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    Edelman, Combs, Latturner, & Goodwin, LLC

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    Chicago, IL 60603

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    Phone: 312-739-4200
    Fax: 312-419-0379


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    FTC Approves Final Order Settling Charges that Mars Petcare Made False Health Claims for Its Eukanuba Brand Dog Food

    Tuesday, December 13th, 2016

    Following a public comment period, the Federal Trade Commission has approved a final consent order with Mars Petcare U.S. settling charges that the company falsely advertised specific health benefits of its Eukanuba brand dog food.

    According to the FTC’s complaint, filed in August 2016, the company claimed in ads, but could not prove, that a 10-year study found that dogs fed Eukanuba could extend their expected lifespan by 30 percent or more. The Commission charged that the longevity claims were false or unsubstantiated and that the claim that longevity was proven through scientific evidence was false, in violation of the FTC Act.

    Under the final order settling the charges, Mars Petcare is barred from engaging in similar deceptive acts or practices in the future. The order prohibits the company from making any misleading or unsubstantiated claims that its Eukanuba-brand pet food or any other pet food will enable any dogs to extend their lifespan by 30 percent or more or live exceptionally long lives. It also prohibits the company from making misleading or unsubstantiated claims regarding the health benefits of any pet food, and requires it to have competent and reliable scientific evidence to back up any such claims.

    Finally, the proposed order prohibits Mars Petcare, when advertising any pet food, from misrepresenting the existence, results, conclusions, or interpretations of any study, or falsely stating that the health benefits claimed are scientifically proven. It also contains compliance and monitoring requirements to ensure the company abides by its terms.

    The Commission vote approving the final order and responses to the public commenters was 3-0. (FTC File No. 152-3229; the staff contact is David M. Newman, FTC Western Region, San Francisco, 415-848-5123.)

    National Collegiate private student loans

    Tuesday, December 13th, 2016

    Are you being sued or dunned on a private student loan allegedly held by National Collegiate Student Loan Trust? (updated)

    Until 2015, about 125 lawsuits per month were  filed to collect National Collegiate Student Loan Trust   loans in Cook County alone, with more in other Illinois counties.  We defended about 100  of these cases.  Most of those we have defended have been dismissed, with or without prejudice.  As a result, the filing of new cases virtually ceased.

    Recently, National Collegiate trusts have resumed filing lawsuits against Illinois residents.

    Some important dos and don’ts with respect to these loans:

    DO NOT  allow National Collegiate to get a judgment against you by failing to respond to a summons and complaint.  National Collegiate  has obtained hundreds of judgments against people who did not bother to defend themselves even though they had valid defenses.  If you fail to respond, National Collegiate  can get a default judgment against you and then garnish your non-exempt wages, seize your non-exempt assets and put liens on your real property.

    DO NOT agree to a judgment with an agreement that you will pay a small sum per month for six months or so.  At one point, National Collegiate was trying to get people to agree to this.  If  you do this you have waived your right to dispute the debt and at the end of that period the judgment  can be enforced against your nonexempt assets and up to 15% of your wages.   Judgments are enforceable for 20-27 years in Illinois, and bear interest at 9%.  Some of these agreements don’t even pay the interest on the judgment.  Any agreement should completely resolve the debt, with a substantial discount.

    DO NOT  make the mistake of calling National Collegiate or its attorneys or debt collectors before speaking to an attorney.  We will review your documents and facts and consult with you without charge, and advise you whether you have a defense, whether we will take your case and what our fees will be.

    DO NOT ASSUME THAT NATIONAL COLLEGIATE IS ENTITLED TO COLLECT without having an attorney familiar with these loans examine potential defenses.  We believe that most National Collegiate cases have serious problems with them, for multiple reasons.

    • First, we believe that virtually all of the lawsuits filed on these loans are filed in violation of Illinois law.
    • Second, National Collegiate sometimes cannot prove that it has the right to collect on the student loan debt at issue. In at least one case, National Collegiate filed suit on a loan that had been assigned to another entity and paid in full to that entity.
    • Sometimes National Collegiate cannot prove  the amount due.  National Collegiate loans are actually serviced by Transworld/ NCO Financial, an organization which has a long history of consent orders and government investigations.   Transworld is currently under investigation by the Consumer Financial Protection Bureau; this casts doubt on the accuracy of any records it produces.
    • Some suits appear to be filed beyond the statute of limitations.  We have obtained rulings that these loans are governed by the five-year Illinois statute of limitations, not the ten year statute as National Collegiate claims.
    • The interest rates on some of the loans may be unlawful.
    • Finally, we believe that many or all of the obligations of cosigners under these loans may not be enforceable.

    We have lots of experience defending claims on these private loans.  We have also brought a number of affirmative claims challenging National Collegiate’s  collection practices, as both individual and (more than half a dozen) class actions.  Many of these collection practices, including many National Collegiate collection letters, violate the Fair Debt Collection Practices Act and other laws.

    If you are currently being sued or dunned on a private student loan allegedly held by National Collegiate, please call us immediately.

    Also, please send us any collection letters seeking to collect National Collegiate loans.  Many contain violations of the Fair Debt Collection Practices Act and other laws.

    Perkins loans

    Tuesday, December 13th, 2016

    Please contact us if a debt collector is trying to collect a Perkins loan from you.  It appears that in some or many cases, the collectors are trying to obtain collection fees in excess of 30% of the principal, interest and late charges.  Collection fees are capped by law at 30%.

    FTC Rules California Naturel, Inc. Misled Consumers, Violated the FTC Act

    Monday, December 12th, 2016

    Order bars company from deceptively labeling products as “all natural”

    The Federal Trade Commission has granted summary decision against California Naturel, Inc., for falsely advertising its sunscreen product as “all natural” in violation of Sections 5 and 12 of the FTC Act.

    In its opinion, written by Chairwoman Edith Ramirez, the Commission states that the company promotes its “all natural” sunscreen on its website as containing “only the purest, most luxurious and effective ingredients found in nature.”  But California Naturel admitted that eight percent of its sunscreen formula is in fact dimethicone, a synthetic ingredient.

    The Commission was not persuaded by the company’s argument that its ingredient list and a disclaimer recently added to the company’s web page cured its misleading advertising, noting that consumers should not have to search for and dig out information that contradicts what an advertisement expressly and prominently conveys. For example, the “all natural” claims were prominent on the webpage, while the disclaimer was added to the bottom of the webpage, was not visible without scrolling down, and was well below the “Add to Cart” button.

    The Commission’s final order prohibits California Naturel from misrepresenting the ingredients or composition of its products; whether a product is “all natural” or “100% natural;” the extent to which a product contains any natural or synthetic ingredient or component; or the environmental or health benefits of such a product. It also requires the company to have competent and reliable evidence to support any of the four foregoing claims it makes about any of its products.

    The final order and accompanying opinion resulted from an administrative complaint issued against California Naturel in April 2016. FTC staff trying the case requested the summary decision.

    The Commission vote approving the Commission Opinion and Final Order was 3-0, with Commissioner Maureen Ohlhausen dissenting in part and issuing a separate statement. In her statement, Commissioner Ohlhausen agrees that California Naturel’s unqualified “all natural” claims were false and misleading in violation of Sections 5 and 12 at the time they were made, but disagrees with the Commission’s grant of summary decision regarding the effect of California Naturel’s later-added disclaimers because in her view, that issue was not properly before the Commission.

    The company may file a petition for review of the Commission Opinion and Final Order with a United States Court of Appeals within 60 days of when the Order is served.

    Marketers of Blood-Pressure App Settle FTC Charges Regarding Accuracy of App Readings

    Monday, December 12th, 2016

    The marketers of a mobile app designed to measure blood pressure have agreed to settle Federal Trade Commission charges that they deceived consumers with claims that their Instant Blood Pressure (IBP) app was as accurate as a traditional blood pressure cuff. In addition, the Commission alleged that the owner provided a positive review of the app, rating it “five stars” in the app stores, without disclosing his connection to the company.

    Under the terms of the FTC settlement, Aura Labs, Inc., doing business as AuraLife and AuraWare, and its founder and co-owner, Ryan Archdeacon, are barred from making such unsupported claims in the future and must disclose any material connections between Aura and people who endorse its products.

    “For someone with high blood pressure who relies on accurate readings, this deception can actually be hazardous,” said Jessica Rich, director of the FTC’s Bureau of Consumer Protection. “While the Commission encourages the development of new technologies, health-related claims should not go beyond the scientific evidence available to support them.”

    According to the FTC’s complaint, Aura sold the IBP app through Google Play and Apple’s App Store for between $3.99 and $4.99. Between June 2014 and June 2015, sales of the app totaled more than $600,000, according to the agency. In marketing the app, Aura and Archdeacon claimed that it could be used to replace around-the-arm cuffs and would be just as accurate as the traditional device, the FTC charged.

    In reality, however, blood pressure readings reported by the IBP app were significantly less accurate than those taken with a traditional blood pressure cuff. To use the company’s IBP app, users put their right index finger over the phone’s rear camera lens and held the base of the phone over their heart. The Commission charged defendants with violating the FTC Act.

    The stipulated federal court order prohibits the defendants from making the deceptive claims alleged in the complaint. It also prohibits them from making any claims about the health benefits of any product or device without the scientific evidence to support the claims. It imposes a judgment of $595,945.27, which is suspended based on the defendants’ inability to pay. The full amount will become due, however, it they are later found to have misrepresented their financial condition.

    The Commission vote authorizing the staff to file the complaint and stipulated order was 3-0. The FTC filed the complaint and order in the U.S. District Court for the Central District of California, and the order has now been signed by the judge.

    NOTE: The Commission files a complaint when it has “reason to believe” that the law has been or is being violated and it appears to the Commission that a proceeding is in the public interest. Stipulated final orders have the force of law when approved and signed by the District Court judge.

    FDA takes action against four tobacco manufacturers for illegal sales of flavored cigarettes labeled as little cigars or cigars

    Saturday, December 10th, 2016

    FDA News Release

    FDA takes action against four tobacco manufacturers for illegal sales of flavored cigarettes labeled as little cigars or cigars

    December 9, 2016

    The U.S. Food and Drug Administration today issued warning letters to four tobacco manufacturers — Swisher International Inc., Cheyenne International LLC, Prime Time International Co. and Southern Cross Tobacco Company Inc. — for selling flavored cigarettes that are labeled as little cigars or cigars, which is a violation of the Family Smoking Prevention and Tobacco Control Act. The companies received warning letters for products under the “Swisher Sweets,” Cheyenne,” “Prime Time” and “Criss-Cross” brands in a variety of youth-appealing flavors, including grape, cherry, wild cherry and strawberry.

    “Flavored cigarettes appeal to kids and disguise the bad taste of tobacco, but they are just as addictive as regular tobacco products and have the same harmful health effects,” said Mitch Zeller, J.D., director of the FDA’s Center for Tobacco Products. “Because about 90 percent of adult daily smokers smoked their first cigarette by the age of 18, continued enforcement of the ban on cigarettes with characterizing flavors is vital to protect future generations from a lifetime of addiction.”

    The Tobacco Control Act, which was passed by Congress and signed by the President in 2009, banned cigarettes containing certain characterizing flavors, such as candy or fruit flavors, to reduce the number of youth who start to smoke and who become addicted to dangerous tobacco products. The FDA began enforcing that provision in September 2009.

    The agency has determined that, although labeled as little cigars or cigars, the products meet the definition of cigarettes in the Tobacco Control Act, because they are likely to be offered to, or purchased by, consumers as cigarettes based on their overall presentation, appearance, and packaging and labeling. Additionally, since the products meet the definition of a cigarette, the FDA determined that the products are adulterated because they contain a natural or artificial characterizing flavor, or misbranded if they only purport to do so.

    The FDA has requested the manufacturers respond to the warning letters within 15 working days of receiving the letter. Failure to obey federal tobacco law may result in the FDA initiating further action, including, but not limited to, civil money penalties, criminal prosecution, seizure, and/or injunction. The agency expects many of these products to remain available for purchase by consumers at retail establishments while the FDA works with the manufacturers to ensure the products are in compliance with the requirements of the law.

     

    Federal Trade Commission warning re tenant screening — intended for landlords, but tenants should read

    Monday, November 28th, 2016

    Screening tenants? Check out the FTC’s new guidance

    Using background checks to screen tenants? Or maybe your company provides those background checks to landlords? Make sure you’re complying with the Fair Credit Reporting Act (FCRA). The FTC’s new guidance for landlords and for tenant background screening companies can help.

    What do landlords need to know?

    Landlords must take certain steps before getting a consumer report and after taking an adverse action based on the report. A consumer report can include a credit report, a rental history report or a criminal history report. Landlords can only get consumer reports if they have a “permissible purpose,” like tenant screening. Before you get a consumer report, you must certify to the company providing the report that you’ll use the report only for housing purposes.

    If you, as a landlord, take an adverse action against a tenant or rental applicant, then you must give notice – orally, in writing or electronically. An adverse action could include denying a lease, requiring a co-signor, or requiring higher rent than for another applicant. The FTC’s guidance has more examples of when an adverse action notice is required. When you send an adverse action notice, it must include the contact information for the company who supplied the report and an explanation of the right to dispute the report.

    What should tenant background screening companies keep in mind?

    Even if you don’t think of your company as a consumer reporting agency, it may be one if it provides information about people to landlords for use in housing decisions. Background screening reports provided by your company are covered by the FCRA if they’re used to help decide eligibility for housing and include information “bearing on a consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living.”

    If your tenant background screening company is covered by the FCRA, then you have four main requirements:

    • Follow reasonable procedures to ensure accuracy.
    • Get certifications from your clients.
    • Provide your clients with information about the FCRA.
    • Honor the rights of applicants and tenants.

    The new guidance includes details about each of these requirements, as well as a handy chart of key FCRA provisions.

    Whether you’re a landlord or a screening company, when you’re done using a consumer report, you must securely dispose of it. For more information, read Disposing of Consumer Report Information? Rule Tells How.

    Share these resources – and the FTC’s Credit Reporting and Human Resources portals – with others in your company.

     

    Federal Communications Commission warning re robotexts

    Friday, November 25th, 2016

    ROBOTEXT CONSUMER PROTECTION

     

    TEXT MESSAGE SENDERS MUST COMPLY WITH

    THE TELEPHONE CONSUMER PROTECTION ACT

    The FCC’s Enforcement Bureau issues this Advisory to promote understanding of the clear limits on the use of autodialed text messages, known as “robotexts.”  The FCC is committed to protecting consumers from harassing, intrusive, illegal, and unwanted robotexts to cell phones and other mobile devices.

    The FCC has stated that the restrictions on making autodialed calls to cell phones encompass both voice calls and texts.[1]  Accordingly, text messages sent to cell phones using any automatic telephone dialing system are subject to the Telephone Consumer Protection Act of 1991 (“TCPA”).[2]  The term “automatic telephone dialing system” (or “autodialer”) covers any equipment that has the capacity to store or produce numbers to be dialed and dial them without human intervention but does not need to have the present ability to do so.[3]

    The TCPA places limits on autodialed calls and prerecorded- or artificial-voice[4] calls to wireless numbers; emergency numbers; guest or patient rooms at hospitals, health care facilities, elderly homes, or similar establishments; and to any service for which the called party is charged for the call.[5]  The FCC’s corresponding rules[6] restrict the use of prerecorded-voice calls and automatic telephone dialing systems, including those that deliver robotexts.[7]  The FCC’s Enforcement Bureau will rigorously enforce the important consumer protections in the TCPA and our corresponding rules.  We expect this Advisory will facilitate compliance with the law and rules by those who initiate robotexts to mobile devices.

    Restrictions on Robotexts.  The TCPA prohibits autodialed calls or text messages, as well as prerecorded calls, unless made with the prior express consent of the called party, to any telephone number assigned to a cell phone or other mobile device (such as a pager), unless the calls or text messages are:  (1) made for emergency purposes; (2) free to the end user and have been exempted by the Commission, subject to conditions prescribed to protect consumer privacy rights; or (3) made solely to collect debts “owed to or guaranteed by the United States.”[8]

    Consumer Consent.  Those contending that they have prior express consent to make robotexts to mobile devices have the burden of proving that they obtained such consent.[9]  This includes text messages from text messaging apps and Internet-to-phone text messaging where the technology meets the statutory definition of an autodialer.[10]  The fact that a consumer’s wireless number is in the contact list of another person’s wireless phone does not, by itself, demonstrate consent to receive robotexts.[11]  Further, recipients may revoke their consent at any time using any reasonable method.[12]  When a recipient of an autodialed text has revoked consent to receive future robotexts, the text sender may immediately send one final autodialed text to confirm the recipient’s opt-out request.[13]

    Advertising Robotexts.  Prior express written consent is required for autodialed texts that include or introduce an advertisement except in certain limited circumstances.[14]  Even if a person has provided such consent, however, his or her later opt-out request requires the sender to stop sending text advertisements.[15]

    Robotexts to Reassigned Wireless Numbers.  The Commission has determined that when a caller reasonably relies on prior express consent to robocall or robotext a wireless number and does not discover that the number has been reassigned to another party prior to making the call or text, the caller is not liable for the first call or text going to the called party who did not provide consent.[16]  They are, however, liable for any continued calls or text messages to a reassigned number after the initial call or text, regardless of whether or when they learn of the reassignment.[17]

    Enforcement.  Robotext violations are subject to enforcement by the FCC, including forfeiture penalties up to $18,936 per violation,[18] and state enforcement agencies.

    Need More Information?  Media inquiries should be directed to Will Wiquist at (202) 418-0509 or will.wiquist@fcc.gov. Information about the Telephone Consumer Protection Act is available here: https://www.fcc.gov/general/telemarketing-and-robocalls.  For general information on the FCC, you can contact the FCC at 1-888-CALL-FCC (1-888-225-5322) or visit our website at www.fcc.gov.

    Consumer complaints.  To file a complaint with the FCC about a robotext, visit consumercomplaints.fcc.gov or call (888) CALL-FCC.    

    To request materials in accessible formats for people with disabilities (Braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY).

    Issued by: Chief, Enforcement Bureau

    [1] Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Report and Order, 18 FCC Rcd 14014, 14115, para. 165 (2003).

    [2] Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Declaratory Ruling and Order, 30 FCC Rcd 7961, 7978, 8017, paras. 24, 111-15 (2015) (TCPA Omnibus Declaratory Ruling and Order), pets. for review pending sub nom. ACA Int’l v. FCC, No. 15-1211 (D.C. Cir. filed July 10, 2015).  Just as texts are a subset of “calls” under the TCPA, “robotexts” are a subset of “robocalls.”  See id. at 7964, para. 1 & n.1.

    [3] TCPA Omnibus Declaratory Ruling and Order, 30 FCC Rcd at 7973-74, 7975-76, paras. 14-15, 19.  A robotext platform may be deemed to have initiated the text for purposes of liability under the TCPA in certain circumstances.  Id. at 7980-81, para. 30 & n.110.

    [4] We refer to prerecorded- or artificial-voice calls together as “prerecorded” calls.

    [5] 47 U.S.C. § 227(b)(1)(A).  The TCPA also places limits on unsolicited prerecorded telemarketing calls to residential telephones.  See 47 U.S.C. § 227(b)(1)(B).

    [6] See 47 CFR § 64.1200.

    [7] By this Enforcement Advisory, the FCC’s Enforcement Bureau highlights certain obligations under the TCPA and corresponding Commission rules.  Failure to receive this notice does not absolve an entity of the obligation to meet the requirements of the Communications Act of 1934, as amended, or the Commission’s rules and orders.  Companies, individuals, and other entities should read the full text of the relevant portions of the TCPA and corresponding Commission rules, respectively, at 47 U.S.C. § 227 and 47 CFR § 64.1200, as well as FCC orders interpreting and/or applying those provisions.

    [8] See 47 U.S.C. § 227(b)(1)(A)(iii); see also 47 CFR § 64.1200(a)(1)(iii) (prohibiting such calls to “any telephone number assigned to a paging service, cellular telephone service, specialized mobile radio service, or other radio common carrier service, or any service which the called party is charged for the call”). Congress has amended Section 227 to except federal debt collection calls and the Commission recently implemented rules related to that exception.  Rules and Regulations Implementing the Telephone Consumers Protection Act of 1991, Report and Order, FCC 16-99 (Aug. 11, 2016), 2016 WL 4250379.

    [9] TCPA Omnibus Declaratory Ruling and Order, 30 FCC Rcd at 7990, para. 47; see also Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Request of ACA International for Clarification and Declaratory Ruling, Declaratory Ruling, 23 FCC Rcd 559, 565, para. 10 (2008) (concluding that creditors and debt collectors claiming prior express consent to make prerecorded-voice or autodialed calls to cell phones are responsible for demonstrating such consent was obtained).

    [10] TCPA Omnibus Declaratory Ruling and Order, 30 FCC Rcd at 8020, paras. 115-16 (consumer consent required for autodialed Internet-to-phone text messages and for text messages sent from apps “that enable entities to send text messages to all or substantially all text-capable U.S. telephone numbers, including through the use of autodialer applications downloaded or otherwise installed on mobile phones”).

    [11] Id. at 7989, para. 47.

    [12] Id. at 7996, paras. 55-70.  The prior express consent requirement is subject to limited exemptions granted by the Commission for specific types of calls; all exempted of these types must result in no charge to the called party and must satisfy specified conditions.  See id. at 8027-28, para 138 (financial alerts); id. at 7986, para. 40 (collect calling agencies setting up a billing relationship); id. at 8031-32 paras. 147-48 (certain healthcare messages); see also Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Cargo Airline Association Petition for Expedited Declaratory Ruling, Order, 29 FCC Rcd 3432, 3439, para. 21 (2014) (certain package delivery notifications).

    [13] Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, SoundBite Communications, Inc. Petition for Expedited Declaratory Ruling, Declaratory Ruling, 27 FCC Rcd 15391 (2012) (setting forth certain requirements that the one-time text must meet).

    [14] See 47 CFR § 64.1200(a)(2) (requiring prior express written consent for prerecorded and autodialed telephone calls that include or introduce an advertisement or constitute telemarketing, except that consent need not be in writing for certain health care calls and calls made by or on behalf of a tax-exempt nonprofit organization).

    [15] TCPA Omnibus Declaratory Ruling and Order, 30 FCC Rcd at 7996, para. 64.

    [16] Id. at 8006-07, para. 85 (emphasizing that the caller bears the burden of demonstrating a reasonable basis for believing that he had consent to make the call and that he did not know about the number reassignment when making the one allowable call).

    [17] Id. at 8006-07, 8009, paras. 85, 89.

    [18] Before proposing a monetary forfeiture penalty against a party that does not, or should not, hold an FCC license, permit, certificate, or other authorization, the FCC must first issue a warning citation.  47 U.S.C. § 503(b)(5).  If a party continues to violate the Communications Act or the Commission’s rules after receiving a citation, the FCC may impose a monetary forfeiture penalty covering both violations that occur after the citation and those violations that were addressed in the citation.  See S. Rep. No. 95-580, 95th Cong., 1st Sess. at 9 (1977), reprinted in 1978 U.S.C.C.A.N. 109 (If a person or entity that has been issued a citation by the Commission thereafter engages in the conduct for which the citation of violation was sent, the subsequent notice of apparent liability “would attach not only for the conduct occurring subsequently but also for the conduct for which the citation was originally sent.”) (emphasis added).

    Great Lakes Credit Union

    Wednesday, November 23rd, 2016

    We are interested in locating persons who purchased cars on time from a car dealer and whose contracts were assigned to Great Lakes Credit Union, when the purchaser was not previously a member of the Credit Union.

    Northwest Collectors

    Tuesday, November 22nd, 2016

    Please contact us if Northwest Collectors, Inc. is trying to collect money from you.