[Federal Register Volume 62, Number 213 (Tuesday, November 4, 1997)]
[Notices]
[Pages 59708-59712]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-29298]
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FEDERAL TRADE COMMISSION
[File No. 9723128]
Beylen Telecom, Ltd., Niteline Media, Inc., and Ron Tan; Analysis
To Aid Public Comment and Agreement Containing Consent Order
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement.
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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 (which is also
attached)--that would settle these allegations.
DATES: Comments must be received on or before January 5, 1998.
ADDRESSES: Comments should be directed to: FTC/Office of the Secretary,
Room 159, 6th St. and Pa. Ave., NW., Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Eileen Harrington, Federal Trade
Commission, H-238, 6th St. and Pennsylvania Ave., NW., Washington, DC
20580. (202) 326-3127. Paul Luehr, Federal Trade Commission, H-238, 6th
St. and Pennsylvania Ave., NW., Washington, DC 20580. (202) 326-2236.
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 (which is
also attached) and the allegations in the accompanying complaint. An
electronic copy of the full text of the consent agreement package can
be obtained from the Commission Actions section of the FTC Home Page,
on the World Wide Web, at ``http://www.ftc.gov/os/actions97.htm.'' A
paper copy can be obtained from the FTC Public Reference Room, Room H-
130, Sixth Street and Pennsylvania Ave., NW., Washington, DC 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, subject to final
approval, an agreement containing a consent order from Beylen Telecom,
Inc. (``Beylen''), NiteLine Media, Inc. (``NiteLine''), and Ron Tan
(``Tan''). NiteLine and Tan have solicited consumers to download viewer
software over the Internet in order to view computer images. Beylen has
provided telecommunications and other services to NiteLine and other
``audiotext'' entities that use telephone calls to provide information
to, and collect money from, consumers.
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 or make final the agreement's proposed
order.
This matter concerns allegations about the manner in which
respondents solicited and billed consumers to use a software program to
view adult images on the Internet. The Commission has issued a proposed
draft complaint that sets forth the allegations to be resolved by the
proposed administrative consent order. The draft complaint closely
parallels the Commission's federal court complaint and amended
complaint filed in FTC v. Audiotex Connection, Inc. CV-97 0726 (DRH)
(E.D.N.Y. filed Feb. 13, 1997) against defendants allegedly engaged in
activities similar or related to those of the respondents. The proposed
draft complaint challenges three practices of the respondents. First,
the draft complaint alleges that respondents NiteLine and Tan
misrepresented that consumers could view adult images at no cost if
consumers downloaded and used the respondents' purported ``viewer''
software. Second, the draft complaint alleges that respondents NiteLine
and Tan failed to disclose or adequately disclose material aspects of
the ``viewer'' program, including that the program would shut off a
consumer's modem speakers, cut off the consumer's modem connection to
his local Internet service provider, and automatically place an
international telephone call from the consumer's modem to a remote
Internet site. The draft complaint alleges that Beylen violated the law
by
[[Page 59709]]
providing the ``means and instrumentalities'' to carry out the two
types of practices just described. Finally, the draft complaint alleges
that respondents Beylen, NiteLine, and Tan caused consumers to receive
deceptive telephone bills for calls that purportedly went to Moldova in
Eastern Europe, when they actually only went to Canada.
The proposed administrative consent order, published for comment
with this notice, again closely parallels the consent order proposed in
FTC v. Audiotex Connection, Inc. CV-97 0726 (DRH) (E.D.N.Y.). The
proposed administrative consent order contains prohibitions designed to
prevent respondents from engaging in similar acts and practices in the
future. The proposed administrative consent order also contains
monetary provisions designed to redress injury to consumers.
Sections I and IIA of the proposed order prohibit respondents from
engaging in the types of activity alleged in the draft complaint. Part
IIB of the proposed order requires the respondents to obtain written or
contractual assurances from third parties that calls will go to the
destination for which charges are assessed on a consumer's telephone
bill.
Section III requires the respondents to contribute to a redress
fund established pursuant to the consent order proposed in FTC v.
Audiotex Connection, Inc. CV-97 0726 (DRH) (E.D.N.Y.). Money from this
fund is to be paid to long-distance carriers so that they can issue
credits to consumers through their telephone bills. A portion of the
redress fund also is be paid to the FTC so that the Commission or its
agent can refund some consumers directly.
Sections IV, VI, and VIII require the respondents to maintain
copies of business records related to using the Internet to place
international long-distance telephone calls; to provide copies of the
order to certain of the company's personnel; to notify the Commission
of any change in employment or corporate structure that might affect
compliance with the order; and to file compliance reports with the
Commission. Section VII forbids the defendants from distributing any
version of their ``viewer'' program to third parties.
The proposed administrative consent order does not contain a
``sunset'' provision that would terminate the order twenty years after
it is issued or after a complaint is filed in federal court.
The purpose of this analysis is to facilitate public comment on the
proposed order. It is not intended to constitute an official
interpretation of the agreement and proposed order or to modify in any
way their terms.
Beylen Telecom, Ltd. and Niteline Media, Inc., corporations, and Ron
Tan, individually and as an officer of Niteline Media, Inc.
Agreement Containing Consent Order
The Federal Trade Commission has conducted an investigation of
certain acts and practices of Beylen Telecom, Ltd., NiteLine Media,
Inc., corporations, and Ron Tan, individually and as an officer of
NiteLine Media, Inc. (``proposed respondents''). Proposed respondents,
having been represented by counsel, are willing to enter into an
agreement containing an order resolving the allegations contained in
the attached draft complaint. Therefore,
It is hereby agreed by and between Beylen Telecom, Ltd. and
NiteLine Media, Inc., by their duly authorized officers, and Ron Tan,
individually and as an officer of NiteLine Media, Inc., and counsel for
the Federal Trade Commission that:
1a. Proposed respondent Beylen Telecom, Ltd., is a corporation
organized, existing and doing business under and by virtue of the laws
of the Cayman Islands with its principal office or place of business at
Genesis Building, PS Box 2097, Grand Cayman, Cayman Islands, British
West Indies.
1b. Proposed respondent NiteLine Media, Inc. is a New York
corporation with its principal office or place of business at 7302 19th
Avenue, Brooklyn, New York 11204.
1c. Proposed respondent Ron Tan is an individual residing within
the State of New York and is an officer and shareholder of NiteLine
Media, Inc. Individually or in concert with others he formulates,
direct, or controls the policies, acts, or practices of NiteLine Media.
His principal office or place of business is the same as that of
NiteLine Media, Inc.
2. For the purpose of this Order, proposed respondents admit all
the jurisdictional facts set forth in the draft complaint.
3. The proposed respondents waive:
(a) Any further procedural steps;
(b) The requirement that the Commission's decision contain a
statement of findings of fact and conclusion of law;
(c) All rights to seek judicial review or otherwise to challenge or
contest the validity of the Order entered pursuant to this agreement;
and
(d) Any claim under the Equal Access To Justice Act.
4. This agreement shall not become part of the public record of the
proceeding unless and until it is accepted by the Commission. If this
agreement is accepted by the Commission, it, together with the draft
complaint, will be placed on the public record for a period of sixty
(60) days and information about it publicly released. The Commission
thereafter may either withdraw its acceptance of this agreement and so
notify proposed respondents, in which event it will take such action as
it may consider appropriate, or issue and serve its complaint (in such
form as the circumstances may require) and decision in disposition of
the proceeding.
5. This agreement is for settlement purposes only and does not
constitute an admission by any of the proposed respondents that the law
has been violated as alleged in the draft complaint, or of any
wrongdoing whatsoever, or that the facts as alleged in the draft
complaint, other than the jurisdictional facts, are true.
6. This agreement contemplates that, if it is accepted by the
Commission, and if such acceptance is not subsequently withdrawn by the
Commission pursuant to the provisions of Section 2.34 of the
Commission's Rules, the Commission may, without further notice to
proposed respondents, (1) issue its complaint corresponding in form and
substance with the attached draft complaint and its decision containing
the following Order in disposition of the proceeding, and (2) make
information about it public. When so entered, the Order shall have the
same force and effect and may be altered, modified, or set aside in the
same manner and within the same time provided by statute for other
orders. The Order shall become final upon service. Delivery of the
complaint and the decision and Order to proposed respondents' attorneys
as stated in this agreement by any means specified in Section 4.4(a) of
the Commission's Rules shall constitute service. Proposed respondents
waive any right they may have to any other manner of service. The
complaint may be used in construing the terms of the Order. No
agreement, understanding, representation, or interpretation not
contained in the Order or in the agreement may be used to vary or
contradict the terms of the Order.
7. Proposed respondents have read the draft complaint and the
following Order. They understand that they may be liable for civil
penalties in the amount provided by law and other appropriate relief
for each violation of the Order that occurs after it becomes final.
[[Page 59710]]
Definitions
For purposes of this Order, the following definitions shall apply:
1. ``Beylen'' means Beylen Telecom, Ltd. and its successors,
assigns, shareholders, officers, agents, servants, employees, and those
persons in active concert or participation with them who receive actual
notice of this Order by personal service or otherwise, whether acting
through any corporation, subsidiary, division, or other device.
2. ``NiteLine'' means NiteLine Media, Inc. and its successors,
assigns, shareholders, officers, agents, servants, employees, and those
persons in active concert or participation with them who receive actual
notice of this Order by personal service or otherwise, whether acting
through any corporation, subsidiary, division, or other device.
3. ``Ron Tan'' means Ron Tan a/k/a Roeun Tan, individually, and in
his capacity as an officer and shareholder of NiteLine Media, Inc., and
his successors, assigns, officers, agents, servants, employees, and
those persons in active concert or participation with them who receive
actual notice of this Order by personal service or otherwise, whether
acting through any corporation, subsidiary, division, or other device.
4. Unless otherwise specified, ``respondents'' shall mean Beylen
and NiteLine, corporations, their successors and their officers; Ron
Tan, individually and as an officer of NiteLine; and each of the
above's agents, representatives and employees. Unless otherwise
specified, ``respondent'' shall mean NiteLine, Ron Tan or Beylen.
5. ``Commerce'' shall mean ``commerce'' as defined in Section 4 of
the Federal Trade Commission Act, 15 U.S.C. Sec. 44.
6. ``Clearly and Conspicuously'' shall mean as follows:
In an advertisement communicated through an electronic medium (such
as television, video, radio, and interactive media such as the Internet
and online services), the disclosure shall be presented simultaneously
in both the audio and video portions of the advertisement. Provided,
however, that in any advertisement presented solely through video or
audio means, the disclosure may be made through the same means in which
the ad is presented. The audio disclosure shall be delivered in a
volume and cadence sufficient for an ordinary consumer to hear and
comprehend it. The video disclosure shall be of a size and shade, and
shall appear on the screen for a duration, sufficient for an ordinary
consumer to read and comprehend it. In addition to the foregoing, in
interactive media the disclosure shall also be unavoidable and shall be
presented prior to the consumer incurring any financial obligation. The
disclosure shall be in understandable language and syntax. Nothing
contrary to, inconsistent with, or in mitigation of the disclosure
shall be used in any advertisement.
7. ``Document'' is synonymous in meaning and equal in scope to the
usage of the term in Federal Rule of Civil Procedure 34(a), and
includes writings, drawings, graphs, charts, photographs, audio and
video recordings, computer records, and other data compilations from
which information can be obtained. A draft or non-identical copy is a
separate document within the meaning of the term.
8. ``David.exe'' means a software program that, as alleged in the
Commission's draft complaint, a respondent has promoted, offered,
distributed, or provided on web sites as a ``viewer,'' which consumers
may download, install, and execute, and which dials an international
long-distance telephone number for which a fee is charged.
9. ``Eligible Consumer'' means a telephone subscriber that was
billed for international long distance calls to Moldova from December,
1996 through February, 1997 to one of the telephone numbers listed in
Schedule A, annexed hereto.
10. ``Relevant Charges'' means the dollar amount billed by AT&T,
MCI, Sprint or another long distance carrier to an Eligible Consumer
for international long distance calls to Moldova from December 1996
through February 1997, to one of the telephone numbers listed in
Schedule A, annexed hereto.
I.
It is therefore ordered that, in connection with using the Internet
to place international long distance telephone calls, each respondent
shall not violate Section 5(a) of the FTC Act, 15 U.S.C. Sec. 45(a) by:
A. Representing, either directly or by implication, that consumers
may download, install, activate or use a computer software program to
view computer-stored images without cost, unless there are no costs to
consumers arising from such activity.
B. Representing, either directly or by implication, that a consumer
may view computer-stored images by downloading, installing and
activating a software program known as ``David.exe'' or any other
substantially similar software, unless such respondent clearly and
conspicuously discloses, in close proximity to the representation, any
material facts concerning costs and consequences to a consumer that
result from downloading, installing, and activating such software,
including, but not limited to, the following:
1. That the consumer's computer will terminate its modem connection
to the consumer's usual Internet service provider;
2. That the consumer's modem will dial an international long-
distance telephone number and establish a long-distance telephone
connection with some remote location outside the United States;
3. (a) A statement that ``International long distance telephone
charges to [insert country of call termination] apply''; and
(b) Either:
(i) a statement that ``This call may cost you as much as [insert
the maximum estimate of possible per-minute tariffed charge available
through one of the three largest U.S. long-distance carriers (e.g. MCI,
Sprint or AT&T; hereafter ``a major U.S. carrier'')] per minute''; or
(ii) a stated range of possible costs-per-minute for the call,
where the maximum possible per-minute charge available through a major
U.S. carrier is disclosed at least as prominently as any lower estimate
of possible charges, and the lower estimate is based on a non-
promotional standard tariffed charge available through a major carrier,
and there is a clear and conspicuous disclosure of the following
statement: ``To determine your exact per-minute charges, contact your
long distance carrier.''; and,
4. That, once connected, the consumer's computer modem will not
terminate the international long-distance telephone connection to the
remote service provider unless and until: (a) the consumer terminates
the connection by using a ``disconnect'' feature that is displayed on
the screen throughout the connection; OR (b) the call is terminated
automatically after some specific, stated period of time (e.g. after 5
minutes); OR (c) the consumer turns off the power switch to his
computer or modem, or takes other drastic and unusual action to
terminate the telephone connection, if neither (a) nor (b) above are
applicable.
II.
It is further ordered that:
A. Each respondent shall not violate Section 5(a) of the FTC Act,
15 U.S.C. Sec. 45(a) by directly causing international long-distance
charges to appear on the telephone billing statement of any consumer
when such call does not, in
[[Page 59711]]
fact, go to the international destination for which charges are
assessed; and
B. Each respondent, when contracting with any entity for
international call charges to appear on any consumer's telephone bill,
shall include written terms in such contract requiring calls to go to
the destination for which charges are assessed on a consumer's
telephone bill. If, at the time of the entry of this Order, a
respondent has an existing contract with another entity that arranges
call charges to appear on any consumer's telephone bill, the respondent
may satisfy the requirements of this Section by obtaining from that
entity a letter or other written assurance that calls go to the
destination for which charges are assessed on a consumer's telephone
bill.
III.
It is further ordered that:
A. Pursuant to the Consent Decree and Order proposed in FTC v.
Audiotex Connection, Inc., CV-97 0726 (DRH) (EDNY) (``the Consent
Decree''), and after the entry of such Consent Decree, Eligible
Consumers charged by AT&T or MCI for telephone calls involving
David.exe shall, to the extent possible, receive a credit on their
monthly telephone bill equal to the amount of the Relevant Charges. To
the extent an Eligible Consumer has already been credited such an
amount in full, no additional credit shall be extended. To the extent
an Eligible Consumer has received a partial credit, only the remaining
balance of the original Relevant Charge shall be credited. The process
for issuing the credits to Eligible Consumers will be administered by
AT&T and MCI, respectively, and monitored and/or audited by the FTC.
The reasonable costs of the two carriers arising from the issuance of
credits for the Relevant Charges and from such administration of
credits shall be reimbursed by the escrow agent by deducting and paying
to AT&T and MCI, respectively, the amounts stated below.
B. Pursuant to the Consent Decree and Order proposed in FTC v.
Audiotex Connection, Inc., CV-97 0726 (DRH) (EDNY), and after the entry
of such Consent Decree, a Redress Escrow Account shall be established
at a bank with a branch located in the State of New York, and Joel
Dichter, Esq., shall be designated as the sole escrow agent and
signatory to this Redress Escrow Account. In addition to the funds
deposited by the defendants in FTC v. Audiotex Connection, Inc., the
respondents shall deposit sufficient funds into the Redress Escrow
Account as are necessary to enable the escrow agent to distribute the
funds, consisting of a total deposit of all sums provided by Section
IIIB(1) and (2), below, contemporaneously with a deposit of the $60,000
provided by Section IIIB(3), in the following manner:
1. AT&T shall be distributed the sum of $660,000 toward the cost of
administering the credit to consumers provided by Section IIIA, above,
and toward reimbursement of out-of-pocket expenses associated with
calls to the Moldova telephone numbers;
2. MCI shall be distributed the sum of $99,302.57 toward the cost
of administering the credit to consumers provided by Section IIIA above
and toward reimbursement of out-of-pocket expenses associated with
calls to the Moldova telephone numbers;
3. Forty Thousand Dollars ($40,000) shall be distributed to the
Federal Trade Commission and shall be used, where practicable, to
provide redress to Eligible Consumers charged by an international long-
distance carrier other than AT&T or MCI (hereinafter referred to as
``Eligible Non-AT&T/MCI Consumers''). The Commission, in its sole
discretion, may use a designated agent to administer redress for
Eligible Non-AT&T/MCI Consumers. If the Commission, in its sole
discretion, determines that redress to consumers is wholly or partially
impractical, any funds up to Forty Thousand Dollars ($40,000.00) not so
used shall be paid to the United States Treasury. The respondents shall
be notified as to how such funds are disbursed, but shall have no right
to contest the manner of distribution. Eligible Non-AT&T/MCI Consumers
shall have 90 days from the Court's entry of the Consent Decree to
request a refund. If the Commission or its designated agent determine
within 120 days from the entry of the Consent Decree that the cost of
issuing and administering refunds to Eligible Non-AT&T/MCI Consumers
exceeds Forty Thousand Dollars ($40,000.00), the Commission or its
designated agent shall so notify the escrow agent, and an additional
sum of money not to exceed Twenty Thousand Dollars ($20,000.00) shall
be distributed by the escrow agent to the Commission for redress to
Eligible Non-AT&T/MCI Consumers. To the extent that the escrow agent is
not notified in writing by the Commission within such 120 day period
that all or a portion of the additional Twenty Thousand Dollars
($20,000.00) is required by the Commission for redress purposes, the
$20,000.00 or remaining portion thereof not required by the Commission
for redress purposes shall be released from the Redress Escrow Account
and distributed promptly by the escrow agent to any contributing
defendant in FTC v. Audiotex Connection, Inc. and/or any contributing
respondent.
C. The respondents unilaterally agree to comply with this
administrative Order after the Commission votes to accept it and during
the 60-day comment period before the Order becomes final. Should the
respondents distribute funds during that period to the Redress Escrow
Account, in amounts sufficient to commence the redress program under
the Consent Decree in FTC v. Audiotex Connection, Inc., such payment
shall fulfill the respondents' redress obligations under Section IIIB
above.
IV.
It is further ordered that for a period of three years after the
date of entry of this Order, each respondent shall maintain, and make
available to the FTC upon reasonable notice, documents that, in
reasonable detail, accurately, fairly, and completely reflect such
respondent's activities related to using the Internet to place
international long distance telephone calls including:
A. 1. Representative written and, if distributed in audio format,
audiotaped copies of all solicitations, advertisements, or other
marketing materials actually used;
2. The number, frequency, and average duration of calls to any
international, tolled telephone numbers advertised or promoted directly
or indirectly by such respondent, as well as the payments received and
payments made for such calls;
3. The portion of the contract or the other written assurance
referenced in Section IIB of this Order; and,
Records that reflect, for every consumer complaint or refund
request received from any consumer to whom such respondent has sold,
billed or sent any goods or services, or from whom such respondent
accepted money for such goods or services, whether received directly or
indirectly or through any third party:
1. the consumer's name, address, telephone number and the dollar
amount paid by the consumer;
2. the written complaint or refund request, if any, and the date of
the complaint or refund request;
3. the basis of the complaint and the nature and result of any
investigation conducted concerning the validity of the complaint;
4. each response from the respondent(s) and the date of the
response;
5. any final resolution and the date of the resolution; and
[[Page 59712]]
6. in the event of a denial of a refund request, the reason for
such denial.
V.
It is further ordered that, to enable the Commission to monitor
compliance with the provisions of this Order, for a period of three
years after the date of entry of this Order:
A. Each corporate respondent shall notify the FTC in writing,
within thirty (30) days of: (1) any reorganization, name change,
dissolution, change in majority ownership, or any corporate change that
may affect compliance obligations arising under this Order; and (2) any
affiliation with any new business entity (including but not limited to,
any partnership, limited partnership, joint venture, sole
proprietorship or corporation) in connection with using the Internet to
place international long distance telephone calls, such notification to
include: (a) the name of the business entity; (b) the address and
telephone number of the business entity; (c) the names of the business
entity's officers, directors, principals and managers; and (d) a
summary description of the business entity's intended activities; and
B. Each individual respondent shall notify the FTC in writing,
within thirty (30) days of the discontinuance of his current business
affiliation or employment with a corporate respondent, or of his
affiliation or employment with any new business entity (including but
not limited to, any partnership, limited partnership, joint venture,
sole proprietorship or corporation) in connection with using the
Internet to place international long distance telephone calls, in the
latter case such notification to include: (a) the name of the business
entity; (b) the address and telephone number of the business entity;
(c) the names of the business entity's officers, directors, principals
and managers; and (d) a summary description of the business entity's
intended activities; and
C. Each respondent shall designate its counsel as authorized to
accept service of all documents related to this Order.
VI.
It is further ordered that each respondent shall not provide or
distribute to any person, except for a court, counsel for the
respondents, counsel's consultants, agents of the Commission or other
law enforcement authorities, or others as ordered by a court of
competent jurisdiction, copies of ``David.exe'' or ``david7.exe'' or
any substantially similar software.
VII.
It is further ordered that for a period of three years after the
date of entry of this Order, each respondent shall in connection with
any business using the Internet to place international long distance
telephone calls:
A. Provide a copy of this Order once to, and obtain a signed and
dated acknowledgment of receipt of the same from, each affiliate,
subsidiary, division, sales entity, successor, officer, director,
shareholder, employee, agent or representative of such respondent; and
B. Maintain, and upon reasonable notice make available to
representatives of the Commission, the original and dated
acknowledgments of the receipts of copies of this Order required by
Section VIIA above.
VIII.
It is further ordered that where required by this Order, written
notice to:
A. The Commission shall be effected by serving papers, by personal
delivery or certified mail, addressed to: Associate Director, Federal
Trade Commission, Division of Marketing Practices, Sixth Street and
Pennsylvania Avenue, N.W., Room 238, Washington, DC 20580; and
B. The respondents shall be effected by serving papers, by personal
delivery or certified mail, addressed to: Joel R. Dichter, Klein,
Zelman, Rothermel & Dichter, L.L.P., 485 Madison Avenue, New York, NY
10022.
IX.
It is further ordered that each respondent shall, within 180 days
after the date of entry to this Order, file with the Commission a
report, in writing, setting forth the manner and form of compliance
with this Order.
X.
It is further ordered that, to the extent that this Order may
conflict with any federal law or regulation which is later enacted or
amended, such law and not this Order shall apply where such a conflict
exists. For the purposes of this Order, a conflict exists if the
conduct prohibited by this Order is required by such federal law or if
conduct required by this Order is prohibited by such federal law.
Attachment A--List of Moldova Phone Numbers
373-955-1100
373-955-1111
373-955-1200
373-955-1300
373-955-1400
373-955-1500
373-955-1600
373-955-2000
373-955-2010
373-955-2020
373-955-2030
373-955-2222
373-955-2400
373-955-2401
373-955-2402
373-955-2403
373-955-2404
373-955-2405
373-955-2406
373-955-2407
373-955-2408
373-955-2409
373-955-2410
373-955-2411
373-955-2419
Donald S. Clark,
Secretary.
[FR Doc. 97-29298 Filed 11-3-97; 8:45 am]
BILLING CODE 6750-01-P
