UNITED STATES OF AMERICA
                          BEFORE FEDERAL TRADE COMMISSION


Commissioners:                     Robert Pitofsky, Chairman
                                   Mary L. Azcuenaga
                                   Janet D. Steiger
                                   Roscoe B. Starek, III
                                   Christine A. Varney

____________________________________ )
  In the Matter of                                ))
INTERNATIONAL ASSOCIATION OF                      )
CONFERENCE INTERPRETERS, a/k/a                    )
Association Internationale des                    )
Interprètes de Conférence, and                    )           Docket No. 9270
                                                  )
UNITED STATES REGION OF THE                       )
INTERNATIONAL ASSOCIATION OF                      )
CONFERENCE INTERPRETERS,                          ))
                Respondents.                      )
____________________________________)


                                                 ORDER

                                                        I.

        IT IS ORDERED that, for purposes of this order, the following definitions shall apply:

        A.   "AIIC" means respondent International Association of Conference Interpreters, also
known as Association Internationale des Interprètes de Conférence, its directors, trustees, general
assemblies, councils, committees, working groups, boards, divisions, sectors, regions, chapters,
officers, representatives, delegates, agents, employees, successors, and assigns.

        B.  "U.S. Region" means respondent United States Region of AIIC, its directors, trustees,
general assemblies, councils, committees, working groups, boards, divisions, sectors, regions,
chapters, officers, representatives, delegates, agents, employees, successors, and assigns.



        C.  "Fees" means any cash or non -cash charges, rates, prices, benefits or other
compensation received or intended to be received for the rendering of services, including, but not
limited to, salaries, wages, transportation, lodging, meals, allowances (including subsistence and
travel allowances), reimbursements for expenses, cancellation fees, recording fees, compensation
for time not worked, compensation for travel time, compensation for preparation or study time,
and payments in kind.

        D.  "Cancellation fee" means any fee intended to compensate for the termination,

          OPINION OF COMMISSIONER ROSCOE B. STAREK, III,
            CONCURRING IN PART AND DISSENTING IN PART

                           In the Matter of

  INTERNATIONAL ASSOCIATION OF CONFERENCE INTERPRETERS, ET AL.
                           Docket No. 9270


     In an opinion issued just about a year ago, the Commission
held that respondent California Dental Association ("CDA")
committed a per se violation of the antitrust laws by
promulgating and enforcing restrictions on members' advertising
of prices for dental services in California.1  Although I agreed
with my colleagues that CDA's restraints on both price and non-
price advertising merited antitrust condemnation, I disagreed
with their per se approach, which in my view applied -- by its
language and its logic -- not only to CDA's particular price
advertising restraints but also to "all agreements among
competitors to restrain truthful, nondeceptive price
advertising."2  I pointed out in CDA that Massachusetts Board of
Registration in Optometry, 110 F.T.C. 549 (1988) ("Mass. Board")
-- frequently and fruitfully relied on until CDA, then cast aside
(if not explicitly overruled) by the CDA majority for reasons
never clearly spelled out -- still provides a dependable
framework for the analysis of horizontal restraints.3


     1    California Dental Ass'n, Docket No. 9259, 5 Trade Reg.
Rep. (CCH)   24,007 (Mar. 25, 1996) ("CDA"), appeal pending, No.
96-70409 (9th Cir., filed May 20, 1996).  The Commission also
concluded that CDA's restrictions on both price and non-price
forms of advertising were unlawful under the antitrust rule of
reason.  CDA, slip op. at 37-39 [5 Trade Reg. Rep. (CCH)
  24,007 at 23,796-97].

     2    CDA, Opinion of Commissioner Roscoe B. Starek, III,
Concurring in Part and Dissenting in Part, at 1 [5 Trade Reg.
Rep. (CCH)   24,007 at 23,815].

     3    "[I]f the majority considers Mass. Board beyond repair,
why has it not overruled the case?  If the majority has
identified specific weaknesses in Mass. Board analysis that might
be remedied, why not apply Mass. Board in this and other
appropriate cases so that the process of case-by-case adaptation
and improvement can occur?"  Id. at 9 [5 Trade Reg. Rep. (CCH)
  24,007 at 23,818].

                                                     OPINION OF THE COMMISSION

By Varney, Commissioner:

           Respondents International Association of Conference Interpreters ("AIIC," as it is known
by its French acronym) (IDF 1) 1 and its United States Region ("U.S. Region") are charged with
violating Section 5 of the Federal Trade Commission Act ("FTC Act") by adopting and enforcing
rules that govern how their members compete.  We find that  respondents  price-fixing practices
and market allocation rules are  per se unlawful agreements in restraint of trade and a violation of
the FTC Act.  We further find that the rules governing non-price terms and conditions of
employment, business arrangements, and advertising must be analyzed under the rule of reason.
Because the record evidence is insufficient to demonstrate a violation of law under the rule of
reason, we dismiss the complaint allegations that those rules unlawfully restrain trade.   In
these conclusions, we also find that AIIC s actions, which form the basis for this lawsuit, affect
interstate commerce in the United States and are sufficient to confer specific personal
that respondents do not qualify for the  "not-for-profit" exemption to the FTC s jurisdiction; and
that respondents do not qualify for either the statutory or non-statutory labor exemption.

           The order we enter prohibits respondents for  a period of twenty (20) years from imposing
any price-related or market allocation restraints in the United States.

1.   BACKGROUND

           The Commission s complaint in this matter, issued on October 25, 1994, charges the
respondents with restraining competition among conference interpreters in the United States in
violation of Section 5 of the FTC Act, 15 U.S.C.   45 (1994), by conspiring with their members
to fix the price and output of interpretation services in the United States.  After pretrial
26 days of trial testimony, and pre- and post-trial motion s, the record closed on May 16, 1996.
Administrative Law Judge ("ALJ") James P. Timony issued a decision and proposed order on July
26, 1996.

           The ALJ found that for more than forty years, AIIC regulated the employment of its
members by adopting and enforcing an elaborate series of work rules governing,  inter alia, the
minimum daily rates to be charged in the United States, length of the working day, number of
interpreters to be hired at a conference, ability of out-of-town and staff interpreters to compete


     1  The following abbreviations are used in this opinion:
           ID          -- Initial Decision of the ALJ
           IDF         -- Numbered Findings in the ALJ s Initial Decision
           CX          -- Complaint Counsel s Exhibit
           CXT -- Complaint Counsel s Exhibit -- English Translation
           RX          -- Respondents  Exhibit
           Tr.         -- Transcript of Trial before the ALJ
           Stip. -- ALJ s order setting forth joint Stipulations of Fact



with local freelance interpreters, advertising, and payment for travel expenses, per diem, rest days

                                      UNITED STATES OF AMERICA
                              BEFORE FEDERAL TRADE COMMISSION

__________________________________________
                                                       )
  In the Matter of                                     )
                                                       )
INTERNATIONAL ASSOCIATION OF                           )
CONFERENCE INTERPRETERS, a/k/a                         )
Association Internationale des                         )
Interprètes de Conférence, a                           )
corporation, and                                       )      DOCKET NO. 9270
                                                       )
UNITED STATES REGION OF THE                            )
INTERNATIONAL ASSOCIATION                              )
OF CONFERENCE INTERPRETERS,                            )
an unincorporated association.                         )
__________________________________________)



                                          INITIAL DECISION


         The Commission's complaint in this matter, issued October 25, 1994,
charges the International Association of Conference Interpreters ("AIIC") and the
U.S. Region of AIIC with unfair methods of competition.

         The complaint charges that AIIC maintains work rules binding on members;
that AIIC members can be expelled for violations; that the U.S. Region of AIIC has
participated in enforcing those rules; that AIIC has minimum fees for interpretation
services in the United States; that members' rates of daily remuneration shall be
the rates specified in the fee schedules.

         The complaint alleges that AIIC rules require: (a) identical compensation for
interpreters working on the same interpretation team regardless of differences in
their experience or skill; (b) payment of interpretation fees on an indivisible full-day
basis, regardless of the number of hours actually worked; (c) added fees for
whispered or solo interpretation; (d) cancellation charges; and (e) restrictions on
providing services free of charge.



      The complaint alleges that AIIC rules prescribe rates for: (a) reimbursement
for travel, lodging, and subsistence; (b) compensation for travel time, briefing time,
rest time, weekends or other non-working days over the duration of a conference;
and (c) recording of interpretations.

      The complaint alleges that the AIIC work rules prescribe mandatory