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Message:: [QUOTE="cpm9ball, post: 1667845, member: 24633"]The Florida Bar Journal       Per Se Violations of the Florida Deceptive and Unfair Trade Practices Act by Mark S. Fistos Page 62     This article identifies three categories of  “per se” violations of the Florida Deceptive and Unfair Trade Practices  Act (FDUTPA), F.S. Ch. 501, Part II, with respect to what the text of  FDUTPA indicates may be a basis for a statutory violation. It also sets  forth several advantages to finding and alleging per se violations of  FDUTPA.     FDUTPA broadly declares in §501.204(1) that  “nfair methods of competition, unconscionable acts or practices, and  unfair or deceptive acts or practices in the conduct of any trade or  commerce” are unlawful. By design, FDUTPA does not contain a definition  or “laundry list” of just which acts can be “deceptive,” “unfair,” or  “unconscionable.” No specific rule or regulation is required to find  conduct unfair or deceptive under the statute.[SUP]1[/SUP]     There is, however, an entire body of state  and federal rules, ordinances, and statutes which serves to identify  specific acts that constitute automatic violations of FDUTPA’s broad  proscription in §501.204(1). These rules, ordinances, and statutes, if  violated, constitute “per se” violations of FDUTPA, and could  automatically expose parties to actual damages, injunctions, and civil  penalties up to $15,000 per violation. An assessment of potential per se  FDUTPA violations, therefore, should play a part in any commercial law  practice, and is imperative for any lawyer bringing or defending against  a claim for deceptive or unfair trade practices. Approaches to FDUTPA Liability        There are two basic approaches to analyzing  FDUTPA liability: one is to determine whether an act or practice in  trade or commerce violates broadly worded standards relating to  unfairness, deception, unconscionable acts or practices, or unfair  methods of competition; a second is to assess whether conduct in trade  or commerce constitutes a per se violation.[SUP]2[/SUP]     • The Standards Approach     As a statute of reference, FDUTPA contains  broad proscriptions and then points to interpretations and other bodies  of law to give guidance on what may be considered in determining  liability under the statute. Along these lines, FDUTPA tracks the broad  language of the Federal Trade Commission Act (FTC act)[SUP]3[/SUP]  and declares “nfair methods of competition, unconscionable acts or  practices, and unfair or deceptive acts or practices in the conduct of  any trade or commerce” to be unlawful. Subsection 501.204(2) of FDUTPA  in turn provides that “due consideration and great weight” be given  interpretations by federal courts and the Federal Trade Commission of  what constitutes unfairness and deception. In interpreting the terms  “unfair” and “deceptive,” the FTC and federal courts have found  violations of the FTC act with reference to certain broadly worded  standards of unfairness and deception which apply across industries to  differing fact patterns. Based on FTC interpretations and federal case  law dating from the 1960s, Florida courts have adopted and applied in  various contexts a broadly worded standard of unfairness under which a  practice is unfair, “if it offends public policy and is immoral,  unethical, oppressive, unscrupulous or substantially injurious to  consumers.”[SUP]4[/SUP]     • The Per Se Approach    Conceptually, the per se approach to FDUTPA  liability embraces the notion that an act or practice in trade or  commerce may be “unfair,” “deceptive,” or “unconscionable,” because it  violates a predetermined guideline embodying public policy or morality,  or because it violates a predetermined guideline meant to protect  consumers from injury. A per se violation occurs where conduct violates a  specific guideline in the form of a statute, ordinance, or rule and a  violation of that guideline in turn automatically or “per se”  constitutes a violation of FDUTPA. The violation is said to be  “automatic” or “per se” because the statute, ordinance, or rule  constitutes a previously determined identification of specific unfair,  deceptive, or unconscionable conduct, and, when violated, automatically  states a FDUTPA violation, without the necessity of a full-blown  analysis of the conduct in light of broader standards of unfairness or  deception. Legislative Acknowledgment     In 1993, the Florida Legislature formally  acknowledged the per se approach in redefining the term, “violation of  this part” in §501.203(3) of FDUTPA, which now specifically refers to  sources upon which a litigant may base an alleged FDUTPA violation.[SUP]5[/SUP]  Subsection 501.203(3)(b) acknowledges the federal standards of  unfairness and deception as a basis for violations. Subsection  501.203(3) in turn addresses per se violations beginning with the  lead-in phrase to §501.203(3) which provides that “‘Violation of this  part’ means any violation of . . . the rules adopted under this act.” Subsections (a) and (c) of §501.203(3) further state: Violation of this part . . . may be based upon any of the following as of July 1, 2001:[SUP]6[/SUP]    (a) Any rules promulgated pursuant to the Federal Trade Commission Act, 15 U.S.C. ss. 41 et seq.                * * *        [or]    (c) Any  law, statute, rule, regulation, or ordinance which proscribes unfair  methods of competition, or unfair, deceptive, or unconscionable acts or  practices.[SUP]7[/SUP]        Categories of Per Se Violations    The rules, regulations, ordinances, and  statutes referenced in the above-quoted §501.203(3) refer to sources  which may serve as a basis for a per se FDUTPA violation. These sources  can be broken down into three categories:     1) Per se violations whereby a statute,  ordinance, or rule expressly refers to FDUTPA and provides a violation  thereof to be a violation of FDUTPA;     2) Per se violations whereby a statute,  ordinance, or rule expressly describes deceptive, unconscionable, or  unfair conduct without referring expressly to FDUTPA and when violated  constitutes a per se violation of FDUTPA; and     3) Per se violations whereby a court, in  the absence of any such reference or description, construes a statute,  ordinance, or rule to be a per se violation of FDUTPA.     • Per se by Specific Reference                In §501.203(3)(c), FDUTPA indicates a violation may based on “[a]ny law, statute, rule, regulation, or ordinance which proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or practices.”[SUP]8[/SUP]  Currently, at least 17 Florida statutes and one ordinance contain  provisions which specifically refer to FDUTPA and state that violations  of their provisions in turn are violations of FDUTPA.[SUP]9[/SUP]  The typical language of this first type of per se provision reads like  the provision of the Buying Services Act of 1991, which specifically  references FDUTPA and states: “A violation of this act shall be deemed  an unfair or deceptive trade practice within the meaning of part II of  chapter 501 [FDUTPA]. Violators shall be subject to the penalties and  remedies provided therein.”[SUP]10[/SUP]     • Per Se by Description    The reference in §501.203(3)(a) and (c) to  FDUTPA violations based on FTC or FDUTPA rules, or “[a]ny law, statute,  rule, regulation, or ordinance” can further be interpreted as a formal  acknowledgment of violations of a second type of per se violation which  occurs when a rule, statute, or ordinance is violated, and the rule,  statute, or other ordinance expressly describes unfair, deceptive, or  unconscionable conduct, without necessarily referring expressly to  FDUTPA.     Pursuant to the definition of “violation of  this part,” a violation of FDUTPA can occur when “rules adopted under  th[e] act” are violated. The Office of the Attorney General has  rulemaking authority under FDUTPA in §501.205 and pursuant thereto has  adopted Fla. Admin. Code R. 2-18, relating to “contract<strike> for future  consumer services.” Like many of the state and federal rules and  statutes which fall under the second category of per se violation, Rule  2-18 contains a prefatory phrase which states, “It shall be an unfair or  deceptive act or practice to . . .” and then it describes specific  conduct. </strike><strike></strike><strike> </strike><strike>    Apart from OAG rules, FDUTPA provides in §501.203(3)(c) that a violation may be based upon “any rule [or] regulation”  which proscribes such conduct in trade or commerce. Several other  Florida state agencies have adopted rules which describe unfair or  deceptive acts, mostly with respect to deceptive, false, or misleading  advertising. The coverage of these rules ranges from mortgage brokering[SUP]11[/SUP] to rules addressing certain professions like medicine[SUP]12[/SUP] and architecture.[SUP]13[/SUP]  Given that these rules specifically describe unfair, unconscionable, or  deceptive acts, they may also serve as per se violations of FDUTPA.</strike><strike> </strike><strike>    Like certain administrative rules, at least  12 Florida statutes may serve as per se violations because they contain  declarations that conduct or violations of their provisions are  deceptive, unfair, unconscionable, or unfair methods of competition.  Some of these statutes, like the free gift advertising law, simply  declare that any violation of the statute is a deceptive trade practice.[SUP]14[/SUP]  Others contain broad proscriptions of unfair, unconscionable, or  deceptive conduct in a certain industry with subsequent definitions of  specific violations, or they otherwise describe specific acts which are  considered unfair, unconscionable, or deceptive in a specific industry.[SUP]15[/SUP]</strike><strike> </strike><strike>    • Rules Adopted by the FTC</strike><strike>    Pursuant to the FTC act, the FTC has  adopted rules which describe unfair or deceptive acts in several  contexts, and which appear in 16 C.F.R. ch. 1, subch. D, entitled “Trade  Regulation Rules.” Some of the more well known of these include the FTC  rules governing door-to-door sales,[SUP]16[/SUP] franchises,[SUP]17[/SUP] holders in due course,[SUP]18[/SUP] negative option sales plans,[SUP]19[/SUP] funeral industry practices,[SUP]20[/SUP] and mail or telephone order sales.[SUP]21[/SUP]   According to the definition of “violation of this part,” in  §501.203(3)(a) a violation of FDUTPA can occur when federal  administrative rules promulgated by the Federal Trade Commission  pursuant to the FTC act are violated. Along these lines, the 11th  Circuit has confirmed that §501.203(3)(a) of FDUTPA creates a private  cause of action for violation of an FTC rule even though none exists  under federal law.[SUP]22[/SUP]</strike><strike> </strike><strike>    Besides the FTC act, the FTC promulgates or  enforces rules adopted pursuant to several other federal consumer  protection statutes. These administrative rules, like the FTC’s “Trade  Regulation Rules,” expressly describe unfair or deceptive acts and  practices, and they should be equal fodder for per se treatment.</strike><strike> </strike><strike>    The definition of “violation of this part,” in §501.203(3)(c) of FDUTPA states a violation may be based on “[a]ny  . . . rule [or] regulation . . . which proscribes unfair methods of  competition, or unfair, deceptive, or unconscionable acts or practices.”[SUP]23[/SUP]  This subsection is separate from §501.203(3)(a) which addresses FTC act  “Trade Regulation Rules” as a basis for a violation. The use of the  word “any” to modify the terms “rule” or “regulation” in §501.203(3)(c)  is not limited in the text of the definition to FTC rules specifically  adopted by the FTC pursuant to the FTC act, which is the case for  §501.203(3)(a). The Florida Legislature has further expressly intended  as a rule of statutory construction that FDUTPA be construed liberally  “[t]o protect the consuming public and legitimate business enterprises .  . . [and] . . .[t]o make state consumer protection and enforcement  consistent with established policies of federal law relating to consumer  protection.”[SUP]24[/SUP]  When read together, the foregoing provisions support the position that  federal rules which describe unfairness and deception and/or state a  violation thereof violates the FTC act, embody “established policies of  federal law relating to consumer protection” that when violated can  serve as per se violations of FDUTPA, even though they may not be “Trade  Regulation Rules” adopted by the FTC under specific authority of the  FTC act. </strike><strike> </strike><strike>    Per se FDUTPA violations therefore should  be stated for violations of FTC rules adopted pursuant to statutes like  the Telemarketing and Consumer Fraud and Abuse Prevention Act[SUP]25[/SUP] and the Children’s Online Privacy Protection Act of 1998,[SUP]26[/SUP]  because the rules adopted under these federal statutes expressly  describe unfair or deceptive conduct. To bring cases under FDUTPA based  on violations of these and other similar rule provisions is not only  consistent with federal law relating to consumer protection, but it also  effectuates the Florida Legislature’s intent that FDUTPA be construed liberally to protect the consuming public and legitimate businesses.</strike><strike> </strike><strike>    • Federal Statutes Describing Unfairness or Deception</strike><strike>    Like FTC-enforced rules, several federal  statutes expressly describe unfair and deceptive acts and practices or  refer to violations of their provisions as violations of the FTC act.  According to §501.203(3)(c), FDUTPA violations may be based on “[a]ny . . . statute  . . . which proscribes unfair methods of competition, or unfair,  deceptive, or unconscionable acts or practices.” FDUTPA thus may also be  interpreted to refer to violations of federal consumer protection  statutes which describe unfair or deceptive acts either by their own  terms or by reference to the FTC act.[SUP]27[/SUP]  For the same reasons federal rules describing unfairness and deception  or stating that a violation thereof violates the FTC act serve as per se  violations of FDUTPA, so should federal statutes which contain similar  provisions. Federal consumer protection statutes which proscribe  deception or unfairness on their own terms or with reference to the FTC  act and thus should be per se FDUTPA violations include statutes  addressing equal credit opportunities,[SUP]28[/SUP] federal warranty rights,[SUP]29[/SUP] truth-in-lending,[SUP]30[/SUP] fair credit reporting,[SUP]31[/SUP] credit repair,[SUP]32[/SUP] debt collection,[SUP]33[/SUP] and mailings of unordered merchandise,[SUP]34[/SUP] among others. </strike><strike> </strike><strike>    • Ordinances as Per Se Violations of FDUTPA</strike><strike>    Besides rules and statutes, nearly 20 years  ago, the Florida Supreme Court determined that “the Legislature in  enacting the Little FTC Act [FDUTPA], foresaw the passage of  supplementary local consumer legislation or ordinances.”[SUP]35[/SUP]  This determination was based in part on the FDUTPA subsection which  provides that FDUTPA is supplemental to and does not preempt local  ordinances which are consistent with its provisions.[SUP]36[/SUP]  In this vein, the Florida Legislature in 1993, through redefining  “violation of the part” in §501.203(3)(c), provided that violations of  the act may be based on “[a]ny . . . ordinance . . . which proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or practices.”[SUP]37[/SUP]  Accordingly, FDUTPA should be reasonably construed to refer to  violations of city and county ordinances which describe unfair or  deceptive acts, provided they are not inconsistent with FDUTPA. Local  governments throughout Florida have passed ordinances covering deception  and unfairness in specific subject areas like price gouging,[SUP]38[/SUP] title loans,[SUP]39[/SUP] secondhand merchandise,[SUP]40[/SUP] and motor vehicle repairs.[SUP]41[/SUP]  Others have passed their own consumer protection codes which proscribe  specific unfair or deceptive acts across industries and businesses  generally[SUP]42[/SUP] and which should serve equally well as per se FDUTPA violations. </strike><strike> </strike><strike>    • Per Se by Judicial Construction</strike><strike>    A third type of per se violation of FDUTPA  can occur when a court determines that activity made unlawful by another  statute, rule, or ordinance is unfair or deceptive within the meaning  and scope of FDUTPA, even though no explicit reference is made to FDUTPA  in the underlying statute, rule, or ordinance, and even if the statute,  rule, or ordinance has no express provision prohibiting unfair or  deceptive trade practices.The  legislative staff analysis of the 1993 bill which redefined a  “violation of this part” in §501.203(3), stated in part, the bill  “codifies existing practice and long-standing judicial decisions that make it clear that a violation of the act can involve a[nother] rule or statute.”[SUP]43[/SUP]</strike><strike> </strike><strike>    • Cases Construing FDUTPA</strike><strike>    To date, no Florida court has construed  §501.203(3)(c) as amended in 1993 and mentioned per se violations; ergo,  no judicial precedent exists for the opinion that §501.203(3) of FDUTPA  incorporates judicial decisions on per se violations as may be  indicated in the legislative history. Nonetheless, without benefit of  the reworked definition of a “violation of this part,” a few courts have  made findings (albeit sometimes in dicta) to the effect that conduct in  violation of other statutes, and even the Florida Constitution, could  constitute violations of FDUTPA. </strike><strike> </strike><strike>    In re Samuels v. American Legal Clinic, Inc.,  176 B.R. 616 (Bankr. M.D. Fla. 1994), is the only case which has  construed FDUTPA and actually used the term “per se violation” in  construing another law to be a per se violation of FDUTPA. In re Samuels  involved a pro se debtor who brought an adversary proceeding against a  layperson and her “American Legal Clinic, Inc.,” which had represented  her in a dismissed debt adjustment case. The debtor sought monetary  damages and injunctive and declaratory relief under FDUTPA for the  layperson’s alleged unauthorized practice of law. The bankruptcy court  in In re Samuels  determined that the layperson did engage in the unauthorized practice  of law within the meaning of Florida law, and that her ads and services  were deceptive under FDUTPA and that she had set up people for failure  in the bankruptcy system. The court cited the Fla. Const. Art. V, §15,  which provides that the Florida Supreme Court has the exclusive  jurisdiction to regulate the admission of persons to the practice of law  and the discipline of such persons. The court went on to note that the  Florida Supreme Court had created only a limited number of forms which  may be used by lay persons in Florida courts, and that nonattorneys  could only perform typing and secretarial services. The court concluded,  “[The layperson’s] violation of the Florida Constitution by exceeding  the parameters created for typing services [was] a per se violation of  the Florida UDAP laws [FDUTPA].”[SUP]44[/SUP]</strike><strike> </strike><strike>    State Dept. of Agriculture and Consumer Services v. Quick Cash of Clearwater,  605 So. 2d 898 (Fla. 2d DCA 1992), involved a suit by the Division of  Consumer Services to enjoin several pawnbrokers’ alleged violations of  FDUTPA. The lower court had quashed the division’s complaint because it  ruled the division did not have the authority to bring the action. In  reversing, the appellate court expressed reservations about the  division’s authority, but concluded that if the division could plead and  prove the defendants were engaging in a business method which involved  criminal usury under F.S. §687.071, this “could constitute either an  unfair method of competition or an unfair or deceptive act for purposes”  of FDUTPA.[SUP]45[/SUP]</strike><strike> </strike><strike>    Anden v. Litinsky,  472 So. 2d 825 (Fla. 4th DCA 1985), was a FDUTPA case brought by  property owners against an “investment” company and individually against  its president for making false representations and constructing a home  deficiently. The lower court entered judgment in favor of the property  owners. The defendants appealed. The appellate court noted the corporate  president was not a licensed contractor even though he made  representations to the plaintiffs to the contrary. The court quoted  former FDUTPA Rule 2-15.03(1), Fla. Admin. Code, which prohibited false  representations in procurement of a construction contract, the  definition of “contractors” in F.S. §§489.105(3) and 489.113(2), which  made it a misdemeanor to engage in business or act a contractor without  being duly licensed. Based on the administrative rule and statutory  violations the court held the trial court was “eminently correct” in  finding the corporate president had violated FDUTPA.</strike><strike> </strike><strike>    • Cases from Other Jurisdictions</strike><strike>    Judicial opinions from other jurisdictions  have tended to contain more extensive discussions of the per se approach  than those in Florida. To the extent another state’s unfair and  deceptive trade practice (UDAP) statute and FDUTPA are based on the same  model statutory language, decisions from that state should be  persuasive. By way of example, some out-of-state courts have permitted  per se treatment with reference to violations of federal environmental  statutes,[SUP]46[/SUP] statutes prohibiting video piracy,[SUP]47[/SUP] and the federal Food, Drug and Cosmetic Act;[SUP]48[/SUP] others have allowed per se violations based on state credit laws,[SUP]49[/SUP] misbranding statutes,[SUP]50[/SUP] environmental regulations,[SUP]51[/SUP] and a state’s Uniform Commercial Code provisions.[SUP]52[/SUP]</strike><strike> </strike><strike>Per Se Advantages</strike><strike>    In whatever category a per se violation may  fall, and whether it involves an ordinance, rule, or statute, there are  distinct advantages to finding and alleging per se violations of  FDUTPA.</strike><strike> </strike><strike>    Basing a FDUTPA claim on a per se violation  provides standing through FDUTPA to bring civil actions to seek relief  for violations of statutes and rules where none exists.[SUP]53[/SUP]  Reliance on another statute as a per se FDUTPA violation does not  import the standing requirements of the other statute into FDUTPA.[SUP]54[/SUP]  A per se argument for unfair or deceptive acts may be made, even where  the underlying statute only provides for criminal penalties.[SUP]55[/SUP]</strike><strike> </strike><strike>    Another advantage to finding a per se  violation is that often the court will not have to determine whether the  act or practice falls under the broad—but not precisely  defined—standards of deception and unfairness. Courts may have less  discretion interpreting rules, regulations, ordinances, or statutes with  specific requirements.[SUP]56[/SUP]</strike><strike> </strike><strike>    When per se violations are present they may  also quell perfunctory constitutional challenges based on the potential  vagueness of FDUTPA and its purported failure to give adequate notice  of what is prohibited. While constitutional challenges to FDUTPA have  failed on appeal,[SUP]57[/SUP]  they are still routinely raised in circuit court litigation. A clearly  stated per se violation should help debunk a quotidian vagueness  challenge to FDUTPA.</strike><strike> </strike><strike>    Cases may settle more quickly if violation of a clear-cut guideline like a per se violation is shown.[SUP]58[/SUP]</strike><strike> </strike><strike>    A per se violation may also provide  additional remedies and sanctions. If a claimant proves a violation of  an underlying statute which constitutes a per se violation of FDUTPA, he  or she may be able to recover remedies under both statutes. FDUTPA in  §501.213(1) provides “[t]he remedies of this part are in addition to  remedies otherwise available for the same conduct under state or local  law.” Several statutes which constitute per se violations of FDUTPA  contain their own remedies and sanctions which may be available in  addition to those under FDUTPA.[SUP]59[/SUP]</strike><strike> </strike><strike>     Moreover, even though a statute, rule, or  ordinance which has been violated does not specifically cross-reference  FDUTPA or specifically describe unfair or deceptive conduct, it may  provide evidence of an identifiable public policy, morality, or intent  to protect consumers regarding specific acts or practices, and therefore  be advantageous to use as a per se violation under FDUTPA. Courts in  other jurisdictions regularly construe state statutes to be per se  violations of the state’s UDAP statute, because the underlyingstatute  incorporates public morals or policy which, when violated, constitutes a  per se unfair act or practice. In such cases, courts often analyze the  underlying violation in light of the FTC unfairness standard which holds  that an act is unfair if it “offends public policy as it has been  established by statutes . . . or . . . it is within at least the  penumbra of some . . . statutory or other established concept of  unfairness” and/or they find the violation is immoral, unethical,  oppressive, or unscrupulous or causes substantial injury to consumers.[SUP]60[/SUP]  In addition, at least one state court has found a statute to be a per  se UDAP violation when the court found the underlying statute was  designed to protect the consuming public, and even where the underlying  statute did not provide for a private cause of action.[SUP]61[/SUP]</strike><strike> </strike><strike>    Finally, per se violations may make it  easier to prove civil penalties. Section 501.2075 of FDUTPA provides  that a person is liable for a civil penalty up to $10,000 per violation  in an action brought by an enforcing authority if such person “knew or should have known that his or her conduct was unfair or deceptive or prohibited by rule.”[SUP]62[/SUP]  Per se violations provide more notice and definition of prohibited  conduct; consequently, they may make it easier to prove a defendant knew  or should have known his or her conduct was unfair or deceptive.</strike><strike> </strike><strike>Conclusion</strike><strike>    As a statute of reference, FDUTPA refers in  the definition of a “violation of this part” to interpretations and  other bodies of law to give its necessarily broad proscriptions shape  and meaning: One reference is the federal standards of unfairness and  deception; another is the body of state and federal rules and statutes  and local ordinances which may be available to state per se or  “automatic” violations of the statute. These rules, statutes, and  ordinances may expressly refer to FDUTPA, describe unfair,  unconscionable, or deceptive conduct, or may provide evidence of public  policy or morality upon which a court may base a per se violation. </strike><strike> </strike><strike>    Advantages to finding and alleging per se  violations are many. Civil penalties may be easier to prove if per se  violations are presented. Per se violations maypermit  standing where none exists; they may also hasten settlement, provide  advance notice, allow additional remedies, and evidence public policy.  In the long run they may reduce the incidence of consumer injury. From a  practitioner’s perspective, per se violations should be addressed  separately in every case and on equal footing with an evaluation of the  facts in light of the standards of unfairness and deception. A thorough  familiarity with per se violations is clearly indispensable for any  lawyer assessing a claim for deceptive or unfair trade practices.</strike><strike> </strike><strike>        </strike><strike>[SUP]    [/SUP]Mark S. Fistos  served for 10 years as an assistant attorney general in the economic  crimes litigation unit of the Florida attorney general’s office,  concentrating his practice on cases involving deceptive and unfair trade  practices. He has drafted significant portions of Florida’s Deceptive  and Unfair Trade Practices Act. Mr. Fistos is a member of The Florida  Bar Consumer Protection Law Committee. He currently represents persons  who are victims of consumer fraud with the firm of James, Hoyer,  Newcomer & Smiljanich in its Tallahassee office.</strike><strike> </strike><strike>    This article is submitted on behalf the Consumer Protection Law Committee, Kenneth J. Nolan, chair, and Michael Flynn, editor.</strike>[/QUOTE]

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