"PUBLIC DOCUMENT." Rule 4.2(c)(2) 

UN ITED STATES OF AMERICA 

BEFORE THE FEDRAL TRADE COMMISSION 

OFFICE OF THE ADMINISTTRA TIVE LA W JUDGES DOCKET NO: 93 

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In the Matte r of 

Universal Computers and Electronics. Inc. d/b/a 

Appliancebestbuys.com d/b/a universalcdtv.com 

Respondents 

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VERIFED ANSWER 

WITH AFFIRlVlATIVE 

DEFENSES 

The Respondents respectfully submit the within Verified Answer on a Pro Se 

basis to the compiailll dated April 1. 2011 (hereafter "Complaint"). based upon the information 

and records maintained by the Respondents. 

I. Respondent denies the allegations as sel fanh within paragraph " 1" of the 

Complaint. 

a. Respondent never operated nor maintained a principal office or place of 

business at 170-08 Jamaica NY 11432. Instead the same was located in Long 

Island City. New York. 

b. Respondenl does not currently mainta in an interactive functioning website 

bearing the address www.applianccbcstbll\S.COIll as alleged in paragraph 001 " 

of the Complaint and has not done so fo r some time. Further insofar as the 

website did exist during certain times as alleged in the Complaint. technical 

difficulties existed as to its content and funct ioning as set forth in detail in a 

letter dated December 3, 20 10 to this agency. 

2. Respondent denies the allegations as set forth within paragraph "2"" of the 

Complaint. The Respondent does not currentl y operate a website bearing address 

www.univcrsallcdtv.com nor did the same offer each of the a ll eged items for sale 

as there was no method of making a purchase. 

3. Respondent denies upon information and belief the allegations as set forth within 

paragraph "r of the Complaint. 

4. Respondent admits the allegations as set forth within paragraph "4" of the 

Complai nt to the extent that the same seems to reOeet the alleged statute. 

5. Respondent denies upon infonl1ation and belief the allegations as se t forth withi n 

paragraph "5" of the Complain t. 

6. Respondent denies upon infonnation and be lief the allegations as set forth withi n 

paragraph "6" of the Complaint. 

7. Respondent denies upon information and belief the allegations as set forth within 

paragraph "7"" of the Complaint. 

04 29 2011
 04 29 2011
 
8. 	 Respondent admits the allegations as set forth within paragraph "8" of the 

Complaint to the extent that \\ww.appliancebestbuys.com did in fac t advertise the 

items as alleged in the complaint: however respondent is not entirely sure if these 

items are covered by the statute. 

9. 	 Respondent denies the allegations as set forth within paragraph "9" of the 

Complaint. 

10. Re spondent denies the allegations as set fOrlh withi n paragraph ,.] 0" of the 

Complaint. 

11. 	 Respondent admits the allegations as set forth within paragraph ,,] r' of the 

Complaint to the extent that the same seems to reflect the alleged statute. 

12. 	 Respondent denies the allegations as set forth within paragraph "\ T of the 

Complaint 10 the extent that it is believed that not all of the named ellli ti es and 

websites should be held liable for said penalties. 
AFFIRMATIVE DEFENSES 

First Affirmative Defense 

13. 	 www.UniversaILCDTV.col1l is not a proper party to this action. as the same has 

been incorrectly named. 

Second Affirmative Defense 

14. 	 Respondent berein was never properly served. 

Third Affirmative Defense 

15. 	 Respondent at no time anempled to deceive anyone or purposefully obscure 

infonnation. 

Fourth Affirmative Defense 

16. 	 At such times as alleged within the Complaint. the Respondent was not awa re said 

site was even potentially in violation of any FTC statute or otherwise. and upon 

said notice in 2008. terminated any perceived violative acts by adding hyperlinks 

to energy guide infonnation. (as per the "Appliance Labeling Rule") for a ll items. 

via direct database coding. 

Fif1h Affirmative Defense 

17. 	 The Respondent does not know if all the products are "covered products" 

under the applicable rules and regulations and thus does not admit to the 

violations as alleged. 

RESERVATION AND NON-WAIVER 

Respondents reserve the right to assert any additional and further defenses as may 

be revealed by additional information recei ved or as may be warranted by discovery. 

WHEREFORE. Based upon the above it is respectfully requested that this Agency 

dismiss all orthe allegations and that the Re spondents be awarded costs expended in 

defense ofthese proceedings. 

Uni versal Computers and Elec tronics. Inc .. Pro se 

By ~1l,aaa1~ anuel Salllos. as pnnclpa agent of 

Uni versal Computers and Electronics. Inc. 

210 Stanton Street. Apt 616 

New York. New York 10002 
CERT IFICATE OF SERVICE 


This is to certify that the undersigned has this date served this ANS\VER TO 

COM PLAINT in the above entitled actions upon all other panics to this cause by 

depositing a copy hereof in a postpaid wrapper in a Federal Express depository under the 

exclusive care and custody of Federal Express for the parties belovo' or via email. 

Chief Administrative Law Judge D. Michael Chappell (via email to oali a fh:.go\' and 

printed paper copy) 

Laura Schneider - Senior Attorney (via Federal Express) 

Federal Trade Commission! Bureau ofConslimer Protection! Division of Enforcemem 

600 Pennsylvania Avenue. NW 

M-8102B Washington. DC 20580 

Donald S. Clark (via Federal Express) 

Office ofthe Secretary 

Federal Trade Commission 

Washington. D.C. 20580 

Assistant Director (via Federal Express) 

Federal Trade Commission 

601 New Jersey Avenue. N.W. 

Washington. D.C. 20580 

,.",'&,"'A,", "".~//~_ 

I anlle! Santos. as prmclpal agent of 

Universal Computers and Electronics. Inc. 
VERIFICATION 


STATE OF NEW YORK ) SS: 

COUNTY OF QUEENS ) 

Manuel Santos. being duly sworn deposes and states: 


I am the agent/officer of the corporation Universal Computers and Electronics. 


Inc. and have read the attached Veri lied Answer and Allirmative Derenses and 


know the contents thereof. The contents o f \\ hich is true to the best of my 


knowledge based upon information and documentation maintained 


by this office. 


Dated: 


Jamaica. Ne" York ~ 

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