# Roger J. Callahan; Analysis To Aid Public Comment > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3A98-1361 ## Record - **Collection:** Federal Register - **Document type:** Notice - **Published:** January 21, 1998 - **Citation:** 63 FR 3128 ## Text FEDERAL TRADE COMMISSION [File No. 942-3278] Roger J. Callahan; Analysis To Aid Public Comment AGENCY: Federal Trade Commission. ACTION: Proposed consent agreement. ----------------------------------------------------------------------- SUMMARY: The consent agreement in this matter settles alleged violations of federal law prohibiting unfair or deceptive acts or practices or unfair methods of competition. The attached Analysis to Aid Public Comment describes both the allegations in the draft complaint that accompanies the consent agreement and the terms of the consent order--embodied in the consent agreement--that would settle these allegations. DATES: Comments must be received on or before March 23, 1998. ADDRESSES: Comments should be directed to: FTC/Office of the Secretary, Room 159, 6th St. and Pa. Ave., N.W., Washington, D.C. 20580. FOR FURTHER INFORMATION CONTACT: C. Steven Baker or Russell W. Damtoft, Federal Trade Commission, Chicago Regional Office, 55 East Monroe St., Suite 1860, Chicago, IL 60603, (312) 353-8156. SUPPLEMENTARY INFORMATION: Pursuant to section 6(f) of the Federal Trade Commission Act, 38 Stat. 721, 15 U.S.C. 46 and Section 2.34 of the Commission's Rules of Practice (16 CFR 2.34), notice is hereby given that the above-captioned consent agreement containing a consent order to cease and desist, having been filed with and accepted, subject to final approval, by the Commission, has been placed on the public record for a period of sixty (60) days. The following Analysis to Aid Public Comment describes the terms of the consent agreement, and the allegations in the complaint. An electronic copy of the full text of the consent agreement package can be obtained from the FTC Home Page (for January 13, 1998), on the World Wide Web, at ``http://www.ftc.gov/ os/actions/htm.'' A paper copy can be obtained from the FTC Public Reference Room, Room H-130, Sixth Street and Pennsylvania Avenue, N.W., Washington, D.C. 20580, either in person or by calling (202) 326-3627. Public comment is invited. Such comments or views will be considered by the Commission and will be available for inspection and copying at its principal office in accordance with Section 4.9(b)(6)(ii) of the Commission's Rules of Practice (16 CFR 4.9(b)(6)(ii)). Analysis of Proposed Consent Order To Aid Public Comment The Federal Trade Commission has accepted an agreement, subject to final approval, to a proposed consent order from respondent Roger J. Callahan. The proposed consent order has been placed on the public record for sixty (60) days for reception of comments by interested persons. Comments received during this period will become part of the public record. After sixty (60) days, the Commission will again review the agreement and the comments received and will decide whether it should withdraw from the agreement and take other appropriate action or make final the agreement's proposed order. This matter concerns efficacy claims made regarding Dr. Callahan's Addiction Breaking System promoted by respondent. The Commission's complaint charges that respondent, in concert with Mega Systems, Inc., made false and unsubstantiated claims that Dr. Callahan's Addiction Breaking System (1) Reduces an individual's compulsive desire to eat, leading to significant weight loss, (2) reduces an individual's compulsive desire to eat, leading to significant weight loss without the need to diet or exercise, and (3) cures addictions and compulsions, including but not limited to, smoking, eating, and using alcohol or heroin. The proposed consent order contains provisions designed to remedy the violations charged and to prevent the respondent from engaging in similar acts and practices in the future. The proposed order extends to any weight loss product or program or any product or program purported to treat addictions or compulsions. Part I of the proposed consent order prohibits the respondent from representing that Dr. Callahan's Addiction Breaking System, or any substantially similar product or program purported to treat addictions or compulsions, (1) reduces an individual's compulsive desire to eat, leading to significant weight loss, (2) reduces an individual's compulsive desire to eat, leading to significant weight loss without the need to diet or exercise, or (3) cures addictions and compulsions, including but not limited to, smoking, eating, and using alcohol or heroin. Part II of the proposed order prohibits the respondent from representing the performance, benefits, or efficacy of any weight loss product or program or any product or program purported to treat addictions or compulsions, unless the representation is substantiated. Part III of the proposed order requires the respondent to pay fifty thousand dollars into a redress fund. The remaining parts of the proposed consent order require the respondent to maintain promotional and substantiation materials related to the claims covered by the order, to notify the Commission of any changes in his employment, and to file one or more compliance reports. The purpose of this analysis is to facilitate public comment on the proposed consent order. It is not intended to constitute an official interpretation of the agreement and proposed order or to modify in any way their terms. Donald S. Clark, Secretary. [FR Doc. 98-1361 Filed 1-20-98; 8:45 am] BILLING CODE 6750-01-M --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A98-1361. Public record. Not legal advice.