Nissan North America, Inc. and TBWA Worldwide, Inc.; Analyses of Proposed Consent Orders To Aid Public Comment, 4711-4713 [2014-01748]
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Federal Register / Vol. 79, No. 19 / Wednesday, January 29, 2014 / Notices
FEDERAL TRADE COMMISSION
[File No. 122–3010]
Nissan North America, Inc. and TBWA
Worldwide, Inc.; Analyses of Proposed
Consent Orders To Aid Public
Comment
Federal Trade Commission.
Proposed consent agreements.
AGENCY:
ACTION:
The consent agreements in
these matters settle alleged violations of
federal law prohibiting unfair or
deceptive acts or practices. The attached
Analyses of Proposed Consent Orders to
Aid Public Comment describe both the
allegations in the draft complaints and
the terms of the consent orders—
embodied in the consent agreements—
that would settle these allegations.
DATES: Comments must be received on
or before February 24, 2014.
ADDRESSES: Interested parties may file
comments at https://
ftcpublic.commentworks.com/ftc/
nissannorthamericaconsent and https://
ftcpublic.commentworks.com/ftc/
tbwaconsent online or on paper, by
following the instructions in the
Request for Comments part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘Nissan North America
Consent Agreement, Inc.—Consent
Agreement; File No. 122–3010’’ or
‘‘TBWA Worldwide, Inc.—Consent
Agreement; File No. 122–3010’’ on your
comment and file your comments online
at https://ftcpublic.commentworks.com/
ftc/nissannorthamericaconsent and
https://ftcpublic.commentworks.com/
ftc/tbwaconsent https://
ftcpublic.commentworks.com/ftc/
fidelitynationalconsent by following the
instructions on the web-based forms. If
you prefer to file your comments on
paper, mail or deliver your comments to
the following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580.
FOR FURTHER INFORMATION CONTACT:
Matthew D. Gold, FTC Western Region,
(415–848–5100), 901 Market Street,
Suite 570 San Francisco, CA 94103.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreements containing consent
orders to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, have been
placed on the public record for a period
of thirty (30) days. The following
Analyses To Aid Public Comment
tkelley on DSK3SPTVN1PROD with NOTICES
SUMMARY:
VerDate Mar<15>2010
16:05 Jan 28, 2014
Jkt 232001
describe the terms of the consent
agreements, and the allegations in the
complaints. An electronic copy of the
full text of the consent agreement
packages can be obtained from the FTC
Home Page (for January 23, 2014), on
the World Wide Web, at https://
www.ftc.gov/os/actions.shtm. Paper
copies can be obtained from the FTC
Public Reference Room, Room 130–H,
600 Pennsylvania Avenue NW.,
Washington, DC 20580, either in person
or by calling (202) 326–2222.
You can file comments online or on
paper. For the Commission to consider
your comments, we must receive them
on or before February 24, 2014. Write
‘‘Nissan North America Consent
Agreement, Inc.—Consent Agreement;
File No. 122–3010’’ or ‘‘TBWA
Worldwide, Inc.—Consent Agreement;
File No. 122–3010’’ on your comment.
Your comment—including your name
and your state—will be placed on the
public record of this proceeding,
including, to the extent practicable, on
the public Commission Web site, at
https://www.ftc.gov/os/
publiccomments.shtm. As a matter of
discretion, the Commission tries to
remove individuals’ home contact
information from comments before
placing them on the Commission Web
site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment does
not include any sensitive health
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which . . . is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
PO 00000
Frm 00057
Fmt 4703
Sfmt 4703
4711
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
nissannorthamericaconsent and https://
ftcpublic.commentworks.com/ftc/
tbwaconsent by following the
instructions on the web-based forms. If
this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘Nissan North America Consent
Agreement, Inc.—Consent Agreement;
File No. 122–3010’’ or ‘‘TBWA
Worldwide, Inc.—Consent Agreement;
File No. 122–3010’’ on your comment
and on the envelope, and mail or deliver
it to the following address: Federal
Trade Commission, Office of the
Secretary, Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580. If possible, submit your
paper comment to the Commission by
courier or overnight service.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before February 24, 2014. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
Analysis of Proposed Consent Order To
Aid Public Comment in the Matter of
Nissan North America, Inc.
The Federal Trade Commission
(‘‘FTC’’ or ‘‘Commission’’) has accepted,
subject to final approval, an agreement
containing consent order from Nissan
North America, Inc. (‘‘respondent’’).
The proposed consent order has been
placed on the public record for thirty
(30) days for receipt of comments by
interested persons. Comments received
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
E:\FR\FM\29JAN1.SGM
29JAN1
tkelley on DSK3SPTVN1PROD with NOTICES
4712
Federal Register / Vol. 79, No. 19 / Wednesday, January 29, 2014 / Notices
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
appropriate action or make final the
agreement’s proposed order.
This matter involves the advertising,
marketing, and sale of the Nissan
Frontier pickup truck by respondent.
Respondent has marketed the Nissan
Frontier to consumers through the ‘‘Hill
Climb’’ advertisement, which
respondent disseminated on television
and over the internet. According to the
FTC complaint, the Hill Climb
advertisement deceptively demonstrated
the capabilities of the Nissan Frontier.
Specifically, according to the FTC
complaint, the Hill Climb advertisement
depicts a Nissan Frontier pickup truck
rescuing a dune buggy that is trapped in
sand on a steep hill. The Nissan Frontier
speeds up the sand dune and stops
immediately behind the dune buggy.
The Nissan Frontier then pushes the
dune buggy up and over the top of the
hill. Onlookers are portrayed observing
the feat in amazement. A narrator
subsequently states, ‘‘The mid-size
Nissan Frontier with full-size
horsepower and torque. Innovation for
doers, innovation for all.’’ According to
the complaint, the demonstration is
portrayed in a realistic, ‘‘YouTube’’
style, as if shot with a mobile phone
video camera.
According to the complaint,
respondent represented that the Hill
Climb advertisement accurately
represents the performance of an actual,
unaltered Nissan Frontier pickup truck
under the depicted conditions. The
complaint further alleges that this claim
is false, and thus violates the FTC Act,
because the Nissan Frontier pickup
truck is incapable of performing the feat
depicted in the Hill Climb
advertisement. In truth, according to the
complaint, both the Nissan Frontier
pickup truck and the dune buggy were
dragged to the top of the hill by cables,
and the sand dune was made to appear
to be significantly steeper than it
actually was.
The proposed consent order contains
provisions designed to prevent
respondent from engaging in similar
acts or practices in the future.
Specifically, Part I prohibits respondent
from misrepresenting, in the context of
the advertisement as a whole, any
material quality or feature of any
Nissan-branded pickup truck through
the depiction of a test, experiment, or
demonstration. Part I specifies that
nothing in the order shall be deemed to
preclude the use of any production
VerDate Mar<15>2010
16:05 Jan 28, 2014
Jkt 232001
techniques that do not misrepresent a
material quality or feature of the
advertised truck.
Part II of the proposed order requires
respondent to maintain, and make
available to the Commission upon
written request, copies of relevant
advertisements, as well as any and all
unedited video and still images taken
during the production of any
advertisement depicting a
demonstration, experiment, or test.
Under Part II, respondent must also
maintain any and all affidavits or
certifications submitted by an employee,
agent, or representative to any television
network or other individual, where such
affidavit or certification affirms the
accuracy or integrity of a demonstration
contained in an advertisement.
Parts III, IV, and V of the proposed
order require respondent to provide
copies of the order to its personnel; to
notify the Commission of changes in
corporate structure that might affect
compliance obligations under the order;
and to file compliance reports with the
Commission. Part VI provides that the
order will terminate after twenty (20)
years, with certain exceptions.
The purpose of this analysis is to
facilitate public comment on the
proposed order. It is not intended to
constitute an official interpretation of
the proposed order or to modify its
terms in any way.
Analysis of Proposed Consent Order To
Aid Public Comment in the Matter of
TBWA Worldwide, Inc.
The Federal Trade Commission
(‘‘FTC’’ or ‘‘Commission’’) has accepted,
subject to final approval, an agreement
containing consent order from TBWA
Worldwide, Inc. (‘‘respondent’’).
The proposed consent order has been
placed on the public record for thirty
(30) days for receipt 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
appropriate action or make final the
agreement’s proposed order.
This matter involves the advertising
and marketing of the Nissan Frontier
pickup truck by respondent.
Respondent is an advertising agency of
Nissan North America, Inc., and
prepared and disseminated the ‘‘Hill
Climb’’ advertisement, which promoted
the Nissan Frontier pickup truck.
According to the FTC complaint, the
Hill Climb advertisement, which
appeared on television and over the
PO 00000
Frm 00058
Fmt 4703
Sfmt 4703
Internet, deceptively demonstrated the
capabilities of the Nissan Frontier.
Specifically, according to the FTC
complaint, the Hill Climb advertisement
depicts a Nissan Frontier pickup truck
rescuing a dune buggy that is trapped in
sand on a steep hill. The Nissan Frontier
speeds up the sand dune and stops
immediately behind the dune buggy.
The Nissan Frontier then pushes the
dune buggy up and over the top of the
hill. Onlookers are portrayed observing
the feat in amazement. A narrator
subsequently states, ‘‘The mid-size
Nissan Frontier with full-size
horsepower and torque. Innovation for
doers, innovation for all.’’ According to
the complaint, the demonstration is
portrayed in a realistic, ‘‘YouTube’’
style, as if shot with a mobile phone
video camera.
According to the complaint,
respondent represented that the Hill
Climb advertisement accurately
represents the performance of an actual,
unaltered Nissan Frontier pickup truck
under the depicted conditions. The
complaint further alleges that this claim
is false, and thus violates the FTC Act,
because the Nissan Frontier pickup
truck is incapable of performing the feat
depicted in the Hill Climb
advertisement. The complaint further
alleges that respondent knew or should
have known that the claim is false. In
truth, according to the complaint, both
the Nissan Frontier pickup truck and
the dune buggy were dragged to the top
of the hill by cables, and the sand dune
was made to appear to be significantly
steeper than it actually was.
The Hill Climb advertisement was
created by TBWA Chiat/Day Los
Angeles, a division of TBWA
Worldwide, Inc. Because TBWA Chiat/
Day Los Angeles is not a formal
corporate entity, the Commission’s
order names TBWA Worldwide, Inc., as
respondent. Via the order’s definition of
‘‘respondent,’’ however, the injunctive
provisions of the order apply only to
TBWA Chiat/Day Los Angeles and to its
sister agency, TBWA Chiat/Day New
York.
The proposed consent order contains
provisions designed to prevent
respondent from engaging in similar
acts or practices in the future.
Specifically, Part I prohibits respondent
from misrepresenting, in the context of
the advertisement as a whole, any
material quality or feature of any pickup
truck through the depiction of a test,
experiment, or demonstration. Part I
specifies that nothing in the order shall
be deemed to preclude the use of any
production techniques that do not
misrepresent a material quality or
feature of the advertised truck.
E:\FR\FM\29JAN1.SGM
29JAN1
Federal Register / Vol. 79, No. 19 / Wednesday, January 29, 2014 / Notices
Consistent with prior FTC cases
involving advertising agencies, Part I
also declares that respondent can be
held liable for violating Part I of the
order only if it knew or should have
known that the test, experiment, or
demonstration misrepresented a
material quality or feature of the
advertised truck.
Part II of the proposed order requires
respondent to maintain, and make
available to the Commission upon
written request, copies of relevant
advertisements, as well as any and all
unedited video and still images taken
during the production of any
advertisement depicting a
demonstration, experiment, or test.
Under Part II, respondent must also
maintain any and all affidavits or
certifications submitted by an employee,
agent, or representative to any television
network or other individual, where such
affidavit or certification affirms the
accuracy or integrity of a demonstration
contained in an advertisement.
Part III of the proposed order requires
respondent to provide copies of the
order to certain of its personnel. Parts IV
and V of the proposed order require
TBWA Worldwide, Inc., to notify the
Commission of changes in corporate
structure that might affect compliance
obligations under the order; and to file
compliance reports with the
Commission. Part VI provides that the
order will terminate after twenty (20)
years, with certain exceptions.
The purpose of this analysis is to
facilitate public comment on the
proposed order. It is not intended to
constitute an official interpretation of
the proposed order or to modify its
terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2014–01748 Filed 1–28–14; 8:45 am]
BILLING CODE 6750–01–P
FEDERAL TRADE COMMISSION
[File No. 142–3030]
Reynolds Consumer Products Inc.;
Analysis of Proposed Consent Order
To Aid Public Comment
Federal Trade Commission.
Proposed consent agreement.
AGENCY:
tkelley on DSK3SPTVN1PROD with NOTICES
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair or
deceptive acts or practices. The attached
Analysis of Proposed Consent Order To
Aid Public Comment describes both the
allegations in the draft complaint and
SUMMARY:
VerDate Mar<15>2010
16:05 Jan 28, 2014
Jkt 232001
the terms of the consent order—
embodied in the consent agreement—
that would settle these allegations.
DATES: Comments must be received on
or before February 20, 2014.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
reynoldsfoilconsent online or on paper,
by following the instructions in the
Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘Reynolds Consumer
Products, Inc.—Consent Agreement; File
No. 142–3030’’ on your comment and
file your comment online at https://
ftcpublic.commentworks.com/ftc/
reynoldsfoilconsent https://
ftcpublic.commentworks.com/ftc/
fidelitynationalconsent by following the
instructions on the web-based form. If
you prefer to file your comment on
paper, mail or deliver your comment to
the following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580.
FOR FURTHER INFORMATION CONTACT:
Jessica Lyon, Bureau of Consumer
Protection, (202–326–2344), 600
Pennsylvania Avenue NW, Washington,
DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis To Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for January 21, 2014), on
the World Wide Web, at https://
www.ftc.gov/os/actions.shtm. A paper
copy can be obtained from the FTC
Public Reference Room, Room 130–H,
600 Pennsylvania Avenue NW.,
Washington, DC 20580, either in person
or by calling (202) 326–2222.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before February 20, 2014. Write
‘‘Reynolds Consumer Products, Inc.—
Consent Agreement; File No. 142–3030’’
on your comment. Your comment—
including your name and your state—
will be placed on the public record of
this proceeding, including, to the extent
PO 00000
Frm 00059
Fmt 4703
Sfmt 4703
4713
practicable, on the public Commission
Web site, at https://www.ftc.gov/os/
publiccomments.shtm. As a matter of
discretion, the Commission tries to
remove individuals’ home contact
information from comments before
placing them on the Commission Web
site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment does
not include any sensitive health
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which . . . is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
reynoldsfoilconsent by following the
instructions on the web-based form. If
this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘Reynolds Consumer Products,
Inc.—Consent Agreement; File No. 142–
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
E:\FR\FM\29JAN1.SGM
29JAN1
Agencies
[Federal Register Volume 79, Number 19 (Wednesday, January 29, 2014)]
[Notices]
[Pages 4711-4713]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-01748]
[[Page 4711]]
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 122-3010]
Nissan North America, Inc. and TBWA Worldwide, Inc.; Analyses of
Proposed Consent Orders To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreements.
-----------------------------------------------------------------------
SUMMARY: The consent agreements in these matters settle alleged
violations of federal law prohibiting unfair or deceptive acts or
practices. The attached Analyses of Proposed Consent Orders to Aid
Public Comment describe both the allegations in the draft complaints
and the terms of the consent orders--embodied in the consent
agreements--that would settle these allegations.
DATES: Comments must be received on or before February 24, 2014.
ADDRESSES: Interested parties may file comments at https://ftcpublic.commentworks.com/ftc/nissannorthamericaconsent and https://ftcpublic.commentworks.com/ftc/tbwaconsent online or on paper, by
following the instructions in the Request for Comments part of the
SUPPLEMENTARY INFORMATION section below. Write ``Nissan North America
Consent Agreement, Inc.--Consent Agreement; File No. 122-3010'' or
``TBWA Worldwide, Inc.--Consent Agreement; File No. 122-3010'' on your
comment and file your comments online at https://ftcpublic.commentworks.com/ftc/nissannorthamericaconsent and https://ftcpublic.commentworks.com/ftc/tbwaconsent https://ftcpublic.commentworks.com/ftc/fidelitynationalconsent by following the
instructions on the web-based forms. If you prefer to file your
comments on paper, mail or deliver your comments to the following
address: Federal Trade Commission, Office of the Secretary, Room H-113
(Annex D), 600 Pennsylvania Avenue NW., Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Matthew D. Gold, FTC Western Region,
(415-848-5100), 901 Market Street, Suite 570 San Francisco, CA 94103.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreements
containing consent orders to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, have been
placed on the public record for a period of thirty (30) days. The
following Analyses To Aid Public Comment describe the terms of the
consent agreements, and the allegations in the complaints. An
electronic copy of the full text of the consent agreement packages can
be obtained from the FTC Home Page (for January 23, 2014), on the World
Wide Web, at https://www.ftc.gov/os/actions.shtm. Paper copies can be
obtained from the FTC Public Reference Room, Room 130-H, 600
Pennsylvania Avenue NW., Washington, DC 20580, either in person or by
calling (202) 326-2222.
You can file comments online or on paper. For the Commission to
consider your comments, we must receive them on or before February 24,
2014. Write ``Nissan North America Consent Agreement, Inc.--Consent
Agreement; File No. 122-3010'' or ``TBWA Worldwide, Inc.--Consent
Agreement; File No. 122-3010'' on your comment. Your comment--including
your name and your state--will be placed on the public record of this
proceeding, including, to the extent practicable, on the public
Commission Web site, at https://www.ftc.gov/os/publiccomments.shtm. As a
matter of discretion, the Commission tries to remove individuals' home
contact information from comments before placing them on the Commission
Web site.
Because your comment will be made public, you are solely
responsible for making sure that your comment does not include any
sensitive personal information, like anyone's Social Security number,
date of birth, driver's license number or other state identification
number or foreign country equivalent, passport number, financial
account number, or credit or debit card number. You are also solely
responsible for making sure that your comment does not include any
sensitive health information, like medical records or other
individually identifiable health information. In addition, do not
include any ``[t]rade secret or any commercial or financial information
which . . . is privileged or confidential,'' as discussed in Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
---------------------------------------------------------------------------
\1\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
---------------------------------------------------------------------------
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/nissannorthamericaconsent and https://ftcpublic.commentworks.com/ftc/tbwaconsent by following the instructions on the web-based forms.
If this Notice appears at https://www.regulations.gov/#!home, you also
may file a comment through that Web site.
If you file your comment on paper, write ``Nissan North America
Consent Agreement, Inc.--Consent Agreement; File No. 122-3010'' or
``TBWA Worldwide, Inc.--Consent Agreement; File No. 122-3010'' on your
comment and on the envelope, and mail or deliver it to the following
address: Federal Trade Commission, Office of the Secretary, Room H-113
(Annex D), 600 Pennsylvania Avenue NW., Washington, DC 20580. If
possible, submit your paper comment to the Commission by courier or
overnight service.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before February 24, 2014. You can find more
information, including routine uses permitted by the Privacy Act, in
the Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
Analysis of Proposed Consent Order To Aid Public Comment in the Matter
of Nissan North America, Inc.
The Federal Trade Commission (``FTC'' or ``Commission'') has
accepted, subject to final approval, an agreement containing consent
order from Nissan North America, Inc. (``respondent'').
The proposed consent order has been placed on the public record for
thirty (30) days for receipt of comments by interested persons.
Comments received
[[Page 4712]]
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 appropriate action or make final the agreement's
proposed order.
This matter involves the advertising, marketing, and sale of the
Nissan Frontier pickup truck by respondent. Respondent has marketed the
Nissan Frontier to consumers through the ``Hill Climb'' advertisement,
which respondent disseminated on television and over the internet.
According to the FTC complaint, the Hill Climb advertisement
deceptively demonstrated the capabilities of the Nissan Frontier.
Specifically, according to the FTC complaint, the Hill Climb
advertisement depicts a Nissan Frontier pickup truck rescuing a dune
buggy that is trapped in sand on a steep hill. The Nissan Frontier
speeds up the sand dune and stops immediately behind the dune buggy.
The Nissan Frontier then pushes the dune buggy up and over the top of
the hill. Onlookers are portrayed observing the feat in amazement. A
narrator subsequently states, ``The mid-size Nissan Frontier with full-
size horsepower and torque. Innovation for doers, innovation for all.''
According to the complaint, the demonstration is portrayed in a
realistic, ``YouTube'' style, as if shot with a mobile phone video
camera.
According to the complaint, respondent represented that the Hill
Climb advertisement accurately represents the performance of an actual,
unaltered Nissan Frontier pickup truck under the depicted conditions.
The complaint further alleges that this claim is false, and thus
violates the FTC Act, because the Nissan Frontier pickup truck is
incapable of performing the feat depicted in the Hill Climb
advertisement. In truth, according to the complaint, both the Nissan
Frontier pickup truck and the dune buggy were dragged to the top of the
hill by cables, and the sand dune was made to appear to be
significantly steeper than it actually was.
The proposed consent order contains provisions designed to prevent
respondent from engaging in similar acts or practices in the future.
Specifically, Part I prohibits respondent from misrepresenting, in the
context of the advertisement as a whole, any material quality or
feature of any Nissan-branded pickup truck through the depiction of a
test, experiment, or demonstration. Part I specifies that nothing in
the order shall be deemed to preclude the use of any production
techniques that do not misrepresent a material quality or feature of
the advertised truck.
Part II of the proposed order requires respondent to maintain, and
make available to the Commission upon written request, copies of
relevant advertisements, as well as any and all unedited video and
still images taken during the production of any advertisement depicting
a demonstration, experiment, or test. Under Part II, respondent must
also maintain any and all affidavits or certifications submitted by an
employee, agent, or representative to any television network or other
individual, where such affidavit or certification affirms the accuracy
or integrity of a demonstration contained in an advertisement.
Parts III, IV, and V of the proposed order require respondent to
provide copies of the order to its personnel; to notify the Commission
of changes in corporate structure that might affect compliance
obligations under the order; and to file compliance reports with the
Commission. Part VI provides that the order will terminate after twenty
(20) years, with certain exceptions.
The purpose of this analysis is to facilitate public comment on the
proposed order. It is not intended to constitute an official
interpretation of the proposed order or to modify its terms in any way.
Analysis of Proposed Consent Order To Aid Public Comment in the Matter
of TBWA Worldwide, Inc.
The Federal Trade Commission (``FTC'' or ``Commission'') has
accepted, subject to final approval, an agreement containing consent
order from TBWA Worldwide, Inc. (``respondent'').
The proposed consent order has been placed on the public record for
thirty (30) days for receipt 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 appropriate action or make final
the agreement's proposed order.
This matter involves the advertising and marketing of the Nissan
Frontier pickup truck by respondent. Respondent is an advertising
agency of Nissan North America, Inc., and prepared and disseminated the
``Hill Climb'' advertisement, which promoted the Nissan Frontier pickup
truck. According to the FTC complaint, the Hill Climb advertisement,
which appeared on television and over the Internet, deceptively
demonstrated the capabilities of the Nissan Frontier.
Specifically, according to the FTC complaint, the Hill Climb
advertisement depicts a Nissan Frontier pickup truck rescuing a dune
buggy that is trapped in sand on a steep hill. The Nissan Frontier
speeds up the sand dune and stops immediately behind the dune buggy.
The Nissan Frontier then pushes the dune buggy up and over the top of
the hill. Onlookers are portrayed observing the feat in amazement. A
narrator subsequently states, ``The mid-size Nissan Frontier with full-
size horsepower and torque. Innovation for doers, innovation for all.''
According to the complaint, the demonstration is portrayed in a
realistic, ``YouTube'' style, as if shot with a mobile phone video
camera.
According to the complaint, respondent represented that the Hill
Climb advertisement accurately represents the performance of an actual,
unaltered Nissan Frontier pickup truck under the depicted conditions.
The complaint further alleges that this claim is false, and thus
violates the FTC Act, because the Nissan Frontier pickup truck is
incapable of performing the feat depicted in the Hill Climb
advertisement. The complaint further alleges that respondent knew or
should have known that the claim is false. In truth, according to the
complaint, both the Nissan Frontier pickup truck and the dune buggy
were dragged to the top of the hill by cables, and the sand dune was
made to appear to be significantly steeper than it actually was.
The Hill Climb advertisement was created by TBWA Chiat/Day Los
Angeles, a division of TBWA Worldwide, Inc. Because TBWA Chiat/Day Los
Angeles is not a formal corporate entity, the Commission's order names
TBWA Worldwide, Inc., as respondent. Via the order's definition of
``respondent,'' however, the injunctive provisions of the order apply
only to TBWA Chiat/Day Los Angeles and to its sister agency, TBWA
Chiat/Day New York.
The proposed consent order contains provisions designed to prevent
respondent from engaging in similar acts or practices in the future.
Specifically, Part I prohibits respondent from misrepresenting, in the
context of the advertisement as a whole, any material quality or
feature of any pickup truck through the depiction of a test,
experiment, or demonstration. Part I specifies that nothing in the
order shall be deemed to preclude the use of any production techniques
that do not misrepresent a material quality or feature of the
advertised truck.
[[Page 4713]]
Consistent with prior FTC cases involving advertising agencies, Part I
also declares that respondent can be held liable for violating Part I
of the order only if it knew or should have known that the test,
experiment, or demonstration misrepresented a material quality or
feature of the advertised truck.
Part II of the proposed order requires respondent to maintain, and
make available to the Commission upon written request, copies of
relevant advertisements, as well as any and all unedited video and
still images taken during the production of any advertisement depicting
a demonstration, experiment, or test. Under Part II, respondent must
also maintain any and all affidavits or certifications submitted by an
employee, agent, or representative to any television network or other
individual, where such affidavit or certification affirms the accuracy
or integrity of a demonstration contained in an advertisement.
Part III of the proposed order requires respondent to provide
copies of the order to certain of its personnel. Parts IV and V of the
proposed order require TBWA Worldwide, Inc., to notify the Commission
of changes in corporate structure that might affect compliance
obligations under the order; and to file compliance reports with the
Commission. Part VI provides that the order will terminate after twenty
(20) years, with certain exceptions.
The purpose of this analysis is to facilitate public comment on the
proposed order. It is not intended to constitute an official
interpretation of the proposed order or to modify its terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2014-01748 Filed 1-28-14; 8:45 am]
BILLING CODE 6750-01-P