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© 2002 Brian F. Schreurs
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The Federal Trade Commission, having reason to believe that Dura Lube Corporation, American Direct Marketing, Inc., Howe Laboratories, Inc., Crescent Manufacturing, Inc., The Media Group, Inc., and National Communications Corporation, corporations; Herman S. Howard, individually and as an officer and director of the corporations; and Scott Howard, individually and as an officer and director of the corporations hereinafter sometimes referred to as "respondents"), have 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 Dura Lube Corporation (“DLC”) is a New York corporation with its principal office or place of business at 102-3 Hamilton Avenue, Stamford, Connecticut 06902. DLC coordinates the activities of the other corporate respondents herein, which include the manufacture, promotion and sale of Super Dura Lube Engine Treatment and Advanced Dura Lube Engine Treatment (“Dura Lube”), both purported automobile engine treatment products.

2. Respondent American Direct Marketing, Inc. (“ADM”) is a Delaware corporation with its office and principal place of business located at 300 McCann Street, Nashville, Tennessee 37210. ADM is responsible for the direct marketing of Dura Lube. 3. Respondent Howe Laboratories, Inc. (“Howe”) is a Delaware Corporation with its office and principal place of business located at 102-3 Hamilton Avenue, Stamford, Connecticut 06902. Howe is responsible for the distribution of Dura Lube to retailers.

4. Respondent Crescent Manufacturing, Inc. (“Crescent”) is a New York corporation with its office and principal place of business located at 8800 South Main Street, Eden, New York 14057. Crescent manufactures and packages Dura Lube.

5. Respondent The Media Group, Inc. (“Media Group”) is a New York corporation with its office and principal place of business located at 102-3 Hamilton Avenue, Stamford, Connecticut 06902. Media Group provides advertising services for Dura Lube.

6. National Communications Corporation ("National") is a Delaware corporation with its office and principal place of business located at 102-3 Hamilton Avenue, Stamford, Connecticut 06903. National provides advertising services for Dura Lube.

7. Respondent Herman S. Howard is or was at relevant times herein an officer of the corporate respondents. Individually or in concert with others, he has formulated, directed, or controlled the acts and practices of the corporate respondents, including the acts or practices alleged in this complaint. His principal office or place of business is the same as that of DLC.

8. Respondent Scott Howard is or was at relevant times herein an officer of the corporate respondents. Individually or in concert with others, he has formulated, directed, or controlled the acts and practices of the corporate respondents, including the acts or practices alleged in this complaint. His principal office or place of business is the same as that of DLC.

9. The aforementioned respondents cooperated and acted together in carrying out the acts and practices hereinafter set forth.

10. Respondents have manufactured, advertised, promoted, labeled, offered for sale, sold, and distributed to the public various aftermarket motor oil additives (sometimes referred to as engine treatments) known by the product name Super Dura Lube Engine Treatment and Dura Lube Advanced Engine Treatment. These products consist of chlorinated paraffin and other chemicals suspended in motor oil.

11. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.

12. Respondents have disseminated or have caused to be disseminated advertisements and labeling for Dura Lube, including but not necessarily limited to the attached Exhibits A through E. These advertisements contain the following statements, demonstrations, and other depictions:

A. A program-length television advertisement for Dura Lube-branded products (Exhibit A):

(1) Host: ...thousands of testimonials in writing...from people all across the country stat[e] how great Dura Lube really is. For instance, Minnesota. Newspaper man Gerald Snyder boosts his mileage and avoids a hundred dollar transmission repair by treating his car with Dura Lube. Los Angeles. Johnny Ishibashi’s ‘68 Pontiac had flunked California’s tough emissions test. But after just one bottle of Dura Lube, it passed with flying colors.... (Exhibit A, p. 2)

(2) Video: Mechanics manipulating remote controls of running automobile engine.
Host: We added Dura Lube to the oil of a huge race car engine and then drained all the oil out including the Dura Lube. Dura Lube works even if all your oil is gone.... Should the engine have seized already? Under normal circumstances. Severe engine damage would have happened by now.... Then, with no oil pressure we started revving that 500 horsepower engine up under full load. Got any load yet?
Mechanic: Oh, we’ve got a lot of load, Jim. Up to 120 horsepower, 160, 224, 254, 260, 292...
Excited Mechanic: I was ready to leave the building. I thought we were going to see the Fourth of July today and parts flying through that wall.
Mechanic: 302, 348...
Superscript: NO OIL PRESSURE!
Excited Mechanic: I was ready to run.
Mechanic: ...409, 453, 473
Second Excited Mechanic: I’m still speechless.
Mechanic: ...482, 520, 525.
Third Excited Mechanic: Oh, no. Unbelievable. I don’t believe it. Oh, my God.
Superscript: A 500 HP Dura-Lube treated race car engine just ran successfully with no oil pressure under full load and high RPM...Unrehearsed!
Host: That test left professional mechanics shaking. But even with no oil at all, even with that big torture run up, the bearings in the Dura Lube-treated engine looked as good as new, as you can see for yourself. (Exhibit A, pp. 3-4)

(3) Video: Spectators around automobile engine mounted in open field; fire engine in background.
Host: You know, Dura Lube really is a miracle, and we’re going to prove it again. We’re going to empty all the oil out. Now, you would expect that, right? Guess what we’re going to do next? We’re going to take all the water out. No oil. No coolant in the engine.... When we told the authorities what kind of test we were planning, they insisted that we have a fire truck standing by. They didn’t think any engine could withstand the kind of torture we had in mind. First, we started up a big six-cylinder engine. Then we drained out all the oil and that engine just kept humming along. No problem. But we wanted to top ourselves.... We drained that radiator dry as a bone and the engine just purred right along. All right. The oil’s gone. Water’s gone or just about gone. Why is this still running?
Superscript: Floyd Stivik–Lubrication Specialist
Floyd Stivik: Dura Lube. The quality of Dura Lube’s what’s happening, Jim. Dura Lube actually stays up there and does the lubrication for you. It doesn’t leave your engine.
Host: So it’s not treating the oil, it’s treating the metal.
Stivik: That’s exactly right. It’s treating the metal....
Host (to Spectator): Do you know anything about engines?
Spectator: No, just put oil in when the little oil light goes on.
Host: Well, you always worry that one day you’re going to come home from work and the wife tells you that she meant to tell you for the last three days the red light is on in the car. And the next thing you know, you’ve got major problems, major cost factors. With this you wouldn’t have that problem. (Exhibit A, pp. 5-8)

(4) Video: Scenes of outer space; graphic illustrations of moving parts in automobile engine.
Announcer: Introducing Dura Lube. The world’s first space age all-purpose lubricant that virtually eliminates friction like nothing on earth. In space there is no friction, but inside your engine friction drags on every moving component generating heat, wear and tear, causing poor fuel economy, more pollution, even engine breakdown.
Superscript: FRICTION CAUSES: Heat! Wear! Poor Fuel Economy! More Pollution! Engine Breakdown! Announcer: Dura Lube radically reduces friction by penetrating metal surfaces to create a nonfriction shield that gives you a more efficient engine. With Dura Lube you’ll have a cooler running engine and get more miles per gallon, more horsepower with less pollution and a quieter ride.
Superscript: DURALUBE Cooler Engine! More MPG! More Horsepower! Less Pollution! Quieter Ride! Much Less Wear!
Announcer: You’ll eliminate the damage caused by cold starts saving you hundreds if not thousands of dollars.
Superscript: DURALUBE You’ll save hundreds of dollars, if not thousands!
Announcer: Nothing compares to Dura Lube because it treats the metal, not the oil.
Superscript: Treats the metal, not the oil.
Announcer: In fact, the higher the temperature and pressure the better it performs. Dura Lube eats the heat and saves the engine.
Superscript: Eats the heat! Saves the engine. Protects up to 50,000 miles!
Announcer: Just one bottle added to your engine’s oil protects for up to 50,000 miles. (Exhibit A, pp. 15-16)

(5) Host: ...Now, that was a torture test, not something we recommend. But NASCAR driver Steve Hansen experienced exactly that. He didn’t mean to. Steve Hansen didn’t intend to completely lose his oil pump in the middle of a big race, but it happened.
Superscript: It happened on August 7, 1993!
Video: Cars circling racetrack.
Hansen: During the feature race, I started right up front, second car on the outside, green light went on, floored the car wide open. My oil pressure dropped down to nothing. I had no oil pressure.
Superscript: Elko Minnesota September 11, 1993.
Hansen: At that time I thought to myself, well, I’m done. I’ll pull off the track. But the motor still was running good. So I went for it. I figured if it’s going to blow up, it’s going to blow up. I continued to race strong. The oil light got brighter and brighter.... It wasn’t knocking. It wasn’t ticking. It was running strong. I finished a 15-lap race which isn’t bad considering I had no oil and the motor was still running.... (Exhibit A, pp. 19-20)

(6) Host: That’s what Dura Lube can do in emergencies. Let’s see what it’s doing for folks day after day.
First Consumer Endorser: The car was overheating a lot and running hot and I put it right in the motor with the oil and not a problem since.
Superscript: Cools the engine!
Second Consumer Endorser: I used to have this exhaust problem, there would be this little cloud of smoke that was behind my car all the time. After I used Dura Lube it disappeared completely.
Superscript: Cleaner emissions!
Third Consumer Endorser: I used it in my own personal vehicle and I’ve noticed almost 40 to 45 percent increase in my fuel.
Superscript: More MPG!
Host: Oh, come on.
Third Endorser: Really. Really. I usually fuel up once a week and now I’m doing it every two weeks. And I only go like five miles a day round trip.
Host: So you’ve got a routine.
Third Endorser: I’ve got a routine. Believe me, I’ve got a routine. Let me tell you. I can honestly say without a word of a lie that I’ve almost doubled the amount of time I can go on a tank of gas in my truck. (Exhibit A, pp. 20-21).

(7) Host: How can one product do so much? Breakthrough technology. And no one knows that better than astronaut Pete Conrad. You probably know him from his famous walk on the moon. But to Pete that’s old news. Just recently he flight managed our nation’s latest breakthrough, the Delta Clipper, the rocket ship blasts off and then it stops in mid-air. Now, this is like something out of Buck Rogers. Then it moves sideways. And then it lands, ready to take off again.
Superscript: Pete Conrad
Conrad: With Delta Clipper you have an old idea using today’s technology that will allow low cost access to space. With Dura Lube, what can I say? I knew it was a real advance in engine lubrication. Now everyone knows it. Sure there were skeptics. Just like there were plenty of skeptics regarding the Delta Clipper idea, but now we know they’re both winners. (Exhibit A, p. 22)

(8) Host: Just how is Dura Lube able to do all those things? Well, recently we got together with our lubrication specialist, Floyd Stivik. He showed me a simple demonstration of the secret to Dura Lube’s success....
Stivik: Dura Lube will actually go in and relieve that heat and pressure. That’s saving oil, saving maintenance on the car, saving those engines, Jim.
Host: Especially the small cars.
Stivik: Especially small cars, Jim. Let me show you what we’re going to do here. We have a piece of sheet metal. We’re going to simulate an engine.
Host: I see this is flat.... What are you going to do?
Superscript: Perfectly level.
Stivik: We’re going to...put in oil. Hand me some oil, Jim.
Host: Now, do you care which one?
Stivik: It doesn’t make any difference. Dura Lube is completely compatible with all oil, Jim. Synthetics, naturals, it doesn’t make any difference....
Video: Untreated oil heated on piece of sheet metal.
Stivik: ...We’re going to see that actually it’s going to start cooking down and it will actually move away from the flames.
Host: You can certainly see that it is spreading out.
Stivik: Spreading out and you can see it’s starting to cook a little along this edge and moving away from the heat over here.... Now I’m going to pour some Dura Lube in here and we’re going to see what happened.... Look at how it’s going to travel. It’s traveling towards that heat. Jim, it goes to the heat. That’s what’s really important. Dura Lube eats the heat and saves those engines. Look at that. Look at that moving to the heat. Isn’t it amazing? Look what it’s doing. It’s going to come in and marry up to that old oil and do the lubrication job that’s necessary on that engine. (Exhibit A, pp. 23-25)

(9) Announcer: Just look at this heat and pressure test conducted by the Falex Corporation. Now, this independent laboratory found premium oil failing at 1,250 pounds. STP hit the failure mark and 1,750 pounds. Slick 50 fared a little bit better, but it too failed at 2,250 pounds. Now look at Dura Lube. It ran in the optimal temperature zone the whole day. Dura Lube ran off the chart.
Superscript: NO FAILURE
Superscript: Pete Conrad
Conrad: I insisted that they run that test. They did it and it passed with flying colors. (Exhibit A, pp. 25-26)

(10) Host: You’re cruising to the grocery store or something and your oil light comes on. Middle of the night, what are you going to do? Are you going to sit there and walk? If you have Dura Lube in your car, you’re going to make it to your destination. (Exhibit A, p. 27)

B. Dura Lube Advanced Engine Treatment Container Box Labeling (Exhibit B)

(1) Tested #1. Dura Lube Advanced Engine Treatment for gas and diesel engines saves fuel, improves performance, protects engine at start up, prolongs engine life. (Exhibit B, front panel)

(2) Pictured: Conrad in space suit with NASA logo. Text: Dura-Lube is the best lubricant I’ve ever seen. It’s absolutely amazing! -- Charles “Pete” Conrad, International Dura-Lube spokesman.
! Captain United States Navy (retired)
! Skylab 1: Commander; 1973
! *Apollo XII: Commander; 1969
! Gemini XI: Commander Pilot, 1966
! Gemini V: Pilot, 1965
*Executed the second lunar landing
(Exhibit B, side panel).

(3) Pictured: Chart of Falex Pin & V-Block test results. Text of caption explains chart as comparing results for “a leading motor oil,” “a leading synthetic oil,” Slick 50 and Dura Lube. All but the Dura Lube results show failure when load is increased.
Text: Dura-Lube dramatically reduces friction and wear, increases gas mileage and horsepower, makes starting easier, improves performance, and extends engine life.
Dura-Lube’s micro-thin layer of bonded protection, however, safeguards vital engine components during these critical (cold start) periods, allowing engine parts to glide effortlessly against each other, reducing wear by more than 50%!
` Dura-Lube contains none of the potentially harmful solid particles such as lead, silicone, molybdenum disulfide, PTFE, or graphite, which are found in other lubrication products. These ingredients can present a hazard to the environment and some can change tolerance in your vehicle’s engine.
Dura-Lube’s amazing formulation is the choice of professionals worldwide. It is used by taxi companies, police departments, and utilities to reduce fuel and maintenance costs, and to prolong engine life. Professional drivers choose Dura- Lube to protect their engines through the extreme conditions of auto racing, and because Dura-Lube increases horsepower, torque, compression, and fuel economy.
Dura-Lube contains NO chlorinated solvents, NO chlorinated esters, and NO ingredients listed as halogenated hazardous wastes by the U.S. E.P.A. (Exhibit B, back panel)

(4) Headline: Some Facts You Should Know Text: Added to the engine of any car or truck, Dura-Lube dramatically reduces friction and wear, increases gas mileage and horsepower, makes starting easier, improves performance, and extends engine life.
[Dura-Lube] dramatically reduces friction and wear and allows your vehicle’s engine to run smoother and cleaner.
Q: Can I use Dura-Lube if I’ve already treated my engine oil with another product?
A. Yes. You should notice an immediate improvement.
Q: Who tested Dura-Lube?
A. Tests on Dura-Lube have been performed by the Falex Corporation, the world’s largest manufacturer of friction and wear test equipment; by approved test facilities in the United States by numerous testing facilities in Europe, and by satisfied drivers all over the world who have traveled millions of trouble free miles using Dura-Lube.
Q: How long does Dura-Lube last?
A. Dura-Lube protects your vehicle’s engine for up to 50,000 miles of normal driving.

C. Dura Lube Advanced Engine Treatment Bottle Labeling (Exhibit C)

Dura-Lube Engine Treatment dramatically reduces friction and wear, increases gas mileage and horse power, makes starting easier, improves performance, and extends engine life. Dura Lube Engine Treatment protects engine up to 50,000 miles of normal driving.

D. Dura Lube Print Advertising (Exhibit D):

(1) Headline: Save up to $25 per month on gas...or it’s free!

(2) Pictured: Chart titled “Metal against metal pressure test.” Caption explains chart as comparing results of extreme pressure tests for "Penzoil" [sic], "Quaker State," "Slick 50," "Marvel" and "STP." All but the Dura Lube results show failure when pressure up to 40 pounds is applied.

(3) Text: Duralube will save you up to 35% on gasoline! -- and add thousands of miles to the life of your car’s engine -- in just one treatment!

(4) Our new product actually saves you money on gas by improving the efficiency of your engine and increasing your gas mileage by 15, 25, even 35%.

(5) The experts agree. We knew we’d have doubters, but we have proof on our side. In tests performed by the U.S. Government’s Environmental Protection Agency DuraLube clearly increased gas mileage and cut down on harmful emissions. But we knew some people still wouldn’t be convinced, so we contracted with another independent testing laboratory, and then another, and all agreed that DuraLube works.

E. Dura Lube Direct Response Advertising (Exhibit E)

(1) Inset: Picture of Conrad Picture caption with quote: Charles “Pete” Conrad, Jr., International Dura Lube Spokesperson, Research and Development Specialist. “It’s absolutely amazing! DURA LUBE passed the tests with flying colors.”

(2) Text: Dura Lube dramatically reduces friction and wear by penetrating metal surfaces to create a non friction shield and give you a better running engine. You’ll get a smoother ride while eliminating the damage caused by cold engine starts.... In independent lab tests, 3 of the most popular lubricants failed, but DURA LUBE ran off the chart. The engineers couldn’t get it to fail!

(3) We’ve even test-raced DURA LUBE in a 500 horsepower engine without any oil and found that DURA LUBE’s state of the art protection kept on working because DURA LUBE treats the metal, not the oil. DURA LUBE eats the heat and saves the engine. Just one bottle added to your engine’s oil protects for up to 50,000 miles so your motor will run smoother and last longer. This means less maintenance, less breakdowns, and less repairs! DURA LUBE’s secret formula contains no solids of any kind.

(4) Pictured: Graph comparing result of Falex Pin & V-Block test showing Dura Lube passing and other lubricants failing.

13. Through the means described in Paragraph 12, respondents have represented, expressly or by implication, that:

A. Dura Lube does not contain any chlorinated compound.

B. Dura Lube has been tested by the U.S. Environmental Protection Agency.

14. In truth and in fact:

A. Dura Lube contains chlorinated paraffin, a chlorinated compound.

B. Dura Lube has not been tested by the U.S. Environmental Protection Agency.

Therefore, the representations set forth in Paragraph 13 were, and are, false or misleading.

15. Through the means described in Paragraph 12, respondents have represented, expressly or by implication, that:

A. Compared to motor oil alone or motor oil treated with any other product, using Dura Lube:

1. Reduces engine wear.

2. Reduces engine wear by more than 50%.

3. Prolongs engine life.

4. Reduces emissions.

5. Reduces the risk of serious engine damage when oil pressure is lost.

6. Improves gas mileage.

7. Improves gas mileage by up to 35%.

B. One treatment of Dura Lube continues to protect the engine for up to 50,000 miles.

16. Through the means described in Paragraph 12, respondents have represented, expressly or by implication, that at the time they made the representations set forth in Paragraphs 13 and 15, respondents possessed and relied upon a reasonable basis that substantiated such representations.

17. In truth and in fact, at the time they made the representations set forth in Paragraphs 13 and 15, respondents did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, the representation set forth in Paragraph 16 was, and is, false or misleading.

18. Through the means described in Paragraph 12, respondents have represented, expressly or by implication, that tests prove that:

A. Compared to motor oil alone, using Dura Lube:

1. Improves gas mileage.

2. Improves gas mileage by up to 35%.

3. Reduces emissions.

4. Prolongs engine life.

5. Reduces engine wear.

6. Reduces the risk of serious engine damage when oil pressure is lost.

B. One treatment of Dura Lube continues to protect the engine for up to 50,000 miles.

19. In truth and in fact, tests do not prove that:

A. Compared to motor oil alone, using Dura Lube:

1. Improves gas mileage.

2. Improves gas mileage by up to 35%.

3. Reduces emissions.

4. Prolongs engine life.

5. Reduces engine wear.

6. Reduces the risk of serious engine damage when oil pressure is lost.

B. One treatment of Dura Lube continues to protect the engine for up to 50,000 miles.

Therefore, the representations set forth in Paragraph 18 were, and are, false or misleading.

20. Through the means described in Paragraph 12, including, but not necessarily limited to, the demonstrations in Exhibit A, respondents have represented, expressly or by implication, that:

A. The demonstration consisting of running an automobile engine after draining the motor oil treated with Dura Lube, proves, demonstrates or confirms that, compared to motor oil alone, Dura Lube reduces the risk of serious engine damage when oil pressure is lost.

B. The demonstration consisting of heating untreated oil on sheet metal and then treating it with Dura Lube proves, demonstrates or confirms that, without Dura Lube, motor oil fails to protect automobile engines under hot running conditions.

21. In truth and in fact:

A. The demonstration referred to in Paragraph 20.A does not prove, demonstrate or confirm that, compared to motor oil alone, Dura Lube reduces the risk of serious engine damage when oil pressure is lost.

B. The demonstration referred to in Paragraph 20.B does not prove, demonstrate or confirm that, without Dura Lube, motor oil fails to protect automobile engines under hot running conditions.

Therefore, the representations set forth in Paragraph 20 were, and are, false or misleading.

22. Through the means described in Paragraph 12, including, but not necessarily limited to, the advertisements, labeling and promotional materials attached as Exhibits A-B and E, respondents have represented, expressly or by implication, that Charles "Pete" Conrad ("Conrad"), a former Naval aviator and NASA astronaut, has expertise in the evaluation and testing of automobile engine lubrication, and has conferred his endorsement of Dura Lube on the basis of an independent, objective and valid evaluation or test using procedures generally accepted in the field of automobile engine lubrication to yield accurate and reliable results.

23. In truth and in fact, Conrad does not have expertise in the evaluation and testing of automobile engine lubrication, and has not conferred his endorsement of Dura Lube on the basis of an independent, objective, and valid evaluation or test using procedures generally accepted in the field of automobile engine lubrication to yield accurate and reliable results. Therefore, the representations as set forth in Paragraph 22 were, and are, false and misleading.

24. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

* * *

NOTICE

Notice is hereby give to each of the respondents hereinbefore named that the third day of June, 1999, at 10:00 a.m. o’clock, or such later date as determined by an Administrative Law Judge of the Federal Trade Commission, is hereby fixed as the time, and Room 532, Federal Trade Commission Building, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 as the place when and where a hearing will be had before an Administrative Law Judge of the Federal Trade Commission, on the charges set forth in this complaint, at which time and place you will have the right under the Federal Trade Commission Act to appear and show cause why an order should not be entered requiring you to cease and desist from the violations of law charged in this complaint.

You are notified that the opportunity is afforded you to file with the Commission an answer to this complaint on or before the twentieth (20th) day after service of it upon you. An answer in which the allegations of the complaint are contested shall contain a concise statement of the facts constituting each ground of defense; and specific admission, denial, or explanation of each fact alleged in the complaint or, if you are without knowledge thereof, a statement to that effect. Allegations of the complaint not thus answered shall be deemed to have been admitted.

If you elect not to contest the allegations of fact set forth in the complaint, the answer shall consist of a statement that you admit all of the material allegations to be true. Such an answer shall constitute a waiver of hearings as to the facts alleged in the complaint, and together with the complaint will provide a record basis on which the Administrative Law Judge shall file an initial decision containing appropriate findings and conclusions and an appropriate order disposing of the proceeding. In such answer you may, however, reserve the right to submit proposed findings and conclusions and the right to appeal the initial decision to the Commission under Section 3.52 of the Commission’s Rules of Practice for Adjudicative Proceedings.

Failure to answer within the time above provided shall be deemed to constitute a waiver of your right to appear and contest the allegations of the complaint and shall authorize the Administrative Law Judge, without further notice to you, to find the facts to be as alleged in the complaint and to enter an initial decision containing such findings, appropriate conclusions and order.

The following is the form of order which the Commission has reason to believe should issue if the facts are found to be as alleged in the complaint. If, however, the Commission should conclude from record facts developed in any adjudicative proceedings in this matter that the proposed order provisions as to Dura Lube Corporation, American Direct Marketing, Inc., Howe Laboratories, Inc., Crescent Manufacturing, Inc., and The Media Group, Inc., corporations; Herman S. Howard, individually and as an officer and director of the said corporations; and Scott Howard, individually and as an officer and director of the said corporations, might be inadequate to fully protect the consuming public, the Commission may order such other relief as it finds necessary or appropriate, including corrective advertising or other affirmative disclosure.

Moreover, the Commission has reason to believe that, if the facts are found as alleged in the complaint, it may be necessary and appropriate for the Commission to seek relief to redress injury to consumers, or other persons, partnerships or corporations, in the form of restitution and refunds for past, present, and future consumers and such other types of relief as are set forth in Section 19(b) of the Federal Trade Commission Act. The Commission will determine whether to apply to a court for such relief on the basis of the adjudicative proceedings in this matter and such other factors as are relevant to consider the necessity and appropriateness of such action.

ORDER

Definitions

For purposes of this Order, the following definitions shall apply:

“Dura Lube” shall mean the aftermarket motor oil additive known as Super Dura Lube Engine Treatment, Advanced Dura Lube Engine treatment, or any product of substantially similar composition marketed as a motor oil product.

“Motor oil product” shall mean a product for use in conjunction with or in place of fully formulated motor oil.

“Competent and reliable scientific evidence” shall mean tests, analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area, that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.

Unless otherwise specified, “respondents” shall mean Dura Lube Corporation, American Direct Marketing, Inc., Howe Laboratories, Inc., Crescent Manufacturing, Inc., The Media Group, Inc., and National Communications Corporation, corporations, their successors and assigns, and their officers, agents, attorneys, representatives, and employees; and Herman S. Howard and Scott Howard, individually and as officers of the corporations, whether acting directly or through any corporation, subsidiary, division, trust or other device, or any of them.

“Commerce” shall be as defined in Section 4 of the Federal Trade Commission Act, 15 U.S.C. § 44.

I.

IT IS ORDERED that respondents, in connection with the manufacturing, advertising, labeling, packaging, offering for sale, sale, or distribution of Dura Lube, in or affecting commerce, shall not misrepresent, in any manner, expressly or by implication, that:

A. Dura Lube contains no chlorinated compound or any harmful component.

B. Dura Lube has been tested by the U.S. Environmental Protection Agency or meets the specifications, requirements or standards of any governmental or standard setting organization.

II.

IT IS FURTHER ORDERED that respondents, in connection with the manufacturing, advertising, labeling, packaging, offering for sale, sale, or distribution of any product for use in any motor vehicle, in or affecting commerce, do forthwith cease and desist from:

A. Making any representation, in any manner, expressly or by implication, that:

1. Compared to motor oil alone or motor oil treated with any other product, using such product:

a. Reduces engine wear;

b. Reduces engine wear by any percentage, dollar or other figure;

c. Prolongs engine life;

d. Reduces emissions;

e. Reduces the risk of serious engine damage when oil pressure is lost;

f. Improves gas mileage;

g. Improves gas mileage by any percentage, miles per gallon, dollar, or other figure;

2. One or any other number of treatments of such product reduces wear for 50,000 or any other number of miles; or,

3. Regarding the performance, benefits, efficacy, attributes or use of such product, unless, at the time of making such representation, respondents possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates the representation.

B. Misrepresenting, in any manner, expressly or by implication, the existence, contents, validity, results, conclusions, or interpretations of any test or study.

III.

IT IS FURTHER ORDERED that respondents, in connection with the manufacturing, advertising, labeling, packaging, offering for sale, sale, or distribution of any product, in or affecting commerce, shall not misrepresent, in any manner, expressly or by implication, that any demonstration, picture, experiment, illustration or test proves, demonstrates or confirms any material quality, feature or merit of such product, or the superiority or comparability of the product in a material respect relative to any other product.

IV.

IT IS FURTHER ORDERED that, respondents, in connection with the manufacturing, advertising, labeling, packaging, offering for sale, sale, or distribution of any product, in or affecting commerce, shall cease and desist from representing, directly or by implication, that such product has been endorsed by a person, group or organization that is an expert with respect to the endorsement message, unless:

A. The endorser’s qualifications give the endorser the expertise that the endorser is represented as possessing with respect to the endorsement; and

B. The endorsement is supported by an objective and valid evaluation or test using procedures generally accepted by experts in that science or profession to yield accurate and reliable results.

V.

IT IS FURTHER ORDERED that, for five (5) years after the last date of dissemination of any representation covered by this order, respondents shall maintain and upon request make available to the Federal Trade Commission for inspection and copying:

A. All labeling, packaging, advertisements and promotional materials setting forth any representation covered by this order;

B. All materials that were relied upon to substantiate any representation covered by this order; and

C. All tests, reports, studies, surveys, demonstrations or other evidence in their possession or control, or of which they have knowledge, that contradict, qualify, or call into question such representation, or the basis relied upon for the representation, including complaints and other communications with consumers, third-party dispute mediators, or governmental or consumer protection organizations.

VI.

IT IS FURTHER ORDERED that:

A. The corporate respondents and their successors and assigns shall notify the Federal Trade Commission at least thirty (30) days prior to any change in the corporate respondents that may affect compliance obligations arising under this order, including but not limited to dissolution, assignment, sale, merger or other action that would result in the emergence of a successor corporation, the creation or dissolution of a subsidiary, parent, or affiliate that engages in any acts or practices subject to this order, the proposed filing of a bankruptcy petition, or a change in the corporate name or address. Provided, however, that with respect to any proposed change in the corporation about which respondents learn less than thirty (30) days prior to the date such action is to take place, respondents shall notify the Commission as soon as practicable after obtaining such knowledge.

B. Each of the individual respondents, for a period of ten (10) years after the date of issuance of this order, shall notify the Federal Trade Commission of the discontinuance of his current business or employment, or his affiliation with any new business or employment. The notice shall include the respondent’s new business address and telephone number and a description of the nature of the business or employment and his duties and responsibilities.

All notices required by this Part shall be sent by certified mail to the Associate Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, Washington, D.C. 20580.

VII.

IT IS FURTHER ORDERED that the corporate respondents and their successors and assigns and the individual respondents shall deliver a copy of this order to all current and future principals, officers, directors, and managers, and to all current and future employees, agents, and representatives having responsibilities with respect to the subject matter of this order, and shall secure from each such person a signed and dated statement acknowledging receipt of this order. Respondents shall deliver this order to current personnel within thirty (30) days after the service of this order, and to future personnel within thirty (30) days after the person assumes such position and responsibilities.

VIII.

IT IS FURTHER ORDERED that respondents shall:

A. Within thirty (30) days after the date of service of this order, send notice of this order by first class certified mail, return receipt requested, to each purchaser for resale of Dura Lube with which respondents have done business since January 1, 1994. The mailing shall not include any other documents;

B. In the event that respondents receive any information that subsequent to its receipt of notice of this order any purchaser for resale is using or disseminating any advertisement or promotional material that contains any representation prohibited by this order, respondents shall immediately notify the purchaser for resale that respondents will terminate the use of said purchaser for resale if it continues to use such advertisements or promotional materials; and

C. Terminate the use of any purchaser for resale about which respondents receive any information that such purchaser for resale has continued to use any representation prohibited by this order after receipt of the notice required by subparagraph B of this part.

IX.

IT IS FURTHER ORDERED that respondents shall, for five (5) years after the last correspondence to which they pertain, maintain and upon request make available to the Federal Trade Commission for inspection and copying:

A. Copies of all signed statements obtained from persons or entities pursuant to part VII of this order;

B. Copies of all notification letters sent to purchasers for resale pursuant to subparagraph A of part VIII of this order; and

C. Copies of all communications with purchasers for resale pursuant to subparagraphs B and C of part VIII of this order.

X.

IT IS FURTHER ORDERED that respondents shall, within sixty (60) days after service of this order, file with the Federal Trade Commission a report, in writing, setting forth in detail the manner and form in which they have complied or intend to comply with this order.

XI.

IT IS FURTHER ORDERED that this order will terminate twenty (20) years from the date of its issuance, or twenty years from the most recent date that the United States or the Federal Trade Commission files a complaint (with or without an accompanying consent decree) in federal court alleging any violation of the order, whichever later occurs; provided, however, that the filing of such complaint will not affect the duration of:

A. Any paragraph in this order that terminates in less than twenty years;

B. This order’s application to any respondent that is not named as a defendant in such complaint; and

C. This order if such complaint is filed after the order has terminated pursuant to this paragraph.

Provided further, that if such complaint is dismissed or a federal court rules that the respondent did not violate any provision of the order, and the dismissal or ruling is either not appealed or upheld on appeal, then the order will terminate according to this paragraph as though the complaint had never been filed, except that the order will not terminated between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

IN WITNESS WHEREOF, the Federal Trade Commission has caused this complaint to be signed by its Secretary and its official seal to be hereto affixed at Washington, D.C. this twenty-ninth day of April, 1999.

By the Commission.
Donald S. Clark
Secretary
SEAL:

EXHIBIT A
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The following program is a paid advertisement brought 
to you by The Media Group. 
Is there a breakthrough the oil companies may not 
want you to know about? Magic in a bottle that could save 
you hundreds of dollars on oil and gasoline? 
This is unbelievable. 
What do you think? 
I wouldn't believe it if I didn't see it myself. 
It's amazing. You drive through a puddle and your 
car stalls. And this is a whole fire hose on it. 
What do you think of it? 
I can't believe it. I really can't believe it. 
They're flooding this engine. It shouldn't be running. 
I was amazed. I couldn't believe it. 
I'm waiting for it to conk out. It just wouldn't. 
[Clapping] If I didn't see it, I wouldn't believe it. 
If I wasn't here, I wouldn't have believed it. 
I wouldn't believe it if I didn't see it. 
I wouldn’t believe it if I didn’t see it. If I’ve heard 
that line once, I’ve heard it a thousand times. Hi there, folks, 
I’m Jim Caldwell. You know, since we went on the air with our 
first show talking about Dura Lube, hundreds of thousands of you 
have started adding it to your engine oil, your transmission 
fluid, your power steering, your differential. Everywhere there's 
a moving part, people are using Dura Lube. 
Now, we knew that Dura Lube was truly a breakthrough 
product, but we had no idea of the thousands of testimonials in 
writing that we would receive from people all across the country 
stating how great Dura Lube really is.
For instance, Minnesota. Newspaper man, Gerald 
Snyder boost his mileage and avoids a hundred dollar 
transmission repair by treating his car with Dura Lube. 
Los Angeles. Johnny Ishibashi’s ‘68 Pontiac had flunked 
California's tough emissions test. But after just one bottle of 
Dura Lube, it passed with flying colors. 
New York. Barbara Wreck was ready to junk her whole car 
when it kept stalling in the rain. But after using Dura Lube 
spray, the problem absolutely disappeared. That one bottle ended 
up saving her thousands of dollars. 
Now, all this probably sounds a little bit too good to be 
true doesn't it? If something was so good, wouldn't one of the 
big oil companies come out with it? Well, think about it. Would 
a big oil company want to put something on the market that would 
save you so much money on gas and oil, plus make all of their 
existing products obsolete? Would any big oil company want to 
put something on the market that would allow an engine to run 
without oil? 
Well, if you saw our last show, you know that's exactly what 
Dura Lube can do. We added Dura Lube to the oil in a huge race 
car engine and then drained all the oil out including the Dura 
Lube. Dura Lube works even if all your oil is gone. It's not 
like other additives. It's a genuine breakthrough in 
lubrication. Should the engine have seized already? Under 
normal circumstances severe engine damage would have happened by 
now. Already. 
The Dura Lube obviously has attached itself to the engine 
components and still protecting it. 
Then with no oil pressure we started revving that 500 
horsepower engine up under full load. 
Got any load yet? 
Oh, we've got a lot of load, Jim. 
Up to 120 horsepower, 160, 224, 254, 260, 292. 
I was ready to leave the building. I thought we were going 
to see the Fourth of July today and parts flying through that 
wall. 
302, 348. 

I was ready to run. 
[Superscript: No oil pressure!] 
409, 453, 473.
I’m still speechless. 
482, 520, 525. Oh, no. Unbelievable. I don't believe it. 
Oh, my God. 
[Superscript: A 500 HP Dura-Lube treated race car engine just 
ran successfully with no oil pressure under full load and high 
rpm -- unrehearsed!] 
That test left professional mechanics shaking. But even 
with no oil at all, even with that big torture run up, the 
bearings in the Dura Lube treated engine looked as good as new, 
as you can see for yourself. 
I saw it with my own eyes and there's more I can say about 
that. 
Logically, it's not possible to do what was just done. 
It doesn't seem to be not when you think that the bearings 
of the engine are suspended in oil and you just took away that 
suspension totally from that crankshaft and that thing stayed 
together. 
Ever since that show, Dura Lube has been accepted around the 
world, from England to France to Australia and japan, no matter 
what the people are using, no matter what kind of oil, whether 

it's regular, premium or synthetic, Dura Lube simply turns it 
into a super lubricant. Tomorrow's technology today. 
But, you know, people got so excited about that big race 
car-engine demonstration that they kind of missed the fact that 
there is a Dura Lube formulated specifically for your 
transmission. This will give you phenomenally smooth and easy 
shifts and save you hundreds of dollars in costly repairs. 
Now, check this out- Dura Lube spray. This does things that 
no other lubricant even claims to do. It will protect your 
electrical system against any kind of stall due to rain or 
puddles or snow or ice. And of course, it will work on all those 
little nooks and crannies like your roller blades. Let's say you 
want them to spin faster. Or your door locks are frozen or maybe 
your door hinges or you name it. This product works fantastic. 
You know Dura Lube really is a miracle, and we're going to 
prove it again. We're going to top ourselves folks. We’re going 
to take an engine and we're going to empty all the oil out. Now, 
you would expect that, right? Guess what we're going to do 
next? We're going to take all the water out. No oil. No 
coolant in the engine. Then we're going to take this little 
product right here, Dura Lube spray and we're going to do 
something that they wouldn't even let us do unless there's a fire 
engine standing by. In fact, it's exactly why people are saying 
I wouldn't believe it -if I didn't see it. Watch this. We 

gathered a bunch of folks in Suffolk County, Long Island, 
mechanics, a few long time Dura Lube users, and some folks who'd 
never even heard of the product. When we told the authorities 
what kind of test we were planning, they insisted that we have a 
fire truck standing by. They didn't think any engine could 
withstand the kind of torture we had in mind. 
First, we started up a big six cylinder engine. Then we 
drained out all the oil and that engine just kept humming along. 
No problem. 
But we wanted to top ourselves. So we said we'd drain out 
all the water as well. 
Can you imagine? Now, your radiator's designed to cool the 
engine, right? Well, sir, what's going to happen if you take the 
water out of the radiator and you've already taken the oil out. 
What do you think's going to happen? 
I think it would seize, blow up, seize up, never run again. 
Do you think Dura Lube works? 
We're going to find out I think. 
We drained that radiator dry as a bone and the engine just 
purred right along. 
All right. The oil's gone. Water's gone or just about gone. 
Why is this still running? 
[Superscript: Floyd Stevik -- Lubrication Specialist] 

Dura Lube. The quality of Dura Lube’s what's happening, 
Jim. Dura Lube actually stays up there and does the lubrication 
for you. It doesn't leave your engine. 
So it's not treating the oil, it's treating the metal. 
That's exactly right. It's treating the metal. 
You guys get that? Stan, what do you think of that? 
It's amazing. The push rods are still spinning round. 
Nothing's seizing up. There's no noise coming from any place. 
It's got me baffled so far, but I'm watching. I'm watching. I 
want to see more of this. 
What else do you want to see? 
I just want to see how much longer this is going to run 
before it starts clicking and before I hear some bearings 
rapping. 
This test, I mean, you can't deny the test. I mean, I saw 
it for myself. 
If I wasn't here, I wouldn't have believed it. Not at all. 
Do you know anything about engines? 
No, just put oil in when the little oil light goes on. 
Well, you always worry that one day you're going to come 
home from work and the wife tells you that she meant to tell you 
for the last three days the red light is on in the car. And the 
next thing you know you've got major problems, major cost 
factors. With this you wouldn't have that problem. 

No coolant, no oil pressure. No problems. But you folks 
ain't seen nothing yet. 
This is nothing but pure old, good old drinking water. It 
didn't come from Tennessee but it's great water. I'm going to 
pour this in the distributor cap. 
Now, wait a minute. Have you treated this with Dura Lube 
yet? 
Oh, it's a good idea. Wow. 
Small detail. 
I tell you what - 
Now, what would have happened if you had not treated that? 
I wouldn’t have started. 
Let me ask you what would happen if you took that 
distributor, sir, and soaked it with water? 
Never would have been able to start it up. 
Why not? 
Because you can't get water in there, electrical system. 
What's wrong with getting water in the electrical system? 
Electrical and water don't mix. 
Electrical and water don't mix unless -- I'm sorry -- 
Your electricity bounces around instead of going through the 
ignition wire to the spark plug. It would be like an explosion 
instead of a pin point. 

An explosion? Well, then here's a real test of Dura Lube’s 
protection. 
Okay, what I'm going to do is I'm going to spray this cap 
first. 
Yep. 
With protectant, with Dura Lube. 
Get in here Paul. Let's get some witnesses to exactly what 
he's doing. 
Okay? 
Okay. 
Now I'm going to pour this cup of water in here. 
Now, did you put enough in there? 
I think so. Pour a cup of water in here, okay? 
Hold it. Now, look at this. Can we have a drink of that? 
Well, I wouldn't touch that one, but, yeah, it's just pure 
water. Pure water. We're going to put that cap back on and see 
if we can start this engine. 
You're going to dump it out. Okay, so that thing is loaded, 
just loaded with water. 
All right. We're going to start it up now, Jim, with all 
that water in the distributor cap. 
Do you think this is going to start? 
I'm skeptical. 
No way. 

No way? 
It's not going to start. 
Why not? 
Too much water in there. 
You'd think so wouldn't you? Just go around there and stand 
there and wait. We're going to get your camera on the engine 
here. Let's see what we're going to do, Jack. Oh, man. It 
wants to turn over. 
Oh, my. What do you think of that? What do you think of 
that? 
Fantastic, fantastic, unbelievable. I had an engine. As a 
matter of fact, a guy sold me a car. Because every time it would 
rain, the car wouldn't stop. This is unbelievable. 
What do you think? 
I wouldn't believe it if I didn't see it myself. 
What do you think? 
It's incredible. 
Did you expect that to happen? 
No oil, no water. I didn't expect that to happen. 
Distributor cap full of moisture. What do you think, sir? 
It's unbelievable to see how it repels all that water from 
getting it into the electrical system like that. 
That's exactly the word. It repelled. It repelled the 
water. You're amazed, aren't you? What do you think? 

No oil, no water, water in the distributor cap. 
Next thing you'll be telling us you don't need gasoline to 
run the thing. 
Let's make sure that everybody here knows we're not just 
talking about the crank case. Dura Lube. We've got a 
transmission conditioner. The all purpose spray. 
Yeah? 
Can we spray the engine a little bit? 
Oh, my gosh. Now, wait a minute. Hold it. 
Should we leave the valve cover on or off? What do you 
think? 
Leave it off. 
Yeah, leave it off. 
You want to put water in the valve cover? 
It'll work. 
Oh, my gosh. I don't know what to say, folks. 
Maybe I better put a little protection. 
Yeah, just put a little something here. Come on. Come on. 
We've got to give it a little hope here. You're going to spray 
this with water. What do you think should happen? 
I think the engine's going to die. I really do. 
Is the engine going to die, Wayne? 
I would say it would die almost instantly. I keep 

looking around for an external oil source or water source. I
can't find it. I can't believe what's going on.
This is a heck of a legitimate test, isn't it? 
It's 100 percent legitimate. 
You're blown away aren't you? 
I can't believe it. Like I said, I'm still looking for an 
external oil source and more water from somewhere, but I can't 
find it anywhere. 
You think we're faking this? 
No, it's not a fake, but I wouldn't believe it if I 
didn't see it. It's amazing. 
It's good stuff. All right. I guess we've got to try this. I 
didn't know they were going to do this too. Here we go, folks. 
Watch it. Here we go. Watch Floyd. Get the electrical. It's 
still running. What do we think of this? 
It's amazing. It’s amazing. 
Frank, get over here. I've got to get a couple of comments 
from people. 
It's amazing. You drive through a puddle and your car 
stalls. And this is a whole fire hose. 
What do you think of this? 
I can't believe it. I really can't believe it. They're 
flooding this engine. It shouldn't be running. It just 
shouldn't be running. 

What do you think, sir? 
A little common sense, seeing is believing. I can't believe 
it myself. I'm amazed. I'm still looking. 
They're putting water down through the head, through the 
cylinder heads, past the push rods, going into the oil. So 
the oil should be in the pan and this thing is still running. 
Water is a lubricant for cooling, but not as far as, not as far 
as keepin’ an engine running.
But for everyone who really believes in a product, there's 
always someone who thinks you're trying to pull a fast one. 
Can you pull the coil wire out to stall it? Just to see. 
It will stop. It will kill it. 
If you pull the coil wire, of course it's going to stop. 
Right. It will stop. I just want to see if that's the 
distributor. 
I can hear his challenge. He wants you to prove that's 
really the distributor cap. Can you do something here without 
shocking yourself? What can you do? 
I'd have to stop it, wouldn't I, to pull that coil? 
Wayne, you're the expert. He wants - 
It's going to run up the side, isn't it? 
It should die right out, right. 
You're not going to hurt yourself, right Floyd? 
All right, folks. Proof's in the pudding. Are you sold? 

Yes, I'm sold. 
Oh, now watch. He's going to start it up again. He's going 
to start it up again, folks. 
Can other spray lubricants protect an engine from so much 
moisture? No way. Just look at these independent tests. [Chart 
inset] Dura Lube spray was one-third more effective than a 
competing product, One Lube, when it came to moisture protection. 
WD-40 did even worse. It was only one-eighth as effective as Dura 
Lube spray. And that's why only Dura Lube spray can offer this 
amazing guarantee. Your car will go in rain or snow or Dura Lube 
will pay the tow. [Superscript: Dura-Lube Guarantee. Your car 
will go in rain or snow or Dura-Lube will pay the tow! $35 per 
occurrence. Subject to terms and conditions.] That's a 
guarantee. Dura Lube can protect a distributor cap full of 
moisture. Only Dura Lube can stand up to a fire hose. The 
others don't even make such claims. 
You’re pumping water up there and it's still running. It 
shouldn't be. It shouldn't be. Does he walk on water too? 
What's the story here? This is like the next best thing to 
sliced bread. Really. Where did you find this stuff? 
Introducing Dura Lube. The world's first space age all 
purpose lubricant that virtually eliminates friction like nothing 
on earth. In space there is no friction, but inside your engine 
friction drags on every moving component generating heat, wear 

and tear, causing poor fuel economy, more pollution, even engine 
breakdown. [Superscript: Friction causes: Heat! Wear! Poor Fuel 
Economy! More pollution! Engine breakdown!] Dura Lube 
radically reduces friction by penetrating metal surfaces to 
create a non-friction shield that gives you a more efficient 
engine. With Dura Lube you'll have a cooler running engine and 
get more miles per gallon, more horsepower with less pollution 
and a quieter ride. [Superscript: DURALUBE Cooler engine! More 
MPG. More horsepower! Less pollution! Quieter ride! Much less 
wear!] You'll eliminate the damage caused by cold starts saving 
you hundreds if not thousands of dollars. [Superscript: DURALUBE 
You’ll save hundreds of dollars, if not thousands!] Nothing 
compares to Dura Lube because it treats the metal, not the oil. 
[Superscript: Treats the metal, not the oil.] In fact, the 
higher the temperature and pressure the better it performs. 
[Insert: chart of torque pressure tests.] Dura Lube eats the 
heat and saves the engine. [Superscript: Eats the heat! Saves 
the engine!] Just one bottle added to your engine's oil protects 
for up to 50,000 miles. [Superscript: Protects for up to 50,000 
miles!] 
And introducing Dura Lube spray. Has this ever happened to 
you? A rainstorm -- even a small puddle stops you instantly. 
But even a fire hose can't stop an engine once it has Dura Lube 
protection. That's why you'll get this guarantee. Use Dura Lube 

spray as directed, and if you ever get stuck in rain or snow, 
Dura Lube will pay your tow. 
And it does so much more. It protects anywhere you need 
lubrication, door hinges, roller skates, power tools, anywhere 
there's metal to metal contact. [Superscript: Protects anywhere 
you need lubrication. Door hinges. Roller skates. Power tools. 
Metal to metal contact.] And only one can of Dura Lube-spray 
replaces these ten cans of the leading competition. So why 
accept anything else? Order now and you'll receive Dura Lube 
engine treatment. [Superscript: Engine] One bottle protects for 
up to 15,000 miles. Dura Lube transmission treatment 
[Superscript: Transmission.] to guard against fluid breakdown 
and Dura Lube spray [Superscript: Spray], newly formulated, to 
also protect against your electrical system -- guaranteed. Get 
all the protection your car needs for only $29.95. And if you'll 
order now, we'll also include these blue shield sunglasses, a $20 
value, yours absolutely free. [Superscript: Free -- with order] 
But wait. If you order two Dura Lube kits during this special TB 
promotion, you'll receive this fabulous car care kit absolutely 
free. [Superscript: Free -- with order] With color match -- 
covers scratches with the best shine in your car's own color. 
Dura Shield to protect and restore leather and vinyl. 
[Superscript: Protects and restores leather.] Glass shield for 
clear vision through any weather. [Superscript: Clear vision 

through any weather.] And fog shield, the fog eliminator. 
[Superscript: The fog eliminator.] Another $20 value, yours 
free when you order two kits. [Superscript: Not available in 
stores!] Dura Lube tomorrow's technology today. Here's how to 
order. [Superscript: The program you are watching is a paid 
advertisement for Dura-Lube.] 
To order your Dura Lube system, have your credit card ready 
and call 1-800-215-1500. Or send your check or money order for 
$29.95 plus $6.99 for shipping and handling to Dura Lube, 300 
McCann Street, Nashville, Tennessee 37210. Dura Lube provides 
unequaled protection for your car's engine. So call now 1-800- 
215-1500, and order today. 
Welcome back. You know, I want to you take a look at a 
moment from our last show. [Superscript: July 1992]. 
If any oil or oil additive company can step forward and 
prove through the same test that they have a better product than 
Dura Lube, the Dura Lube Corporation will write a check for 
$100,000. 
You know what's amazing about that challenge? Nobody 
stepped forward to claim $100,000. [Superscript: The challenge 
ran over a year!] Oh, sure. A few of the big oil companies 
asked for all the details of the test, but that's the last we 
heard of them. We absolutely shut the competition down. 

One test in our $100,000 challenge was how long an engine 
could run without any oil. Now, that was a torture test, not 
something we recommend. But NASCAR driver Steve Hansen 
experienced exactly that. He didn't mean to. Steve Hansen 
didn't intend to completely lose his oil pump in the middle of a 
big race, but it happened. [Superscript: It happened on August 
7, 1993!] 
During the feature race [Superscript: Elko, Minnesota 
September 11, 1993], I started right up front, second car on the 
outside, green light went on, floored the car wide open, my oil 
pressure dropped down to nothing. I had no oil pressure. At 
that time I thought to myself, well, I'm done. I'll pull off the 
track, but the motor still was running good. So I went for it. 
I figured if it's going to blow up, it's going to blow up. I 
continued to race strong. The oil light got brighter and 
brighter. I couldn't believe it. I kept going. The motor, it 
wasn't knocking. I was figuring after three or four laps I could 
start hearing a knock and it wasn't. It wasn't knocking. It 
wasn't ticking. It was running strong. I finished a 15 lap race 
which isn't bad considering I had no oil and the motor was still 
running. I pulled into the pits. I could see that my pit crew - 
- Cory, he was discouraged. He thought that I blew up the 
engine. 

I thought he was nuts, you know, I was getting mad because 
he wasn't pulling off or nothing. But I guess he knew what he 
was doing. 
Cory just shook his head and I told him, I said, well, Dura 
Lube did its job. 
That's what Dura Lube can do in emergencies. 
Let's see what it's doing for folks day after day. 
The car was over heating a lot and running hot and I put it 
right in the motor with the oil and not a problem since. 
[Superscript: Cools the engine] 
I used to have this exhaust problem, there would be this 
little cloud of smoke that was behind my car all the time. After 
I used Dura Lube it disappeared completely. [Superscript: 
Cleaner emissions!] 
I used it in my own personal vehicle and I've noticed almost 40 
to 45 percent increase in my fuel. [Superscript: More MPG!] 
Oh, come on. 
Really. Really. I usually fuel up once a week and now I'm 
doing it every two weeks. And I only go like five miles a day 
round trip. 
So you've got a routine. 
I've got a routine. Believe me, I've got a routine. Let me 
tell you. I can honestly say without a word of a lie that I've 

almost doubled the amount of time I can go on a tank of gas in my 
truck. 
I had first gotten Dura Lube just before that big winter 
storm we had that hit the whole East Coast. [Superscript: 
Prevents stalls.] 
The storm of the century? 
The storm of the century is what they called it, yeah. And 
I had some calls that were really far away. People really in 
emergency situations that needed cab rides. A lot of cars 
stalled out, but I just kept going. I made it through everything, 
all kinds of puddles. I would go through the puddle saying here 
we go, this is it. This is the end. And it just kept going. 
I think it's fantastic because I had a car and in January 
when we had the rainy season, every time it would rain, the car 
would stay there for a week because it wouldn't move and I'd have 
to wait for the sun to come out. [Superscript: Saves you money!] 
All right. Now I see they had all this water poured on the car. 
I could have saved thousands of dollars because I went out and 
bought another car. 
I lost an engine similar to this one because the oil filter 
came off. [Superscript: Saves your engine] I lost the oil. The 
light came on, but it was too late. The engine was gone. It 
cost me a couple thousand dollars to get a new engine. 
So Dura Lube can definitely save you money. 

Yeah, it can save you a lot of money. 
How can one product do so much? Breakthrough technology. 
And no one knows that better than Astronaut Pete Conrad. You 
probably know him from his famous walk on the moon. But to Pete 
that's old news. Just recently he flight managed our nation's 
latest break through, the DeltaClipper, the rocket ship blasts 
off and then it stops in mid-air. Now, this is like something 
out of Buck Rogers. Then it moves sideways. And then it lands, 
ready to take off again. [Superscript: Pete Conrad] 
With Delta Clipper, you have an old idea using 
today's technology that will allow low cost access to space. 
With Dura Lube, can I say? I knew it was a real advance in 
engine lubrication. Now everyone knows it. Sure there were 
skeptics. Just like there were plenty of skeptics regarding the 
Delta Clipper idea, but now we know they're both winners. 
Just how is Dura Lube able to do all those things? Well, 
recently we got together with our lubrication specialist Floyd 
Stevik. He showed me a very simple demonstration of the secret 
to Dura Lube’s success. 
Everything’s metal in an engine, Jim. 
Right. 
And this metal heats up. Every time it meets, it heats. 
And it actually creates heat and wear inside an engine. 
All right. 

Dura Lube will actually go in and relieve that heat and 
pressure. That's saving oil, saving maintenance on the car, 
saving those engines, Jim. 
Especially the small cars. 
Especially small cars, Jim. Let me show you what we're 
going to do here. We have a piece of sheet metal. We're going 
to stimulate an engine. 
I see this is flat here. [Superscript: Perfectly level] 
Let's remove that. What are you going to do? 
We're going to put some heat in here. We're actually going 
to put in oil. Hand me some oil over there, Jim. 
Now, do you care which one? 
It doesn't make any difference. Dura Lube is completely 
compatible with all oil, Jim. Synthetics, naturals, it doesn't 
make any difference. 
Here you go. 
We're going to put a little bit of this oil right here in 
the front, right over the top of that burner. 
You want that right under the oil? 
Yes, right-under the oil. 
Right under the oil. It is now officially under. 
There we go. 
Is that high enough? You want it a little higher? 
Put a little heat to it, Jim. 

That is really going against that metal now. Okay, cooking. 
We're going to watch that Jim. We're going to see that 
actually it's really going to start cooking down and it will 
actually move away from the flames. 
You can certainly see that it is spreading out. 
Spreading out and you can see it's starting to cook a little 
along this edge and moving away from that heat over here. 
Okay. 
Now, I'm going to pour some Dura Lube in here and we're 
going to see what happened. Now, you know this is perfectly 
level. 
Right. 
Look at how it's going to travel. It's traveling towards 
that heat. Jim, it goes to the heat. That's what's really 
important. Dura Lube eats the heat and saves those engines. 
Look at that. Look at that moving to that heat. Isn't that 
amazing? Look what it's doing. It's going to come in and marry 
up to that oil and do the lubrication job that's necessary on 
that engine. Look at that. Look at that, Jim. Look at it -- 
it’s still moving toward.... 
Now, let's take a look at that again. Look at the hot spot, 
the-circle directly above the flame. The oil moves away from the 
hot spot. You can see the circle it's leaving. But on this 
totally level surface, Dura Lube goes towards the heat. It likes 

heat. Dura Lube eats the heat. That's Dura Lube’s secret. 
Look, it's going right into the hot spot. Dura Lube eats the 
heat caused by friction. Just look at this heat and pressure 
test conducted by the Falex Corporation. [Insert: chart of 
torque-pressure tests] Now, this independent laboratory found 
premium oil failing at 1,250 pounds. STP hit the failure mark at 
1,750 pounds. Slick 50 fared a little bit better, but it too 
failed at 4,250 pounds. Now look at Dura Lube. It ran in the 
optimal temperature zone the whole way. It never failed. Dura 
Lube ran off the chart. [Superscript: No Failure] 
I insisted that they run that test. [Superscript: Pete 
Conrad] They did it and it passed with flying colors. 
Then we decided to try a similar test ourselves, this time 
pitting Dura Lube spray against three popular competitors. 
First, a silicone spray made by Gunk. 
Okay, we turn it. It's rotating now. We’re going to put the 
pressure on. 
It was stopped dead at only five pounds of pressure as 
measured on a simple scale. Then we tried the Teflon spray One 
Lube made by Slick 50. 
I believe that's probably plenty. 
All right, let’s try that. 
We’re going to do the same thing, Jim. 

The result? Exactly the same, five pounds once again as you 
can see. Now, you'd think WD-40 would outperform the rest. 
We’re going to apply the pressure again. 
What have we got? The same place. In fact, it's a little 
less. About four, four-and-one-half pounds, virtually the same 
as the other two. Then came Dura Lube spray. We couldn't even 
get it to stop. It ran right off the scale. That's just one 
reason everybody's talking about Dura Lube. [Superscript: Actual 
elapsed time 46 seconds] 
You're cruising to the grocery store or something and your 
oil light comes on. Middle of the night, what are you going to 
do? Are you going to sit there and walk? If you have Dura Lube 
in your car, you're going to make it to your destination. 
Introducing Dura Lube. The space age lubricant that 
radically reduces friction by penetrating metal surfaces to 
create a non-friction shield. With Dura Lube your engine will 
run cooler and get more miles per gallon, more horsepower with 
less pollution and a quieter ride. [Superscript: DURALUBE 
Cooler engine! More mpg. More horsepower! Less pollution! 
Queter ride! Much less wear!] And introducing Dura Lube spray. 
Has this ever happened to you? A rainstorm, even a small puddle 
stops you instantly. But even a fire hose can't stop an engine 
once it has Dura Lube protection. That's why you'll get this 
guarantee. Use Dura Lube spray as directed, and if you ever get 

stuck in rain or snow, Dura Lube will pay your tow. 
[Superscript: Dura-Lube Guarantee. Your car will go in rain or 
snow or Dura-Lube wil pay the tow! $35 per occurrence. Subject 
to terms and conditions.] 
And it does so much more. It protects anywhere you need 
lubrication, door hinges, roller skates, power tools, anywhere 
there's metal to metal contact. [Superscript: Protects anywhere 
you need lubrication. Door hinges. Roller skates. Power tools. 
Metal to metal contact.] And only one can of Dura Lube spray 
replaces these ten cans of the leading competition. So why 
accept anything else? Order now and you'll receive Dura Lube 
engine treatment. One bottle protects for up to 15,000 miles. 
[Superscript: Dura-Lube contains no chlorinated solvents or 
esters and no ingredients listed as halogenated wastes by USEPA. 
CONTAINS NO SOLIDS!] 
Dura Lube transmission treatment to guard against fluid 
breakdown and Dura Lube spray, newly formulated, to also protect 
your electrical system guaranteed. Get all the protection your 
car needs for only $29.95. And if you order now, we'll also 
include these blue shield sunglasses, a $20 value, yours 
absolutely free. But wait. If you order two Dura Lube kits 
during this special TV promotion, you'll receive this fabulous 
car care kit absolutely free. With Color Match covers scratches 
with the best shine in your car's own color. Dura Shield to 

protect and restore leather and vinyl. [Superscript: Protects 
and restores leather.] Glass Shield for clear vision through any 
weather. [Superscript: Clear vision through any weather.] And 
Fog Shield, the fog eliminator. [Superscript: The fog 
eliminator.] Another $20 value, yours free when you order two 
kits. Dura Lube. Tomorrow's technology today. Here's how to 
order. [Superscript: The program you are watching is a paid 
advertisement for Dura-Lube] 
To order your Dura Lube system, have your credit card ready 
and call 1-800-215-1500. Or send your check or money order for 
$29.95 plus $6.95 for shipping and handling to Dura Lube, 300 
McCann Street, Nashville, Tennessee 37210. Dura Lube provides 
unequaled protection for your car's engine. So call now. 1-800- 
215-1500, and order today. 
Get the electrical. 
It's still running. What do you think of this? 
It's amazing. It's amazing. 
A little common sense, seeing is believing. 
The preceding program was a paid advertisement for Dura Lube 
sponsored by the Media Group. 
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[Exhibits B-E are attached to paper copies of complaint,
but are not available in electronic form.]