and the desire for verification of a product claim. In each case the seller reasons that when the habit is broken the buyer will be satisfied with the performance of the product he receives.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stock v. Integrated Health Plan, Inc.
241 F.R.D. 618 (S.D. Illinois, 2007)
Zanakis-Pico v. Cutter Dodge, Inc.
47 P.3d 1222 (Hawaii Supreme Court, 2002)
Ivey, Barnum & O'Mara v. Indian Harbor Properties, Inc.
461 A.2d 1369 (Supreme Court of Connecticut, 1983)
Newton v. Moffie
434 N.E.2d 656 (Massachusetts Appeals Court, 1982)
State v. O'Neill Investigations, Inc.
609 P.2d 520 (Alaska Supreme Court, 1980)
Porter & Dietsch, Inc. v. Federal Trade Commission
605 F.2d 294 (Seventh Circuit, 1979)
Spiegel, Inc. v. Federal Trade Commission
494 F.2d 59 (Seventh Circuit, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
494 F.2d 59, 26 A.L.R. Fed. 783, 1974 U.S. App. LEXIS 9626, 1974 Trade Cas. (CCH) 74,971, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spiegel-inc-v-federal-trade-commission-ca7-1974.