172 3033

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Maureen K. Ohlhausen, Acting Chairman

Edith Ramirez

Terrell McSweeny

 

 ) 

In the Matter of ) 

 ) 

iSPRING WATER SYSTEMS, LLC ) Docket No. 

a limited liability company. ) 

 ) 

 ) 

COMPLAINT

 The Federal Trade Commission, having reason to believe that iSpring Water Systems, 

LLC, a limited liability company (“Respondent”), has violated the provisions of the Federal 

Trade Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges:

1. Respondent iSpring Water Systems, LLC (“iSpring”), also doing business as 

123filter.com, is a Georgia limited liability company with its principal office or place of business 

at 3020 Trotters Parkway, Alpharetta, GA 30004. 

2. Respondent advertises, labels, offers for sale, and distributes products to consumers, 

including, but not limited to, water filtration systems and parts. Respondent advertises these 

products primarily online, including, but not limited to, on its own website 123filter.com, and 

through third-party websites including, but not limited to, amazon.com, overstock.com, 

sears.com, and homedepot.com. Respondent offers for sale, sells, and distributes its products 

throughout the United States. 

 

3. 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. 

4. Respondent has disseminated or has caused to be disseminated advertisements and 

promotional materials for its products, including, but not necessarily limited to, the attached 

Exhibits A-C. These materials contain the following statements, among others:

A. “Built in USA Legendary brand of water filter” (Exhibit A, 123filter.com web 

advertisement);
2 

B. “Built in USA” (Exhibit B, search result demonstrating instances phrase 

occurs on 123filter.com website); 

C. “Built in USA” (Exhibit C, amazon.com, sears.com, walmart.com, and 

purwaterfilter.org product listings).

5. In numerous instances, including, but not limited to, the promotional materials shown in 

Exhibits A-C, Respondent has represented, expressly or by implication, that its products, 

including, but not limited to, water filtration systems and parts, are all or virtually all made in the 

United States.

6. In fact, in many instances, Respondent’s products are wholly imported. In other 

instances, Respondent sources significant inputs to its products from overseas.

7. Therefore, Respondent’s express or implied representations that its products are made in 

the United States deceive consumers.

COUNT I (False or Unsubstantiated Representation)

8. In connection with the manufacturing, labeling, advertising, promotion, offering for sale, 

sale, or distribution of its products, Respondent has represented, directly or indirectly, expressly 

or by implication, that such products, including, but not limited to, water filtration systems and 

parts, are all or virtually all made in the United States.

9. In fact, in many instances, Respondent’s products are wholly imported. In other 

instances, Respondent sources significant inputs to its products overseas. Therefore, the 

representation set forth in Paragraph 8 is false or misleading, or was not substantiated at the time 

the representation was made. 

VIOLATION OF SECTION 5

10. The acts and practices of Respondent, 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.

THEREFORE, the Federal Trade Commission this _______ day of _______, 20__, has 

issued this Complaint against Respondents. 

By the Commission.

 Donald S. Clark 

 Secretary

SEAL:
Exhibit A
HOME Knowledge base Installers Policies About Us Contact Us Warranty Registration My Account

Categories

Videos

Online Marketplaces

Notifications

Information

iSpring #APG16 Pressure Gauge 0 220 psi 1/4 inch fitting Model: APG16

Search for compatible cartridges and parts

Click to enlarge

List Price:$38.24

$23.90 Add $11.1 to qualify for FREE

Shipping

$22.71 after 5.0% checkout discount.

Rating: Not rated yet (0)

How to check water pressure by using pressure gauge?

Connect a piece of hose to the gauge

Attach the other end to your tap

Turn the water on fully

Read the pressure � it�s as simple as that!

Why iSpring Water Systems?

 Family owned innovative small business that thrives on customers satisfaction

 Built in USA Legendary brand of water filter

 WQA Gold Seal & NSF Certified product to ensure product quality, material safety and your health

 Free tech support before and after sale from Atlanta, Georgia. We love to help our customers.

 Ship from Atlanta facility daily. Only 2-day transit time for most states in Eastern time zone and part of Central time zone (including Texas)

Customers who bought this product also purchased

 Wednesday 16 November, 2016 5347415 requests since Tuesday 26 April, 2005 

iSpring Water Systems - #1 Best Seller Reverse Osmosis Water Filter Copyright © 2016

_Replacement Water Filter Packs-> (40)

_Replacement Filter Cartridges-> (77)

_Under-sink Water Filters-> (20)

_Commercial Reverse Osmosis (1)

_Whole House Water Filters (15)

_Refrigerator Water Filters (10)

_Faucet Mounted Filters (4)

_Shower Filter (4)

_Counter-top Water Filter (6)

_RO, Kitchen, Bath Faucets-> (33)

_Parts and Accessories-> (99)

»» Booster Pump (4)

»» Filter Housings (6)

»» Fittings (57)

»» Flood Prevention (5)

»» Membrane Housing (4)

»» O-Rings (5)

»» Tanks (8)

»»  TDS Tester (3)

»» Teflon tape (1)

»» Tubings (2)

»» Wrench (4)

How to install iSpring reverse osmosis?

Faucet Mount Water Filter

Notify me of updates to iSpring

Pressure Gauge 0 220 psi 1/4 inch

fitting

_Conditions of Use

_Privacy Notice

_Contact Us

iSpring Automatic Shut-off Valve (ASV) Quick Fitting $12.99 iSpring Whole House 12GPM 55W UV Disinfection System / Ultra Violet

Sterilizer $279.99 iSpring Membrane Double Clamp #ACN22 $7.50

iSpring 500GPD RO 2-Year Filter Supply Pack, Fits RCS5T $252.99 iSpring High pressure switch for Reverse Osmosis Water Filter with Booster Pump

#AHP $11.90

iSpring Handheld TDS Meter With Carrying Case, 0 - 9990 ppm TDS Measurement Range,

1 ppm Resolution, +/- 2% Readout Accuracy $14.99

iSpring #APG16 Pressure Gauge 0 220 psi 1/4 inch fitting | iSpring Wate... http://www.123filter.com/catalog/ispring-123filter-pressure-gauge-0-220...

1 of 1 11/16/2016 2:56 PM

Exhibit A
Exhibit B
2 3 4 5 6 7 8 9 10 Next

Washington, DC - From your Internet address - Use precise location - Learn more

Help Send feedback Privacy Terms

"built in usa" site: 123filter.com 1

All Shopping News Videos Images More Settings Tools

About 5,450 results (0.67 seconds) 

iSpring Water Systems - #1 Best Seller Reverse Osmosis Water Filter

https://www.123filter.com/

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS · HOME · Knowledge base · Installers · Policies ...

You visited this page on 11/15/16.

Our Contact Information | iSpring Water Systems - #1 Best Seller ...

www.123filter.com/catalog/contact_us.html

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS ... Thank you for visiting our website. If you have any ...

About Us | iSpring Water Systems - #1 Best Seller Reverse Osmosis ...

www.123filter.com/catalog/about_us.html

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS · HOME · Knowledge base · Installers · Policies ...

Faq | Installation manual | iSpring Water Systems - #1 Best Seller ...

https://www.123filter.com/catalog/knowledgebase.php

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS · HOME · Knowledge base · Installers · Policies ...

Parts and Accessories | iSpring Water Systems

www.123filter.com/catalog/parts-and-components.html

... a range of high quality parts and components for drinking water systems at 123filter! ... BUILT IN 

USA WITH WQA GOLD SEAL CERTIFICATION AGAINST ...

iSpring #RCC7 RCC7 5-Stage Residential Under-Sink Reverse ...

www.123filter.com/.../ispring-5-stage-75gpd-reverse-osmosis-system-rcc7--comparin...

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS · HOME · Knowledge base · Installers · Policies ...

Replacement Water Filter Packs | iSpring Water Systems

www.123filter.com/catalog/replacement-cartridge.html

Got clean water? BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI 

STANDARS · HOME · Knowledge base · Installers · Policies ...

Warranty Registration | iSpring Water Systems - #1 Best Seller ...

www.123filter.com/catalog/warranty_registration.html

BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI ... We do not have 

the order information from vendors other than 123Filter.com ... and continue supplying replacement 

filter cartridges at factory direct prices.

Privacy Policy | iSpring Water Systems - #1 Best Seller Reverse ...

www.123filter.com/catalog/privacy.html

BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST ... 123Filter.com knows that 

you care how information about you is used and shared, and we ... and store any information you 

enter on our Web site or give us in any other way.

Conditions of Use | iSpring Water Systems - #1 Best Seller Reverse ...

https://www.123filter.com/catalog/shipping.php

123filter.com accept your return request within 30 days for a refund - original package, unused ... 

BUILT IN USA WITH WQA GOLD SEAL CERTIFICATION AGAINST NSF/ANSI STANDARS ... 

Quoted prices are exclusive of all taxes. Purchaser ...

"built in usa" site: 123filter.com - Google Search Page 1 of 1

https://www.google.com/?gws_rd=ssl 12 9 201 / / 6

Exhibit B
Exhibit C
Exhibit C 

p. 1 of 11
Home / Appliances / Water Coolers & Filter Systems / Results For: "ispring"

22 results found for "ispring"

& marketplace (22) Only sort by In-store: g Set Your Location h

Newest Arrivals h

Refine Your Search

k Category

Under Sink (15)

Water Coolers (3)

Countertop (2)

Faucet Mounts (2)

k Price

(5) y $0 - $75

(4) y $75 - $225

(6) y $225 - $300

(4) y $300 - $425

(3) y $425 & above

to

k Current Offers

(21) y All Items On Sale

iSpring RCC7AK -

Built in USA, WQA

Certified Reverse

 

 

 

 

Sold by 2Shop

$264.99

z compare now

iSpring #RCC7AK 6-

stage 75 GPD

Reverse Osmosis

 

 Sold by iSpring Water ...

See price

$299.99

z compare now

iSpring RCS5T 500

GPD Tankless SideFlow Commercial 5-

 Sold by iSpring Water ...

$699.99

$599.99

z compare now

iSpring 300GPD

Commercial Reverse

Osmosis Water Filter

 

Sold by iSpring Water ...

$599.99

$549.99

z compare now

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Exhibit C 

p. 2 of 11
(19) y Free Shipping

k Discount

(21) y All Discounted Items

(8) y 20% off and more

(4) y 30% off and more

(1) y 50% off and more

h New Arrivals

h User Ratings

h Store Pickup & Delivery

h Sears & Other Sellers

h Shop Your Way MAX

iSpring WGB32B

Three Stage 20-Inch

Big Blue Whole House

 

 Sold by iSpring Water ...

$599.99

$469.99

y add to compare

iSpring F15-400

Tankless RO System

Replacement Filter Set

Sold by Factory Advant...

$452.39

$400.19

y add to compare

iSpring 100GPD 7-

Stage Reverse

Osmosis RO UV

 

 Sold by iSpring Water ...

$459.99

$399.99

y add to compare

iSpring RCC1UP -

100GPD 6-Stage

Reverse Osmosis

 

 

 

 

Sold by iSpring Water ...

$459.99

$365.99

y add to compare

iSpring F25U75 3-Year

Replacement Filter Set

for 6-Stage 75GPD UV

 Sold by Factory Advant...

$341.89

$302.44

y add to compare

iSpring WGB22B 2-

Stage 20-Inch Big Blue

Whole House Water

 

Sold by iSpring Water ...

$329.99

$299.99

y add to compare

iSpring RCC7P-AK -

WQA GOLD SEAL - 6-

Stage 75GPD Reverse

 

 

 Sold by iSpring Water ...

$399.99

$289.99

y add to compare

iSpring #RCC1P USA

Top Brand 100 GPD 5-

stage Reverse

 

 

 Sold by iSpring Water ...

$359.99

$289.99

y add to compare

advertisement

Exhibit C 

p. 3 of 11
iSpring RCC7P - WQA

GOLD SEAL - 5

Stages 75GPD

 Sold by iSpring Water ...

$299.99

$269.99

y add to compare

iSpring MC4+NW14

2.8-Inch x 12-Inch

400GPD Commercial

Sold by Factory Advant...

$253.49

$224.24

y add to compare

iSpring RCC7 5-Stage

Residential Under-Sink

Reverse Osmosis

 

 

 

AAAAA (1)

Sold by iSpring Water ...

$219.99

$199.00

y add to compare

iSpring CU-A4 - US

Legendary - 4-Stage

0.1 Micron Ultra-

 Sold by iSpring Water ...

$288.99

$169.99

y add to compare

iSpring WCC31 3-

Stage Undercounter

Water Filter System

Sold by Factory Advant...

$165.09

$146.04

y add to compare

iSpring FP15X25 5

micron Sediment Filter

Cartridges, NSF

 

Sold by Factory Advant...

$72.79

$64.39

y add to compare

iSpring 2S-20BB-5M

Big Blue Whole House

Water Filter with 4.5-

 

 Sold by Big Electron Li...

$65.81

$59.83

y add to compare

iSpring #CKC1-New

Wav New Wave Enviro

Portable Single-Stage

Sold by iSpring Water ...

$59.99

$40.99

y add to compare

Exhibit C 

p. 4 of 11
1-22 of (22) Items

iSpring LittleWell

Faucet Mount Water

Filter with Innovative

Sold by iSpring Water ...

$39.99

$19.99

y add to compare

iSpring LittleWell

Faucet Mount Water

Filter Cartridge with

Sold by iSpring Water ...

$15.99

$9.99

y add to compare

Page 1 h 25 Items Per Page h

Sponsored Products

Classic Series Keurig

K50 Black Beverage

Brewer

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Greensand 20 Iron &

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System 2 cu. ft. High...

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Classic Series K55

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Dishwasher Cleaner

Tablets

(19)

$5.99

Exhibit C 

p. 5 of 11
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Exhibit C 

p. 7 of 11
iSpring RCC7 - Built in USA, WQA Certified Reverse Osmosis 5-Stage... https://www.walmart.com/ip/iSpring-RCC7-Built-USA-WQA-Certified...

1 of 2 12/9/2016 2:20 PM

Exhibit C 

p. 8 of 11
Add To Cart

Buying Guideline :

More information

iSpring RCC7 - Built in USA, WQA Certified Reverse Osmosis 5-Stage... http://purwaterfilters.org/product/ispring-rcc7-built-in-usa-wqa-certified-...

1 of 3 12/9/2016 2:22 PM

Exhibit C 

p. 9 of 11
iSpring RCC7 - Built in USA, WQA Certified Reverse Osmosis 5-Stage... http://purwaterfilters.org/product/ispring-rcc7-built-in-usa-wqa-certified-...

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Exhibit C 

p. 10 of 11
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Exhibit C 

p. 11 of 11