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Dated January 2003 Respectfully submitted WILLIAM E. KOVACIC General Counsel GREGORY A. ASHE JAMES REILLY DOLAN VICTOR F. DeFRANCIS Federal Trade Commission Telephone 202 326-3719 Facsimile 202 326-2558 Attorneys for Plaintiff. Therefore the representations set forth in paragraph 26 are false and misleading and constitute deceptive acts and practices in violation of Section 5 a of the FTC Act 15 U.S.C. This requirement ensures that IDPs are issued only to persons who hold a valid truthful and...
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