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1
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DECISION & ORDER
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EXTRACTED KEY WORDS
COMMISSION AMOUNT ADVERTISING LEASE PAYMENT COMPLAINT CONSUMER FEDERAL TRADE COMMISSION DISCLOSURES LEASE SIGNING TOTAL AMOUNT DELIVERY MOTOR VEHICLE ACT GREY ADVERTISING CHARGE REGULATION VIOLATION MANNER CLOSED-END CREDIT SUCCESSORS DIRECTORS REVISED REGULATION AGREEMENT JURISDICTION OFFICERS SUBPARAGRAPH TERMINATE APPEALING |
9723190
B236162
UNITED STATES OF AMERICA
BEFORE FEDERAL TRADE COMMISSION
COMMISSIONERS:
Robert Pitofsky, Chairman
Mary L. Azcuenaga
Sheila F. Anthony
Mozelle W. Thompson
Orson Swindle
In The Matter of
GREY ADVERTISING, INC., a corporation.
DOCKET NO. C-3793
DECISION AND ORDER
The Federal Trade Commission having initiated an investigation of
certain acts and practices of the respondent named in the caption
hereof, and the respondent having been furnished thereafter with a
copy of a draft of complaint which the Bureau of Consumer Protection
proposed to present to the Commission for its consideration and which,
if issued by the Commission, would charge the respondent with
violation of the Federal Trade Commission Act; and
The respondent, its attorneys, and counsel for the Commission having
thereafter executed an agreement containing a consent order, an
admission by the respondent of all the jurisdictional facts set forth
in the aforesaid draft of complaint, a statement that the signing of
said agreement is for settlement purposes only and does not constitute
an admission by the respondent that the law has been violated as
alleged in such complaint, or that the facts as alleged in such
complaint, other than jurisdictional facts, are true 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 respondent has
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:
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2
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COMPLAINT
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EXTRACTED KEY WORDS
LEASE PAYMENT CREDIT GREY EXHIBIT DISCLOSE ACT CONSUMERS RESPONDENT AMOUNT FEDERAL TRADE COMMISSION VEHICLES PRACTICES VIOLATIONS MITSUBISHI REGULATION SCREENS MONTHLY PAYMENT DEALER OPTIONS FEE REPRESENTATION SECURITY DEPOSIT PURCHASE GALANT PARAGRAPH AFFECTING COMMERCE VIDEO BOTTOM REGIONALLY REQUIRED EQUIPMENT CHARGES |
9723190
B236162
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In The Matter of
GREY ADVERTISING, INC., a corporation.
DOCKET NO. C-3793
COMPLAINT
The Federal Trade Commission, having reason to believe that Grey
Advertising, Inc., a corporation ("respondent" or "Grey"), has
violated the provisions of the Federal Trade Commission Act, 15 U.S.C.
§§ 45-58, as amended, the Consumer Leasing Act, 15 U.S.C.
1667-1667e, as amended, and its implementing Regulation M, 12 C.F.R.
213, as amended, and the Truth in Lending Act, 15 U.S.C. §§ 1601-1667,
as amended, and its implementing Regulation Z, 12 C.F.R. § 226, as
amended, and it appearing to the Commission that this proceeding is in
the public interest, alleges:
1. Respondent Grey Advertising, Inc. is a Delaware corporation with
its principal office or place of business at 777 Third Avenue, New
York, New York 10017.
2. Respondent, at all times relevant to this complaint, was an
advertising agency of Mitsubishi Motor of America, Inc.
("Mitsubishi"). Respondent has disseminated advertisements to the
public that promote consumer leases, as the terms "advertisement" and
"consumer lease" are defined in Section 213.2 of Regulation M, 12
C.F.R. § 213.2, as amended.
3. Respondent has disseminated advertisements to the public that
promote credit sales and other extensions of closed-end credit in
consumer credit transactions, as the terms "advertisement," "credit
sale," and "consumer credit" are defined in Section 226.2 of
Regulation Z, 12 C.F.R. § 226.2, as amended.
4. The acts and practices of respondent alleged in this complaint have
been in or affecting commerce, as "commerce" is defined in Section 4
of the Federal Trade Commission Act, 15 U.S.C. § 44.
Lease Advertising
5. Respondent has prepared and disseminated or has caused to be
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3
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AGREEMENT CONTAINING CONSENT
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EXTRACTED KEY WORDS
GREY COMPLAINT ACT FEDERAL TRADE COMMISSION GREY ADVERTISING LEASE PRACTICES ADVERTISEMENTS REPRESENTATION AMOUNT PAYMENT AGREEMENT CREDIT REGULATION VEHICLE DISCLOSURES CONSENT ORDERS DRAFT COMPLAINT TOTAL AMOUNT MOTOR VEHICLE GREY EXHIBIT MONTHLY PAYMENT MOVING BACKGROUND PRINCIPAL OFFICE SUBPARAGRAPH REVISED REGULATION DEALER OPTIONS DECEPTIVE ACTS MITSUBISHI VEHICLES |
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In The Matter of
GREY ADVERTISING, INC., a corporation.
FILE NO. 972 3190
AGREEMENT CONTAINING
CONSENT ORDER
The Federal Trade Commission ("Commission") has conducted an
investigation of certain acts and practices of Grey Advertising, Inc.,
a corporation ("proposed respondent"). Proposed respondent, having
been represented by counsel, is willing to enter into an agreement
containing a consent order resolving the allegations contained in the
attached draft complaint. Therefore,
IT IS HEREBY AGREED by and between Grey Advertising, Inc., by its duly
authorized officers, and counsel for the Federal Trade Commission
that:
1. Proposed respondent Grey Advertising, Inc. is a New York
corporation with its principal office or place of business at 777
Third Avenue, New York, New York 10017.
2. Proposed respondent admits all the jurisdictional facts set forth
in the draft complaint.
3. Proposed respondent waives:
a. Any further procedural steps;
b. The requirement that the Commission's decision contain a
statement of findings of fact and conclusions of law; and
c. All rights to seek judicial review or otherwise to challenge
or contest the validity of the order entered pursuant to this
agreement.
4. This agreement shall not become part of the public record of the
proceeding unless and until it is accepted by the Commission. If this
agreement is accepted by the Commission, it, together with the draft
complaint, will be placed on the public record for a period of sixty
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