Simeon Management Corporation v. Federal Trade Commission

Petitioners ask the court to set aside a cease and desist order of the Federal Trade Commission (FTC or Commission) requiring them to make certain disclosures in their advertising. The Commission entered the order pursuant to its finding that, without such information, the advertisements were deceptive, unfair and false, in violation of sections 5 and 12 of the Federal Trade Commission Act (FTCA), 15 U.S.C. §§ 45 , 52 (1976). Simeon Management Corp., et al., 87 F.T.C. 1184 , 1229 (1976).

We have jurisdiction under 15 U.S.C. §§ 45 (c), (d). We decline to set aside or modify the order.

Petitioners are corporations and individuals engaged in the business of setting up, operating and promoting weight reduction clinics. They provide management and support services to the licensed physicians and nurses who administer the treatments offered by the clinics.

The clinics utilize the “Simeons” method for weight reduction. After an initial physical examination by a licensed physician, the patients are put on a four to six week treatment program which generally includes a 500 calorie per day diet, daily medical counseling and daily injections of human chorionic gonadotropin (HCG).

HCG is a…