MARY JO WHITE
   United States Attorney

   By:
   Assistant United States Attorney
   1 Saint Andrew's Plaza
   New York, NY 10007
   Tel: 212-637-2200

                    IN THE UNITED STATES DISTRICT COURT
                   FOR THE SOUTHERN DISTRICT OF NEW YORK

                    UNITED STATES OF AMERICA, Plaintiff,
                                     v.
           TOMMY HILFIGER U.S.A., INC., a corporation, Defendant.

                           99 Civ. __________ ( )
                                 COMPLAINT

   Plaintiff, the United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("Commission") for its complaint alleges that:

          1. Plaintiff brings this action under Sections 5(a)(1),
          5(m)(1)(A), 9, 13(b) and 16(a) of the Federal Trade Commission
          Act ("FTC Act"), 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 49, 53(b)
          and 56(a) to obtain monetary civil penalties and injunctive and
          other relief for defendant's alleged violations of the
          Commission's Trade Regulation Rule Concerning the Care Labeling
          of Textile Wearing Apparel, 16 C.F.R. Part 423 ("the Care
          Labeling Rule").


          2. The Court has jurisdiction over this matter under 28 U.S.C.
          §§ 1331, 1337(a), 1345, and 1355 and under 15 U.S.C.
          45(m)(1)(A), 49, 53(b) and 56(a). This action arises under 15
          U.S.C. § 45(a)(1).


          3. Venue in the Southern District of New York is proper under
          15 U.S.C. § 53(b) and under 28 U.S.C. §§ 1391(b-c) and 1395(a).


          4. Defendant Tommy Hilfiger U.S.A., Inc. is a Delaware
          corporation with its office and principal place of business
          located within the Southern District of New York at 25 West
          39th Street, 13th Floor, New York, NY 10018. Defendant Tommy
          Hilfiger U.S.A., Inc. resides and transacts business in the

   MARY JO WHITE
   United States Attorney

   By:
   Assistant United States Attorney
   1 Saint Andrew's Plaza
   New York, NY 10007
   Tel: 212-637-2200

                    IN THE UNITED STATES DISTRICT COURT
                   FOR THE SOUTHERN DISTRICT OF NEW YORK

                    UNITED STATES OF AMERICA, Plaintiff,
                                     v.
           TOMMY HILFIGER U.S.A., INC., a corporation, Defendant.

                           99 Civ. __________ ( )

                               CONSENT DECREE

   WHEREAS: Plaintiff, the United States of America, has commenced this
   action by filing the Complaint herein; defendant has waived service of
   the Summons and Complaint; the parties have been represented by the
   attorneys whose names appear hereafter; and the parties have agreed to
   the settlement of any violations of the Federal Trade Commission's
   Trade Regulation Rule Concerning the Care Labeling of Textile Wearing
   Apparel that occurred in the five years preceding the date of the
   filing of the Complaint, as alleged in the Complaint, upon the
   following terms and conditions, without adjudication of any issue of
   fact or law and without defendant admitting liability for any of the
   matters alleged in the Complaint;

   THEREFORE, on the joint motion of plaintiff and defendant, it is
   hereby ORDERED, ADJUDGED, and DECREED as follows:

          1. This Court has jurisdiction of the subject matter and of the
          parties.


          2. The Complaint states a claim upon which relief may be
          granted against the defendant under Sections 5(a)(1),
          5(m)(1)(A), 9, 13(b) and 16(a) of the Federal Trade Commission
          Act, 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 49, 53(b) and 56(a).


          3. Defendant Tommy Hilfiger U.S.A., Inc., its successors and
          assigns, shall pay to plaintiff a civil penalty, pursuant to
          Section 5(m)(1)(A) of the Federal Trade Commission Act, 15

     _________________________________________________________________

               Statement of Commissioner Mozelle W. Thompson
     _________________________________________________________________

   The Commission recently entered into a consent decree with Tommy
   Hilfiger U.S.A., Inc. ("Tommy Hilfiger") to settle alleged violations
   of the Care Labeling Rule. Although I have voted to support this
   settlement because, based on Commission staff's investigation, there
   is ample reason to believe that Tommy Hilfiger has violated the Rule,
   the settlement nonetheless raises some concerns that I wish to discuss
   today.

   The Tommy Hilfiger brand is extraordinarily popular; especially among
   young people. A January 28, 1999 Washington Post article noted that
   Tommy Hilfiger is recognized by teenagers as third in the list of top
   three "coolest" brands, surpassing such well-known brands as Sony,
   Coca-Cola, and Ford. This popularity is reflected in over $840 million
   in sales in 1998. In light of this popularity, it is not surprising
   that Tommy Hilfiger clothing is expensive. Many Tommy Hilfiger basic
   shirts and pants sell for $100 or more.

   The Commission's complaint, among other things, alleged that certain
   Tommy Hilfiger garments did not state a "regular care procedure needed
   for the ordinary use of the product." As a result, according to the
   complaint, many consumers following the stated care instructions found
   color dye bleeding from one portion of garments to other portions. To
   address these alleged violations, Tommy Hilfiger agreed to comply with
   the Care Labeling Rule and to list a toll free help line on care
   labels. It also agreed to pay a $300,000 civil penalty.

   While the $300,000 penalty is indeed significantly higher than the
   penalties we have obtained in prior Care Labeling Rule cases, I am
   concerned that it may not provide sufficient deterrence to large
   profitable garment industry companies. Further, care labeling cases
   can cause enormous monetary injury to consumers who may spend $100 on
   a shirt, wear it a few times, and then find it ruined after following
   the prescribed instructions. This injury is especially egregious in
   cases like this one where the products are being heavily marketed and
   sold to young people who may not be able to effectively obtain redress
   for faulty goods.

   Thus, while I am generally pleased that we are increasing the
   penalties we are obtaining in most care labeling and other consumer
   protection cases where appropriate, these penalties should be
   substantially higher in cases like this one where the volume of sales
   and the nature of the customer may warrant more effective relief.
   ______________