MARY JO WHITE
   United States Attorney for the
   Southern District of New York
   By: SEAN C. CENAWOOD (SC-1952)
   Assistant United States Attorney
   100 Church Street, 19th Floor
   New York, New York 10007
   Tel.: (212) 637-2705

                        UNITED STATES DISTRICT COURT
                       SOUTHERN DISTRICT OF NEW YORK

                          UNITED STATES OF AMERICA
                                 Plaintiff

                                     v.

                    ZORAN LADICORBIC LTD., a corporation
                                 Defendant.

                                98 Civ. ( )

                                 COMPLAINT
                    ___________________________________

   Plaintiff, the United States of America, by its attorney, Mary Jo
   White, United States Attorney for the Southern District of New York,
   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 violations of the Commission's Trade Regulation Rule
   Concerning the Care Labeling of Textile Wearing Apparel ("Care
   Labeling Rule"), 16 C.F.R. Part 23, and injunctive relief for
   violations of the Textile Fiber Products Identification Act, as
   amended ("Textile Act"), 15 U.S.C. § 70, et seq., and the rules and
   regulations implementing the Textile Act, 16 C.F.R. Part 303; for
   violations of the Wool Products Labeling Act of 1939, as amended
   ("Wool Act"), 15 U.S.C. § 68, et seq., and the rules and regulations
   implementing the Wool Act, 16 C.F.R. Part 300; and for violations of
   Section 5(a)(1) of the FTC Act, 15 U.S.C. § 45(a)(1).

                           JURISDICTION AND VENUE

   MARY JO WHITE
   United States Attorney for the
   Southern District of New York
   By: SEAN C. CENAWOOD (SC-1952)
   Assistant United States Attorney
   100 Church Street, 19th Floor
   New York, New York 10007
   Tel.: (212) 637-2705

                        UNITED STATES DISTRICT COURT
                       SOUTHERN DISTRICT OF NEW YORK

                          UNITED STATES OF AMERICA
                                 Plaintiff

                                     v.

                   ZORAN LADICORBIC LTD., a corporation,
                                 Defendant.

                                98 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
   settlement of this action 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).

                               CIVIL PENALTY

   3. Defendant, Zoran Ladicorbic Ltd., its successors and assigns, shall
   pay to plaintiff a civil penalty, pursuant to Section 5(m)(1)(A) of