012 3058
                                    UNITED STATES OF AMERICA
                             BEFORE FEDERAL TRADE COMMISSION


COMMISSIONERS:                    Timothy J. Muris, Chairman
                                  Sheila F. Anthony
                                  Mozelle W. Thompson
                                  Orson Swindle
                                  Thomas B. Leary


     In the Matter of

 LNK INTERNATIONAL, INC.,
      a corporation.                                     DOCKET NO. C-4037
                                                         DECISION AND ORDER


         The Federal Trade Commission having initiated an investigation of certain acts and
the respondent named in the caption hereof, and the respondent having been furnished thereafter
copy of a draft 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 respondent
with violations of the Federal Trade Commission Act; and

         The respondent, its attorney, and counsel for the Commission having thereafter executed an
agreement containing a consent order, and admission by the respondent of all the jurisdictional
forth in the draft complaint, a statement that the signing of said agreement is for settlement
only and does not constitute an admission by 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,
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 violated the said Act, and that a complaint should issue
charges in that respect, and having thereupon accepted the executed consent agreement and placed
such agreement on the public record for a period of thirty (30) days, and having duly considered the
comment filed thereafter by an interested person pursuant to Section 2.34 of its Rules, now in
conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues
complaint, makes the following jurisdictional findings, and enters the following order:



                                                 Page 1 of 4



        1.       Respondent LNK International, Inc. is a New York corporation with its principal
or place of business at 60 Arkay Drive, Hauppauge, New York  11788.

                          UNITED STATES OF AMERICA
                      BEFORE FEDERAL TRADE COMMISSION

                              In the Matter of

                  LNK INTERNATIONAL, INC., a corporation.

                                DOCKET NO.

                                 COMPLAINT

   The Federal Trade Commission, having reason to believe that LNK
   International, Inc. ("respondent") has violated the provisions of the
   Federal Trade Commission Act, and it appearing to the Commission that
   this proceeding is in the public interest, alleges:

   1. Respondent is a New York corporation with its principal office or
   place of business at 60 Arkay Drive, Hauppauge, New York 11788.

   2. Respondent has manufactured, labeled, offered for sale, sold, and
   distributed aspirin and acetaminophen tablets to the public, including
   but not limited to private label aspirin and acetaminophen brands.

   3. 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.

   4. Respondent has disseminated or has caused to be disseminated
   packaging and labeling for certain of its aspirin and acetaminophen
   products, including but not necessarily limited to the attached
   Exhibits A through G. The packaging and labeling contain the following
   statements or depictions:

     A. Health Pride Tri-Buffered Aspirin Analgesic, Exhibit A

     "Made in U.S.A. . . . Distributed by Compass Foods . . . ."
     B. Eckerd Aspirin Plus, Exhibit B

     "Made in U.S.A. . . .

     DISTRIBUTED BY ECKERD DRUG COMPANY . . ."
     C. Quality Choice Enteric Coated Lo-Dose Aspirin, Exhibit C

     "DISTRIBUTED BY QUALITY CHOICE . . .

     MADE IN U.S.A."
     D. Stop & Shop Enteric Coated Aspirin, Exhibit D

          Analysis of Proposed Consent Order to Aid Public Comment
     _________________________________________________________________

   The Federal Trade Commission has accepted an agreement, subject to
   final approval, to a proposed consent order from respondent LNK
   International, Inc. ("LNK").

   The proposed consent order has been placed on the public record for
   thirty (30) days for reception of comments by interested persons.
   Comments received during this period will become part of the public
   record. After thirty (30) days, the Commission will again review the
   agreement and the comments received and will decide whether it should
   withdraw from the agreement and take other appropriate action or make
   final the agreement's proposed order.

   This matter concerns "Made in U.S.A." claims on packaging and labeling
   for LNK's aspirin and acetaminophen tablets sold at retail bearing
   private brand names. The Commission's complaint alleges that
   respondent misrepresented on packaging and labeling that certain of
   these products, manufactured for customers such as Compass Foods
   (A&P), Eckerd Company, and Stop & Shop Supermarket Company, are all or
   virtually all made in the United States. According to the complaint,
   these products are actually made with significant foreign content. The
   products' active ingredients, bulk aspirin and acetaminophen
   compounds, that respondent processed into aspirin and acetaminophen
   tablets, are or were made outside the United States. The imported bulk
   aspirin and acetaminophen comprise a substantial percentage of total
   manufacturing costs and impart the crucial analgesic quality to the
   OTC products at issue. The Commission's complaint does not allege that
   all of LNK's private label aspirin and acetaminophen brands or
   products are mislabeled, but only that certain products for certain
   customers have been improperly labeled.

   The proposed consent order contains a provision that is designed to
   remedy the charges and to prevent the respondent from engaging in
   similar acts and practices in the future. Part I of the proposed order
   prohibits LNK from misrepresenting the extent to which any
   non-prescription drug product containing an analgesic is made in the
   United States. The order defines "analgesic" as an agent used to
   alleviate pain. The proposed order would allow LNK to represent that
   such products are made in the United States as long as all, or
   virtually all, of the ingredients or component parts of such products
   are made in the United States and all, or virtually all, of the labor
   in manufacturing such products is performed in the United States. The
   proposed order also would allow LNK to represent that a product
   containing imported active ingredient(s) is "Processed in the United
   States with Foreign Ingredients" when describing a product that has
   been "significantly processed" in the United States.

                          UNITED STATES OF AMERICA
                      BEFORE FEDERAL TRADE COMMISSION

                              In the Matter of

                  LNK INTERNATIONAL, INC., a corporation.

                             File No. 012 3058

                     AGREEMENT CONTAINING CONSENT ORDER

   The Federal Trade Commission has conducted an investigation of certain
   acts and practices of LNK International, 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 LNK International, Inc., by its
   duly authorized officer, and counsel for the Federal Trade Commission
   that:

          1. Proposed respondent is a New York corporation with its
          principal office or place of business at 60 Arkay Drive,
          Hauppauge, New York 11788.
          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 thirty (30) days and information
          about it publicly released. The Commission thereafter may
          either withdraw its acceptance of this agreement and so notify
          proposed respondent, in which event it will take such action as
          it may consider appropriate, or issue and serve its complaint