# Petition for Writ of Certiorari — Federal Trade Commission v. Mandel Bros. > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386409_0154%3A1 ## Record - **Collection:** Supreme Court brief - **Document type:** Petition for Writ of Certiorari - **Published:** January 1, 1959 - **Citation:** 359 U.S. 385 ## Text . ™ PATO Seat ee ; - ae oar , INDEX os aed Opinion below-.- - . -----.-- sivnedadsvedsacbivads Siacee aoe © Jurisdiction. AtiieSedendencdsa ee ee aeees Wa a Welw w e be 1 Questions presented. ________-- Scien ceeds shevebdarebas 2 MMR iddh yc. ioc cos ssecorseses PSS PP on ae 2 Statement. _ _. _- ews badens sueae CSM A a Ke eee ew eee 2 The invoicing violations. gecsds i SEA SSS 4 The labeling violations -_-_-__.-...-.-..-.--2-2-2-.- 5 Reasons for granting the-writ-—.--- lassenn ~oeoowe Te Conchpiiess 2225 522.22020 6 i: Bee gee eeoue Scat / Appendices - -- - - - - -- sae: tH jae hecsrou deter aadenecodag 15 ; _ EITATIONS eh ere Cases: | ig Black v. ‘Magnolie Liquor Co., 355 U. OM 8 De Gorter v. Federul Trede Commission, 244 F.2d270. 10 . Federal Trade Commission v. Morton Salt Company, GO Rte btn e as aces sha meennee he | Federal Trade Commission v. Ruberoid™ Company, 343 1 SR Soin REAR + CER eile RE nat, MN ner 4 gy Feriton v. Thorley & Co., , [1903] A. C. ORES 10 Knowlton.v. Mooré, 178 U. x. EER ARP Tes id. Local 167, Int'l Brotherhood of aces v. ‘United me i bs 4 4 May Department Stores Company v. Nasional i Relations Board; 326 U. 8. 376___--. =. -- aS 120 National Labor- ‘Rdaiiene Board v. Express Publishing of Co. , 312 U. MN ccd ated etl hice a wi Ein ates Wao Saicbsne 12° Siegel Company, Jacob v. Federal Trade Commission, HG: Oe ee inh te Se canoes ae} we United States v. American Trucking Ass'ns, 310 U. ry DE GicaLaend cde chit neh ata onckewwakn 10 White v. + United States, 191 vf S, 565....-.- Riiecaeks 10 @ 474233—58——1 Gis SU Sent - Statutes: : Fur Products Labeling Act, ' 65. Stat. 175, 15 U. S. C. - Page’ : 26> AML te ceanheheauiwekidnienen 2,7, 10, 11, 13, 24 / ' Section a oa. be iesea oe ‘emis Sot 7, 24, ie StS ere alice iy F heenine cacaken tae 10, 24 Sention He) ¥ Q KER rs se ‘ , } ; \ e ° p Me ; \ ° ® eo, In the Seren Gout of the tad Sues a : OcTOBER TERM, 1958 — : PepEray TRADE Comnsissi0%, PETITIONER v SN sede RS ee ee Se aici aaata INc. $+ & PETITION FOR A WRI 9 OF CERTIORARI TO THE UNITED STATES er: - AFFEAIA FOR THE SEVENTH OIROUIT | j “The Solicitor, General, on ‘be of: the Federal _ Trade. Commission,: prays that a writ of certiorari 3 issue to review that part of the judgment of the. . - United States Court of Appeals for the Seventh Cir- ciit, entered in the above’ eause on April i, 1958, which modified the Commiission’s 8 cease-and- desist order. OPINION BELOW The opinion of the Court of Appeals (Appendix i ) infra, pp. eaayita is reported : at 254 F. 2d 18. 4 . : e ‘ JURISDICTION | ‘The ‘udeient of the Court of Appeals moditying: the Comrhission’s.ordér, and affirming it as modified, _was entered on April 1, 1958 (Appendix B, infra, p. 22). The court’s final decree, enforcing the order as modified, was entered May 8, 1958. The time for (@) 3 — — ———== filing a petition for a writ of certiorari was extended by Mr. Justice Clark on June 25, 1958 to July 30, .1958 (Appendix ©, infra, p. 23). ~The jurisdiction. ‘of this Court is invoked under 28 U. 8. C. 1254 oA (1). QUESTIONS PRESENTED 1. Whether aaa at the retail level are ‘outside the , _ Scope of the provisions of the Fur Produets Labeling '. Aet prohibiting false and. deceptive invoicing. = ~~ ~-9>"Whether the Federal Trade Commission, -in-is- suing cease-and-desist orders against failure to label. fur prodiicts properly, is confined to proseribing “the the precise labeling omissions which it found. _ STATUTE INVOLVED _ The’ relevant portions of the Fur Products talk 3 ae Act, 65 Stat. 175, 15 U. & ©. 69, et seq., are set - forth i in freee infra, pp. 24-28. ‘STATEMENT - - \ On October 27, 1955 the Federal Trade ‘Chantisatontens issued a complaint, charging that respondent, which ; operates a large department store in Chicago, Thi/ _ nois, had .violated the Fur Products Labeling Act - (App. 2-8).". After full administrative proceedings, the Commission, adopting the examiner’s findings (with: minor modifications), found that respondent had violated the Act as charged, and entered. a cease- - and-desist order. The principal violations: found were ' misbranding, false and deceptive invoicing, and false ' advertising. ‘The Court-of Appeals modified the order ; *“App. ,. peters. to the appendix to respondent’ brief ig the Court of oo tig, ot » o ‘ “ar two-important 1 aati, and affirmed and ved _ its other provisions. ‘The court eliminated the pro- _ hibition against false and deceptive invoicing, on the ground that the Act does not “invoices given 9, retai customers; and it held that the Prohibitions - against misbranding were too broad. . : Section 3. (a) of the Act (15 U. S. C. 69a (a). product which is misbranded or falsely or deceptively ‘advertised _or_ invoiced *.* *7?; and Section 3 (b)- (15 U.S. C. 69a (b)) Taakes it unlawful to’sell “any fur product which is made_in whole or in part of fur ‘which has been shipped and received in commerce, and which. is misbranded or falsely or deceptively ad- . vertised oF invoiced * * *.” Section 5 -(b) - (5 af S.C. 69¢ (b)) provides that a fur product or fur is falsely or deceptively invoieed if the “invoice” does not show (A) the name of the aninial that pro; duced the fur; where applicable, (BY that the produet contains used fur, (C) cpiviaits. bleached, dyed, or _or substantial part of paws, tails, bellies, or “waste . fur; (E) the “name and address”’ of the person issu- _jng such invoice; and (F) the country of. origin of any imported furs. Section 2 (f) of the Act (15 U.S.C. 69 (f)) defines ‘‘invoice”’ as “a written account, memo- commercial dealing in fur produets or furs, and “de- scribes the particulars of any fur products. or furs, ; transported or delivered to a purchaser, consignee * srg . makes it unlawful to sell “in commerce * * * any fur” artificially colored fur, or (D) is composed in whole. : randum * * * which ‘is. issued: in connection with any 3 4 cae. eae or any viii person sete is engagec in dealing commer- - cially in fur products or furs.’’ | _. Section 4 of the Act (15: U4 8S. C. 69b). vactides that a fur product i is misbranded if (1) it is “ “falsely or deceptively labeled * * * or identified,” or (2y there is not affixed a label setting forth six specific - categories of information. whigh. are substantially ~ identicat to-those-which Section 5 (b)-requires to be set forth-in ‘the i invoice (except that Section 4 (2) (B) _ requires the label to show the name of the person who _tnanufactures the fur product, rather than the ‘‘name. and address ” of the person issuing the patent The Invoicing Violations | "The Commission found that respondent liad vio- _- lated: the invoicing provisions of the Act because its invoices did not show its address and, in several in- stances, failed. to set forth. the’ correct name of the animal produeing the fur and did not disclose that the fur -was. bleached, dyed, or otherwise artifically colored. -The Commission rejected respondent’s con- tention that the Act is not applicable to retail invoic- ing. It stated (App. 147). that “a prime purpose, of . the Act was .to eliminate deceptive invoicing at the - consumer level’’; that it has ‘consist r construed . the statute’s proneribtions against falseind deceptive » invoicing to extend to invoices or sales slips furnished by retailers t* the purchasing consumer’’; and ‘that ' respondent’s cont¢htion would “render the Act. in- effective in a majoraéspect®’ ayes The Court of Appeals eliminated the prohibitions relating to invoicing, on the ground that under the : ; & ° % : 5 dai a sajea_siip given: to a retail cuales not an “tinvoies’’ (Appéndix A; infra, pp. 19-20). The court ruled that an invoice “must be something issued in connection with a commercial dealing to a purchaser -.; or any other person who is engaged in dealing com- ie mercially’ ‘in furs, and that, “[u]nder no circum- . stances is a sales slip given to a customer by the re- : tailer * * * issued.in cénnection with a commercial | dealing.’? The .court refused to“consider r the legis- : lative history of the Act, on the ground that when- statutory language js “clear apd unambiguous its legislative history cannot contiee the aaa eral tion 8 8 87 -_ ’. The Labeling Violatigne— The Commis$ion found: the, talleuine violations of _ the Act’s labeling requirements: 12 instances of fail- “ure to label the product with the correct name of the - animal producing the fur (Section 4 (2) (A)), 15 _ instanees “of failure to disclose that the product was ; bleached, dyed or otherwise artificially colored (Sec- tion 4 (2) (C)), and 58 instances of failure to show - the country of origin of imported furs (Section 4 (2) ' (F)). The Commission furtliér found 187 viola- . tions of its rules which provide additional labeling | requirements.’ The‘. Commission held (App. 158), — however, that there was “no ‘evidence that. the labels — vaffixed to respondent’s fur products were deficient in — that. they failed to disclose’ that the fur products were — ; *In 9 instances, required’ information was improperly set forth in abbreviated form; in 59 instances, non-required in- formation was mingled with required information ; and’ in 119 instances, ‘required — was set forth. in oe ie ; : Reet : : ae he . composed of used fur, i: liad atta, Ot sli rt tails, bellies, or. waste fur, or that they failed to dis- close respondent's name Sn _ Althongh the ¢examiiner recommended that the cease-and-desist order be limited to the three. cate- py of information found to have been omitted, the Commission’s order directed respondent to cease and. desist from “Misbranding fur produets by: * * * - Failing .to a affix labels to fur prodyets showing”’ the six categories of information required by Section 4° (2) (App. 159-160). The Commission stated. (App. 154) that ‘‘[u]nder the Act a fur product is mis- brended * * * unless it has attached to. it a label set- ting forth clearly and conspicuously all the data in-— dicated as. necessary to be included thereon. by Sec- ° tion 4 (2): that, the subsections “do not deal with _ Separate violations in afid of themselves” (ibid.) ; and that “in any case in which it is-found that the label- ‘ing * * * requirements * * * have not been fully ~ complied with, the appropriate conclusion: is that the fur products in connection with which the deficiencies have occurred have been misbran | * * * and that the appropriate order to be issued in correction of the offense is one requiring cessation of the practice, _ namely, the misbranding * * * by failure te attach Ps ah a (App. 155). : ens _ to pn scope of he order evil panty ut ih ae Tt enjoined respondent. from failing to furnish invoices con- ipining fin, six. setaanrien of inicepation veanisnd by, Gieghct ‘(App. 160), even though it found (App. 158) that there Ser “no evidence” "Sik Gondin ak Baan Cismorie Wed tome oe. - Iated. Since the Court of Appeals held that the part of thé The Court of Appeals struck from ‘the order the — prohibitions against the three categories as to which no violations were found, (Appendix A, infra, pp. 18— 19). Although stating it acvepted the “doctrine that a - cease and desist order does not have to be limited to eat! the illegal.practice in the precise form it is. ‘found to : exist or that those caught violating the Act must.ex- pect some fencing in,’’-the court-refused to “affirm ~ an order requiring one.to cease and desist from doing ! that which the Commission a sppeitealiy toned it did ae not do,’’ 2 & eee . | RRASONS FOR Gn: THE WRIT " _1In holding that aii ‘given by. retailers of : fur products ‘to the ultimate consumer are not “‘in- voices’’ subject to the disclosure requirements. of the Fur. Products Labeling Act, the court below has . adopted a construction .of the Act—a clearly errone-. + ous. constructions.,we believe—which; unless reversed by this Court, will seriously frustrate a. ptineipal. purpose of the Act and substantially limit the pro- tection against misbranding afforded by Cenerew ¢ bad purchasers | of fur products.. Bie 3! Section 3 makes it unlawful (inter alia) to sell “any fur product which is made in whole or in part of fur which has been shipped and received in com- 3 theree, and which is * * * falsely or deceptively * * * invoiced * ** *.’? Section 2.(f) of the Act defines “invoice”? ag “a Written account, memorandum, list, or order dealing with the invoicing violations was beyond the _Commission’s statutory ee it did not reach the ques-" tion of its scope. ae a ae Cree, Ya + @ ,° ° - : “ . ‘ Be Si migr cy . ° = a J ° : pene ‘ 2 / 8. oF epi s ff . =? -- “ i - Vs ‘ ; : catalog, ‘whieh is issued in cniniitleas with any com: " vaercial dealing in fur. products or furs, and describes _ the particulars of any fur products or furs, trans- ported or delivered, to a purchaser, consignee, factor, bailee, correspohde it, or agent, or any other person - who is engaged in dealing. commercially, in fur prod- | - -uets or furs.”’ -The court below held that under thit” definition an\* “invoice” must be. something issued in: connection with a aetions-—as Section. 3 has done (De Gorter v: Federal Trae Commission, 244 F, 2d 270 (C. A. 9))—and_ . yet to have denied, retail customers the same protec- . tion against false. i invoicing. The Commission ‘“‘has nsistently * construed the statute’ s -proscriptions dinst false and deceptive » invoicing to extend ‘to in-' voices or sales slips furnished by retailers to. the pur- _ehasing eonsumer’” (App. 147).° As the Commission - a, At the hearings on a predecessor bill, (substaptially identi- cal. with: that’ which became ‘the Fur Products Labeling Act), there : was extensive discussion of the need for requiring that j the retail level affirmatively disclose pertinent in- learing ‘before the House Committee on Inier- ‘state and. ign Commerce*on H. R. 3734, 80th Cones 3d sess., at pp. 119}.120,-123, and 156-157. 7” *The title of a statufe may be ccnsidéred in resolving amn- ‘biguity. Knowlton v. "Mbore, 178 U.'S. 41,65; White v. United States, 191 Be Ss. foe 550; See also Fehton v. 7 hone & Co., [1908] A. 447 (HL. L.) ‘©This = and also in Federal Trade Commission v. National | Lead'Co,, 1957, 352 U. 8, 419, 431 ‘‘that those caught | violating the "Act must expect some fencing in.’ . However, here the-Commissidn specifically found, that - | there was no evidence of any violation of subdivisions _ (B), (D) and (E) of §4 (2). We-find no difficulty . in subscribing to the doctrine that a cease and desist order does not have to be limited-to the illegal prac- tice in thé precise form it is’ found to exist or that _. .-these caught violating the Act must. expect, some f fene- + ang in but we cannot affirm | an order requiring one to~ cease wd desist from. ro that which the Cotmmis- _sion specifically found it did not do. ? .*-The petitioner concedes that it has. violated subdivi- sions (A), (C) and. (F). of §4 (2) and Rules 4 and. nn ge 29 promulgated under §8 (a) (2) (b). Ht attempts to excuse its violations-upon the ground that they are . technical and trivial. “If such an excuse were valid __the enforcement of the ‘Act would be ‘Trhaelly impos- ‘sible. In,this wefind no merit. - The Commission contends that when Meat failed to place certain information upon the sales slip given to the consumer that constituted a violation of §3 (b). of the Act. Petitioner argues that a sales slip is not an “invoice’’ within the meaning of the. Act: © The. word “‘invoice’’ -has an accepted meaning in the | “commercial world, It is a written account or itemized _ statement of merchandise shipped or sent to a pur- _ chaser or consignee with the quantity, value or prices and charges set, forth. . However, the Fur Products Labeling Act defines the term and we must. took to Soe ‘that definition for its meaning. © | Section 2.(f) of the Act defines ‘ to include in its cease and, desist order Mandel’s .of- , fice~s, tepresentatives, agents and employees. ; | : The cease and desist order here under: review is hereby ordered :modified by deleting therefrom sub- divisions (b), (d) and (e) of subsection 1 of A and all of B. ; | The order as 8 movie i is AvriaMen. : SL ae _ APPENDIX B. , ° ‘3 Untrep Srares Cover oF APPEALS Fon 1 THE Seventa Crroyrt ‘Curcaco 10, ILi1Now, - | | Tuesday; April 1, 1958. Before ‘eee F. Brax Durry, Chief Jydge; Hon. Exmer J. ScHNACKENBERG, Circuit et tec WwW. Lrmn PARKINSON, Circuit Judge. ~ ae No. 12128 Manpvei Brorners, INC., A GORPORATION, PETITIONER FEDERAL TRADE peer aaprONDEN? omonnnemel = PETITION TO SET ASIDE AN ORDER OF THE ‘FEDERAL ‘TRADE | COMMISSION | ‘This cause came on to be heard or Gervais ‘to review and’.set aside an order of the Federal Trade Commission, and the transcript of record ' Federal Frade Comuaniqaion, and was’ 7 sel. On consideantion whereof, it - ‘is ‘onde \.. judged: by. this Court that the cease and desist order \ here under review be modified by deleting therefrom ‘subdivisions (b), (dy,-and (e) of subsection 1 of A and all of B, and the ‘said order as modified is (2) ee am. °°. , APPENDIX "esheets _ Scrmcn Covnr of rae Use Sats Cre! 2 Tea, 1967 ' ORDEB EXTENDING mT to Pus HerrION FOR WRIT OF ° Upon consideration of the application of counsel for — petitioner, yen: _. It ts ordered that the time for filing petition. for ° writ of ‘certiorari in the above-entitled cause be, and - the same is. hereby, extended: to’ and praising J ruly : 30th, 1986. /s/. Tom’C. rasa ie camepaie raetios of the Supreme Court , of the United States. wie this 25th day of June 1966 (28) . : saan p The Ray Products iseias’ Act, 6 Stat. 175, 15 “Uv. 8. C. 69, et $e: provides in pertinent sane as. follows: is SECTION 2. As used in this/Act—’ ic + aaa * (f) The term “invoice” means.a written ac- . count, memorandum, list, or catalog, wliich is _ issued in connection. with any commercial deal- . ing in fur products or furs, ‘and describes the particulars of any fur products or furs, tratis- . ported or delivered to a purchaser, gp gt _ factor, bailee, correspondent, or agent, or other _person who is engaged in’ dealing San - mercially in fur products or furs: [15 U. S.C. OP DAES pipes a SKOTION Gita: (ate - > (a) The introduction, or eco for in- troduction, into commerce, or the sale, adver- =, tising or offering for sale in commerce, or the. ' transportation or. distribution in. commerce, of any fur product which is misbranded ‘or falsely or deceptively advertised or invoiced, within. the meaning of this Act c~ the rules and regu- lations prescribed: under section 8 (b), ‘is un-~ lawful and shalhbe an unfair. method of competi- | tion, and an unfair and deceptive act or practice, in commerce under the Hederal: Trade Commis- sion et (24) _ (b) “The maiuifacture for sale,’sale, advertis- ‘ing, offering for -sale,. transportation of” dis- tribution, of any fur product which is made : a aD a : 25 : Res. papa y PT IE Ree ST CU in whole or in part of fur which has been. shipped and received in commerce, and: which — is aisteabed or falsely or deceptively. adver- “tised or invoicedywithin thé meaning of this Act. or the rules and regulations prescribed under ~~ _ section 8 (b), is unlawful and,shall be an unfair a5 " méthod of eompetition, and an unfair and decep- tive act or practice, in commerce under the Fed- eral Trade Commission Act. : (ce) The introduction into: eeu or. the ° ‘gale; advertising or offering for sale in com- merce, or the transportation or distribution in - commerce, of any fur whith is falsely or decep-" tively advertised or falsely or deceptively ing voiced, within the méaning of this, Actor the rules and regulations prescribed uaeder section | 8 ¢b) is unlawful and‘shall be an unfair method) *. of. competition, and an unfair and deceptive act — or practice; in commerce under the Federal Trade— — Act. [15 U.58. C. 69a] ae 5 ae ea f _* 2 scent ee For the purposes - af this Act, a fur shisitack shall be considered fo be misbranded— — (1) if it is falsely or deceptively labeled or ‘ otherwise falsely or deceptively identified, or’ ~ # the label contains any form of misrepresen- tation .or. deception, directly or by implication, with respect to such fur product; —- (2) if-there is not affixed to the fur product © : a label ‘showing in words and age ee ‘. © legible— « ie ps ; . E ; 26. iy (A) the name or nanies (as “get forth i in the. eee _ Pur Products Name Guide) of the animal or eo _ animats that produced the fur, and such quali- _ ' fying statement as,may be required, — NE to section'7 (6) of this Act; “Fegay -(B) that the fur product cqntains or is-com- pre nei of used. fur, when such-is the fact; j aim Dali, that the fur product contains or is com-. ., + .+-posed of bleached, dyed, or otherwise artifi- # ' -@iaHy colored fur, when such is the fact; ~ | _ “(D) that the. fur product is composed i whole or in substantial part. of. paws, tails, bellies, or waste fur, ‘when' such is the fact; A (E). the name, or other identification issued <> and registeréd. by the Commission, of one or : — _. more of the: persons who manufacture such . “s fur produet for introduction into commerce, . % . introduce it into commeree, sell it in commerce, * advertise. or offer it fér sale -in commerce, or - _ transport or distribute it in commeree ; eae (F) the name of the country of-origin of any imported furs used in the fur product; (3) if the label required by paragraph (2) (A) of this section sets forfh the name or names ‘ of any animal or animals other. than the _ or names provided for i in “nh paragraph. ft ‘y U.S, C-69bj . ; Section 5: ‘ (a) For the. purposes of this Act, a fur prod- -- ‘yet or fur shall be considered to be falsely or de- f ceptively advertised if any advertisement, repre- | “sentation, public announcement, or notice which (we is intended to aid, promote, or assist directly or indirectly in: the sale or offering tay sale of such fur product or fur— (1) does not: show the name or names (as set "forth i in the, Pur Prod” ote, Name Guide) of the, ae . 's es ye & Ws Sarg y ? ies: ° Sy ‘6 bas : % oF . P eo * ; ‘ H > . 7 .? ee em | Y . . animal or animals that produced the fur, and 25d such qualifying statement as -may be required pursuant to sectién 7 (e) of this Act; : (2) does not show that the fur is used fur oF that thé fur product — used. ™. when : such is the fact; (3) does not show that ir’ Sek: Yootat: ox. oF oe fur’ is bleachéd, dyed, or otherwise’ ereeeialiy es, " eolored fur whien stich ig the fact ; oe (4) does not ‘Show. ‘that the fur product is‘ . gompased in-whole or. in ‘substantial part: of : paws, tails, bellies, ‘or waste fur, when such is. ' the fact; : (5) contains the name or names of any ani- | : ‘mal or animals other than the name or names | s _ specified in paragraph: (1) of this subsection, ‘or contains any form of misrepresentation or "e - deception, directly oF by. implication, with re- - 7 mens tosuch fur product or fur; (6). does not ‘show the name of the oanteey a origin. of - any imported furs or those con- tained in a fur product. © (b) For the purposes of this Act; a fur widen or fur shall be eongidered to.be falsely lecep- . ’ tively invoiced ; A (1) if sueli fur product or, for i 18 not coast ; to show—.. .- -{A) the name, or names (as set forth in in the Fur Products Name Guide) of the animal or animals that produced the fur, and suth quali- fying statement as‘may be required pursuant to section 7 (¢) of this Act; * (BY thajathe fur product contains or is com- iy ‘posed of uSed fur, when ‘such is the fact; -(C) that the fur product contains or is com- | posed of bleached, dyed, or otherwise anata . @olored far; when such is the fact; : ase S wv . ei . ‘suing such invoice ; -. nanfes of any animal or animals other than the. . Ps s 7 - a Rekis 3 ’ . 2 : ‘(D) that the fur wecdindt is cea ie - whol or in substantial part of paws, ~~ bellies, or waste ‘tur, When such is the fact: _(E) the name and address of the pers person is- © .(F) the name of the country of origin of any ‘imported furs’ or ‘those contained in a fur 3 produet ; (2) if such invoice nested the name or name or names speeified in paragraph (1) soil of this subsection, or contains any form of representation or deception, directly or by | implication, with -respect to. wach fur product or fur. 1300: BS Oe | ui a . | j 2 j . : s a . ° ‘ e \ > . ©, &. COVERSNERT PRIKTING OFFICE .1988 2 . ‘ ~ « i . ‘ . . . 0 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386409_0154%3A1. Public record. Not legal advice.