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122 3065

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

COMMISSIONERS: Edith Ramirez, Chairman

Julie Brill

Maureen K. Ohlhausen

Joshua D. Wright

________________________________________________

)

In the Matter of )

)

EMINENT, INC., d/b/a REVOLVE CLOTHING, ) DOCKET NO. Ca corporation. )

________________________________________________)

COMPLAINT

Pursuant to the provisions of the Federal Trade Commission Act, as amended, 15 U.S.C.

§ 41 et seq., and by virtue of the authority vested in it by said Act, the Federal Trade

Commission (“Commission”), having reason to believe that Eminent, Inc., d/b/a Revolve

Clothing (“respondent”), has violated the provisions of the Federal Trade Commission Act,

15 U.S.C. § 41 et seq., the Fur Products Labeling Act, 15 U.S.C. § 69 et seq., and the Rules and

Regulations Under the Fur Products Labeling Act, 16 C.F.R. Part 301, and it appearing to the

Commission that this proceeding is in the public interest, alleges:

1. Respondent Eminent, Inc., is a Delaware corporation with its principal office or place of

business at 16800 Edwards Rd., Cerritos, CA 90703. 

2. The acts and practices of respondent alleged in this complaint have been in or affecting

commerce, as commerce is defined in Section 4 of the Federal Trade Commission Act,

15 U.S.C. § 44, and Section 2(j) of the Fur Products Labeling Act, 15 U.S.C. § 69(j).

3. Respondent has advertised, offered for sale, sold, and distributed fur products, as that

term is defined in Section 2(d) of the Fur Products Labeling Act, 15 U.S.C. § 69(d). 

Respondent advertises and offers fur products for sale through its Internet site

www.revolve.com.

4. Since approximately January 2, 2011, respondent disseminated, or caused to be

disseminated, advertisements for fur products, including, but not limited to, an Australia

Luxe Collective Nordic Angel Short Boot (“Nordic Boot”) and a Marc Jacobs Runway
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Roebling Coat (“Runway Coat”). Respondent featured these products in the

advertisements from www.revolve.com that are attached as Exhibit A. The

advertisements contained the following statements (emphasis added, except where

otherwise noted):

a. For the Nordic Boot:

• Color [Grey, Beva, Brown, Chestnut, Black, Moon Gray] 

• Suede upper with rubber sole

• Shell measures approx 13" in length

• Faux fur trim

b. For the Runway Coat: 

 

• Color - Black Olive

• Shell: 100% poly

Lining: 100% cotton

Sherpa Lining: 100% poly

• Button front closure

• Zippered front pockets

• Front flap pockets

• Front welt pockets

• Cuffed sleeves

• Belted vest

• Faux fur trimmed hood

• Styled with Free People High Waisted [sic] Patch Pocket Flare Jean in

Watch Tower [Emphasis in original]

• Styled with KORS Michael Kors Benet Bootie in Mushroom [Emphasis

in original]

The Runway coat had an attached label stating that the product contained “real coyote fur

trim.” 

5. Respondent also advertised on its website a Dakota Xan Fur Poncho and an Eryn Brinie

Belted Faux Fur Vest as having faux fur. These products had attached labels stating that

the products contained “real raccoon fur.”

6. Respondent sold at least 158 units of the above-described products via its website for a

total revenue of at least $32,750.
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COUNT I

7. Through the means described in Paragraphs 4 and 5, respondent represented, expressly or

by implication, that the fur in the products described in those Paragraphs was faux or

fake.

8. In truth and in fact, the products described in Paragraphs 4 and 5 contained real fur. 

Therefore, the representations set forth in Paragraph 7 were false, deceptive, or

misleading.

9. Respondent’s practices, as alleged in this complaint, constitute unfair or deceptive acts or

practices in or affecting commerce in violation of Section 5(a) of the Federal Trade

Commission Act, 15 U.S.C. § 45(a), and false advertising in violation of Section 5(a)(5)

of the Fur Products Labeling Act, 15 U.S.C. § 69c(a)(5), and Sections 301.2(c) and

301.49 of the Rules and Regulations Under the Fur Products Labeling Act, 16 C.F.R. §§ 

301.2(c) and 301.49. Pursuant to Sections 3(a) and 3(c) of the Fur Products Labeling

Act, 15 U.S.C. § 69a(a) and 69a(c), the false advertising of fur products, within the

meaning of the Fur Products Labeling Act and the Rules and Regulations Under the Fur

Products Labeling Act, is unlawful and an unfair and deceptive act or practice, in

commerce, under the Federal Trade Commission Act, 15 U.S.C. § 41 et seq.

COUNT II

10. Through the means described in Paragraphs 4 and 5, respondent did not disclose the

name of the animal, as set forth in the Fur Products Name Guide, 16 C.F.R. § 301.0 that

produced the fur in the products described in Paragraphs 4 and 5.

11. Respondent’s practices, as alleged in this complaint, constitute unfair or deceptive acts or

practices in or affecting commerce in violation of Section 5(a) of the Federal Trade

Commission Act, 15 U.S.C. § 45(a), and false advertising in violation of Sections 5(a)(1)

and 5(a)(5) of the Fur Products Labeling Act, 15 U.S.C. § 69c(a)(1) and (5), and Sections

301.2(c) and 301.49 of the Rules and Regulations Under the Fur Products Labeling Act,

16 C.F.R. §§ 301.2(c) and 301.49. Pursuant to Sections 3(a) and 3(c) of the Fur Products

Labeling Act, 15 U.S.C. § 69a(a) and 69a(c), the false advertising of fur products, within

the meaning of the Fur Products Labeling Act and the Rules and Regulations Under the

Fur Products Labeling Act, is unlawful and an unfair and deceptive act or practice, in

commerce, under the Federal Trade Commission Act, 15 U.S.C. § 41 et seq.

WHEREFORE, THE PREMISES CONSIDERED, the Federal Trade Commission has

caused this Complaint to be signed by its Secretary and its official seal to be hereto affixed, at

Washington, D.C., this ____ day of ____, 2013. 

By the Commission.

Donald S. Clark 

SEAL Secretary