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 1223065 

UNITED STATES OF AMERICA 

 BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Edith Ramirez, Chairwoman 

Julie Brill 

Maureen K. Ohlhausen 

Joshua D. Wright 

_______________________________________________ 

 ) 

In the Matter of ) 

 ) 

EMINENT, INC., d/b/a REVOLVE CLOTHING, ) DOCKET NO. C-4409 

a 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 

Roebling Coat (“Runway Coat”). Respondent featured these products in the 

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

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. 
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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 eighteenth day of July, 2013. 

 By the Commission. 

 Donald S. Clark 

 Secretary 

SEAL: