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Analysis of Proposed Consent Order to Aid Public Comment 

In the Matter of Resident Home LLC, a limited liability company also d/b/a Nectar Sleep,

DreamCloud Sleep, Awara Sleep, Level Sleep, Bundle Living, 1771 Living, Cloverlane, 

Wovenly Rugs, Sleep Authority, and Home Well Designed, and Ran Reske, individually and as 

an officer of Resident Home LLC, File No. 2023179

The Federal Trade Commission (“FTC” or “Commission”) has accepted, subject to final 

approval, an agreement containing a consent order from Resident Home LLC, also d/b/a Nectar 

Sleep, DreamCloud Sleep, Awara Sleep, Level Sleep, Bundle Living, 1771 Living, Cloverlane, 

Wovenly Rugs, Sleep Authority, and Home Well Designed, and Ran Reske (“Respondents”). 

The proposed consent order has been placed on the public record for thirty (30) days for 

receipt of comments by interested persons. Comments received during this period will become 

part of the public record. After thirty (30) days, the Commission will again review the 

agreement and the comments received, and will decide whether it should withdraw from the 

agreement or make final the agreement’s proposed order. 

This matter involves Respondents’ advertising of DreamCloud mattresses as of U.S. 

origin. According to the FTC’s complaint, Respondents represented that DreamCloud mattresses 

were “proudly made with 100% USA-made premium quality materials.” However, the 

complaint alleges that, in numerous instances, DreamCloud mattresses are wholly imported or 

incorporate significant imported materials. In all instances, DreamCloud mattresses are finished 

overseas. Based on the foregoing, the complaint alleges that Respondents engaged in deceptive 

acts or practices in violation of Section 5(a) of the FTC Act. 

The proposed consent order contains provisions designed to prevent Respondents from 

engaging in similar acts and practices in the future. Consistent with the FTC’s Enforcement 

Policy Statement on U.S.-Origin Claims, Part I prohibits Respondents from making U.S.-origin 

claims for their products unless either: (1) the final assembly or processing of the product occurs 

in the United States, all significant processing that goes into the product occurs in the United 

States, and all or virtually all ingredients or components of the product are made and sourced in 

the United States; (2) a clear and conspicuous qualification appears immediately adjacent to the 

representation that accurately conveys the extent to which the product contains foreign parts, 

ingredients or components, and/or processing; or (3) for a claim that a product is assembled in 

the United States, the product is last substantially transformed in the United States, the product’s 

principal assembly takes place in the United States, and United States assembly operations are 

substantial. 

Part II prohibits Respondents from making any country-of-origin claim about a product 

or service unless the claim is true, not misleading, and Respondents have a reasonable basis 

substantiating the representation. 

Parts III through V are monetary provisions. Part III imposes a judgment of $753,300. 

Part IV includes additional monetary provisions relating to collections. Part V requires 

Respondents to provide sufficient customer information to enable the Commission to administer 

consumer redress, if appropriate. 
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Part VI is a notice provision requiring Respondents to identify and notify certain 

DreamCloud mattress purchasers of the FTC’s action within 30 days after the issuance of the 

order, or within 30 days of the customer’s identification, if identified later. Respondents are also 

required to submit reports regarding their notification program 

Parts VII through IX are reporting and compliance provisions. Part VII requires 

Respondents to acknowledge receipt of the order, to provide a copy of the order to certain 

current and future principals, officers, directors, and employees, and to obtain an 

acknowledgement from each such person that they have received a copy of the order. Part VIII 

requires Respondents to file a compliance report within one year after the order becomes final 

and to notify the Commission within 14 days of certain changes that would affect compliance 

with the order. Part IX requires Respondents to maintain certain records, including records 

necessary to demonstrate compliance with the order. Part X requires Respondents to submit 

additional compliance reports when requested by the Commission and to permit the Commission 

or its representatives to interview Respondents’ personnel. 

Finally, Part XI is a “sunset” provision, terminating the order after twenty (20) years, 

with certain exceptions. 

The purpose of this analysis is to aid public comment on the proposed order. It is not 

intended to constitute an official interpretation of the proposed order or to modify its terms in 

any way.