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 1223063 

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 ) 

) 

DRJAYS.COM, INC., ) DOCKET NO. C-4408 

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 DrJays.com, Inc. (“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 DrJays.com, Inc., is a New York corporation with its principal office or place 

of business at 853 Broadway, Suite 1900, New York, NY 10003. 

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.drjays.com. 
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4. From approximately January 2010 until approximately January 2012, respondent 

disseminated, or caused to be disseminated, advertisements for fur products, including, 

but not limited to, the advertisements for a Snorkel Jacket by Crown Holder (“Snorkel 

Jacket”), a Fur/Leather Vest by Knoles & Carter (“Fur/Leather Vest”), and a New York 

Subway Leather Bomber Jacket by United Face (“Bomber Jacket”) that are attached as 

Exhibit A. These advertisements are from respondent=s website and contained the 

following statements (emphasis added): 

a. The Snorkel Jacket with Fur-lined hood by Crown Holder features: 

$ Full zip-closure 

$ 6-pocket design 

$ 2-hidden pockets 

$ Faux fur-lined hood

$ Epaulet straps on shoulders 

$ Cut and sewn logo patch on left sleeve 

$ Gold hardware through out [sic] 

$ Logo applique on left chest 

b. The Fur/Leather Vest by Knoles and Carter features: 

$ Leather trims 

$ Faux fur on exterior

$ Dual buckle closure on collar, zipper closure down front, with snap 

closure on bottom trim 

$ Satin interior 

c. The NY Subway Leather Bomber Jacket (Detachable Hood) by United Face 

features: 

$ Full zipper closure 

$ New York subway map embroidered throughout 

$ Detachable Hood with faux fur lining

$ Multiple pockets 

$ Ribbed hem and cuffs 

$ True to size fit 

Respondent sold at least 241 units of the above-described products via its website for a 

total revenue of at least $19,062. 

5. The Snorkel Jacket had an attached label stating that product contained “real raccoon 

fur.” 
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6. In May 2012, respondent=s website advertised at least one other product as containing 

real fur. However, this advertisement, which is attached as Exhibit B, did not disclose 

the name of the animal that produced the fur. 

COUNT I

7. Through the means described in Paragraph 4, respondent represented, expressly or by 

implication, that the fur in the Snorkel Jacket, the Fur/Leather Vest, and the Bomber 

Jacket was faux or fake. 

8. In truth and in fact, the Snorkel Jacket, the Fur/Leather Vest, and the Bomber Jacket 

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 6, respondent did not disclose the 

names, as set forth in the Fur Products Name Guide, 16 C.F.R. ' 301.0, of the animals 

that produced the fur in the Snorkel Jacket, the Fur/Leather Vest, the Bomber Jacket, and 

the product advertised in Exhibit B. 

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.
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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: