2223023 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of 

LIONS NOT SHEEP APPAREL, LLC, a 

limited liability company, 

LIONS NOT SHEEP PRODUCTS, LLC, a 

limited liability company, 

LIONS NOT SHEEP VENTURES, LLC, a 

limited liability company, 

LIONS NOT SHEEP LLC, a limited liability 

company, and 

SEAN WHALEN, individually and as an officer 

of LIONS NOT SHEEP APPAREL, 

LLC; LIONS NOT SHEEP LLC; LIONS 

NOT SHEEP PRODUCTS, LLC; and 

LIONS NOT SHEEP VENTURES, LLC. 

DOCKET NO. C-4772

COMPLAINT 

The Federal Trade Commission, having reason to believe that Lions Not Sheep Apparel, 

LLC, a limited liability company; Lions Not Sheep Products, LLC, a limited liability company; 

Lions Not Sheep Ventures, LLC, a limited liability company; Lions Not Sheep LLC, a limited 

liability company; and Sean Whalen, individually and as an officer of Lions Not Sheep Apparel, 

LLC, Lions Not Sheep Products, LLC, Lions Not Sheep Ventures, LLC, and Lions Not Sheep 

LLC (collectively, “Respondents”), have 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 Lions Not Sheep Apparel, LLC is a Utah limited liability company with its 

principal office or place of business at 14572 S 790 W #C Bluffdale, Utah 84065. 

Page 1 of 7 
2. Respondent Lions Not Sheep Products, LLC is a Utah limited liability company with its 

principal office or place of business at 14572 S 790 W #C Bluffdale, Utah 84065. 

3. Respondent Lions Not Sheep Ventures, LLC is a Utah limited liability company with its 

principal office or place of business at 14572 S 790 W #C Bluffdale, Utah 84065. 

4. Respondent Lions Not Sheep LLC is a Utah limited liability company with its principal 

office or place of business at 14572 S 790 W #C Bluffdale, Utah 84065. Lions Not Sheep LLC 

owns 100% of Lions Not Sheep Apparel, LLC, Lions Not Sheep Products, LLC, and Lions Not 

Sheep Ventures, LLC. 

5. Respondent Sean Whalen (“Whalen”) is the sole owner and manager of Lions Not Sheep 

LLC. Individually or in concert with others, he formulates, directs, or controls the policies, acts, 

or practices of Lions Not Sheep Apparel, LLC, Lions Not Sheep Products, LLC, Lions Not 

Sheep Ventures, LLC, and Lions Not Sheep LLC (collectively, “Lions Not Sheep” or “Corporate 

Respondents”), including the acts and practices alleged in this complaint. His principal office or 

place of business is the same as that of the Corporate Respondents. 

6. The Corporate Respondents have operated as a common enterprise while engaging in the 

unlawful acts and practices alleged below. Respondents have conducted the business practices 

described below through interrelated companies that have common ownership, officers, 

managers, business functions, employees, and office locations, and that commingled funds, etc. 

Because these Corporate Respondents have operated as a common enterprise, each of them is 

jointly and severally liable for the acts and practices alleged below. Respondent Whalen has 

formulated, directed, controlled, or had the authority to control, or participated in the acts and 

practices of the common enterprise alleged in this complaint. 

7. Respondents have advertised, labeled, offered for sale, sold, and distributed products to 

consumers, including printed apparel, embroidered caps, and a range of accessories. 

8. The acts and practices of Respondents alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act. 

Respondents’ Business Practices 

9. Respondent Whalen organized Lions Not Sheep Apparel, LLC on February 4, 2016. 

Respondent Whalen has been employed and affiliated with Corporate Respondents as Chief 

Executive Officer since their inception. 

10. Heavily marketed through social media channels, Lions Not Sheep describes itself as a 

lifestyle brand from which consumers can purchase apparel and accessories that “show people 

it’s possible to live your life as a LION, Not a sheep” [sic]. 

11. The majority of Lions Not Sheep products are articles of wearing apparel including, but 

not limited to, t-shirts, sweatshirts, jackets, and sweaters. 

Page 2 of 7 
12. Respondents also sell branded hats and accessories, such as flags, stickers, and 

wristbands. 

13. Respondents sell Lions Not Sheep products online, including through their own website, 

lionsnotsheep.com, as well as on third-party platforms such as amazon.com and etsy.com. 

Products cost from $10 for stickers up to $105 for product bundles. 

14. Respondent Whalen holds, and, at all times material to this Complaint has held, sole 

responsibility for and directed publication of all marketing claims made by Corporate 

Respondents. 

15. Respondents have disseminated or have caused to be disseminated advertisements, 

packaging, and promotional materials for Lions Not Sheep products, including but not 

necessarily limited to the attached Exhibits A through F. These materials contain the following 

statements and depictions: 

A. “Made in the USA” or “Made in America” 

(Exhibit A, composite exhibit of lionsnotsheep.com homepage (Sept. 2021), 

product listings (Sept. 2021), Product Label, and Pinterest Post). 

B. “Are your products USA Made? 

Our apparel is printed and/or embroidered in the United States. We purchase all 

our supplies and materials from local businesses in Utah and the surrounding 

states.” 

(Exhibit B, composite exhibit of lionsnotsheep.com FAQs (Sept. 2021) and 

Facebook post (Jan. 2021)). 

C. “100% AMERICAN MADE.” 

(Exhibit C, Lions Not Sheep Facebook Post (June 2020)) 

D. “BEST DAMN AMERICAN MADE GEAR ON THE PLANET” 

(Exhibit D, Lions Not Sheep Instagram Video (June 2020)). 

E. “Products made in USA?? 

* * * 

[E]very damn post y’all ask this. In the time it took you to type this hypocritical 

statement cause the truth is 95% of your belongings are NOT American made, 

you could have visited our site and seen for yourself.” 

Page 3 of 7 
 

 

(Exhibit E, Post by Sean Whalen on Lions Not Sheep Facebook Post (May 

2020)). 

16. In most instances, the products advertised using the statements described in Paragraph 15 

consist of wholly imported shirts and hats with limited finishing work, including printing or 

embroidery, performed in the USA. 

17. On October 8, 2020, Respondent Whalen published a 4:16 video of himself to his social 

media accounts titled “MADE IN AMERICA” with a depiction of the Chinese flag. In that 

video, he introduced himself “as the owner and CEO of an apparel company,” and stated that, to 

make “Made in USA” claims for products, marketers should substantiate their products are “all 

or virtually all” made in the USA. During the video, Respondent Whalen explains he sources tshirts from China, screens them in the USA, folds them into bags in the USA, and then sends 

them to U.S. consumers. He states, “So our shirts are made in America . . . But those shirts are 

made in China, just like damn near every single made in America shirt you’re wearing is. This is 

how it works.” Respondent Whalen closes by stating he could conceal the fact that his shirts are 

of Chinese origin by removing origin tags, but to do that he would have to “charge you more for 

the tshirt ‘cause I gotta pay the manpower and the labor to f----g tear the China tag off and put 

the America tag on. Which maybe at some point in time we do . . . God bless American-made 

products; God bless China; God bless the entire f----g world.” 

18. From May 10, 2021 through October 21, 2021, Respondents removed tags disclosing 

appropriate foreign country of origin from shirt products and printed “Made in USA” at the neck 

of the shirts, as depicted below. (Exhibit F). 

Page 4 of 7 
19. Based on the facts and violations of law alleged in this Complaint, the FTC has reason to 

believe that Respondents are violating or are about to violate laws enforced by the Commission 

because, among other things, Respondents ceased their unlawful activities only after learning the 

FTC was investigating them. 

VIOLATION OF THE FTC ACT 

20. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts or 

practices in or affecting commerce.” 

21. Misrepresentations or deceptive omissions of material fact constitute deceptive acts or 

practices prohibited by Section 5(a) of the FTC Act. 

Count I 

False or Misleading Representation 

22. In connection with the advertising, promotion, offering for sale, or sale of hats and nonapparel accessories, Respondents have represented, directly or indirectly, expressly or by 

implication, that such products are all or virtually all made in the United States. 

23. In fact, in numerous instances, those hats and non-apparel accessories are wholly 

imported or contain significant imported content. Therefore, the representation set forth in 

Paragraph 22 is false or misleading. 

Page 5 of 7 
24. The acts and practices of Respondents as alleged in Paragraphs 22-23 constitute unfair or 

deceptive acts or practices in violation of Section 5(a) of the Federal Trade Commission Act. 

VIOLATIONS OF THE TEXTILE FIBER PRODUCTS IDENTIFICATION ACT AND 

TEXTILE RULES 

25. The Textile Fiber Products Identification Act, 15 U.S.C. §§ 70-70k (the “Textile Act”), 

governs, inter alia, the labeling and advertising of textile fiber products manufactured, sold, 

advertised, or offered for sale in commerce. See 15 U.S.C. § 70a. 

26. Pursuant to the Textile Act, a textile fiber product is misbranded if “a stamp, tag, label, or 

other means of identification, or substitute therefor authorized by section 70c of this title, is not 

on or affixed to the product showing in words and figures plainly legible . . . If it is an imported 

textile fiber product the name of the country where processed or manufactured[; or i]f it is a 

textile fiber product processed or manufactured in the United States, it be so identified.” 15 

U.S.C. § 70b(b). 

27. The Textile Act further provides that “a textile fiber product shall be considered to be 

falsely or deceptively advertised in any mail order catalog or mail order promotional material 

which is used in the direct sale or direct offering for sale of such textile fiber product, unless 

such textile fiber product description states in a clear and conspicuous manner that such textile 

fiber product is processed or manufactured in the United States of America, or imported, or 

both.” 15 U.S.C. § 70b(i). 

28. Subsection 70c declares unlawful removal or mutilation of a stamp, tag, label, or other 

identification required by the Textile Act before the product is sold and delivered to the ultimate 

consumer. 15 U.S.C. § 70c(a). 

29. Pursuant to Subsection 70e of the Textile Act, 15 U.S.C. § 70e(c), the Commission 

promulgated the Textile Fiber Rule, 16 C.F.R. Part 303 (“Textile Rules”). The Textile Rules 

provide, in relevant part: 

a. Articles of wearing apparel are subject to the Textile Act and Textile Rules. 

16 C.F.R. § 303.45(a). 

b. Imported textile products must be labeled with the name of the country where the 

imported product was processed or manufactured. 16 C.F.R. § 303.33(a)(1). 

c. A textile product either (1) made in the United States in whole or in part of imported 

materials; or (2) partially manufactured in a foreign country and partially 

manufactured in the United States must contain a label disclosing those facts. 

16 C.F.R. § 303.33(a)(3). 

d. Product descriptions for textile products advertised in mail order catalogs or mail 

order promotional materials must state clearly and conspicuously that the product was 

Page 6 of 7 
made in the United States, imported, or both in a manner that is consistent with the 

origin labeling of the product advertised. 16 C.F.R. § 303.34. 

30. A violation of either the Textile Act or the Textile Rules constitutes an unfair or 

deceptive act or practice in violation of the FTC Act. See 5 U.S.C. §§ 70a and 70e. 

Count II 

Textile Act and Textile Rules 

31. As set forth in Paragraph 11, Respondents market and sell or have marketed and sold 

textile fiber products subject to the Textile Act and Textile Rules. 

32. As set forth in Paragraph 15, Respondents advertise or have advertised the origin of those 

textile fiber products as USA. 

33. As set forth in Paragraph 16, in numerous instances, these textile products are wholly 

imported or incorporate significant imported materials. 

34. As set forth in Paragraph 18, in numerous instances, Respondents removed tags 

containing information required pursuant to the Textile Act and Textile Rules from retail textile 

fiber products and replaced those tags with false country-of-origin designations. 

35. Therefore, through the means described in Paragraphs 11-18 and 31-34, Respondents 

have introduced, advertised, offered for sale, or sold textile fiber products that are mislabeled or 

falsely or deceptively advertised, in violation of Sections 70a and 70b of the Textile Act, 15 

U.S.C. §§ 70a and 70b, and Sections 303.33 and 303.34 of the Textile Rules, 16 C.F.R. §§ 

303.33 and 303.34. 

36. Respondents’ violations of the Textile Act and Textile Rules constitute deceptive acts or 

practices, in or affecting commerce, in violation of 5(a) of the FTC Act. See 15 U.S.C. §§ 70a 

and 70e. 

37. Therefore, the acts and practices of Respondents as alleged in Paragraphs 31-36 

constitute unfair or deceptive acts or practices in violation of Section 5(a) of the Federal Trade 

Commission Act. 

THEREFORE, the Federal Trade Commission this 28th day of July, 2022, has issued 

this Complaint against Respondents. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

Page 7 of 7 
. 	 



		

    
  

Exhibit A 

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Previous I Next 

UONS NO'I' SHEEP' 

HOME MENS v WOMENS v KIDS LIMITED EDITION DROPS TRACK ORDER BLOG 

LIONS NOT SHEEP OG HAT (ALL BLACK) ***** 378 reviews 

$30.00 

Variant: MESH BACK 

I MESH BACK I FABRIC BACK 

'ti! ADDTOCART 

Expected Del ivery Date: Sep 14 - Sep 18 

DESCRIPTION -

All Black Snapback Trucker Hat. 

MATERIAL -

Adjustable Snapback Trucker Hat with embroidered logo 

MADE IN THE USA 

SHIPPING -

Items will be shipped out in 1-3 days from time of order 

USA Shipping:3-5 Business Days 

International Shipping: 5-9 Business Days 

RETURNS & EXCHANGES -

We offer a 7 Day Returns & Exchanges Policy. 

Items must be in brand new condition for us to accept the return/exchange. 

We do not accept returns or exchanges based of "Change of Mind" 

We only accept size exchanges. We do not accept exchanges for other 

designs I different items. 

WHAT IS LIONS NOT SHEEP -

Ifs a way of being. 

It's something you already have. 

It's already inside you. 

You have 2 choices. 

To lead, or to be led. 

Lions Not Sheep is the savage inside you have chosen to ignore. 

We live in a time when "fairness·· and equality is peddled more than hard 

work and victory is. 

We live in a time that man is encouraged to sit down and shut up than stand 

up and be bold. 

Following the masses is more encouraged than following your heart. 

Lions choose to lead. 

Not to be rebellious or to stand out, we lead because ifs who we are. 

We think differently. We speak and act differently. 

Because WE ARE DIFFERENT. 

A lion makes no apologies for being a lion. 

A lion makes no apologies for wanting to eat. 

A lion wakes up and fucking hunts. 

Power. THE BODY 

Passion. THE RELATIONSHIPS 

Purpose. THE MIND 

Production. THE BUSINESS 

Lions live by a very specific code. 

Their own code to their own tribe. 

Lions Not Sheep is not a group of followers, it is a pride of lions. 

A pride of men and women who PRODUCE abundantly for their pride. 

Who PROTECT their pride at all costs. 

And who PROVIDE for their own needs and desires. 

You choose if you are part of a pride. 

You choose if you are leading, or being led. 

You choose today like every other day if you will be a LION. 

Or if you will be a sheep. 

We are LIONS NOT SHEEP Exhibit A 

p. 2 of 6 
Customer Reviews 

5.0 ***** Based on 378 Reviews 

,. 

1. 

LIONS NOT SHEEP IS PROUDLY SUPPORTED BY ... 

m r~viewers would recommend this product 

Reviews 378 Questions O 

Filter Reviews: 

0.. Search Reviews 

Quality Hats Shipping 

SHEEP Love Statement 

***** 

• I recommend this product 

Hats 

Great!! l love all my products from 

Lions not sheep. Great quality and 

perfect style. 

lions Not Sheep OG Hilt (All Black) 

- MESH BACI< 

Michelle G. VerifiNI Buyer 

Was this helpful? ,. 0 " 0 

Lions Message Compliments 

55356 

• I recommend this product 

Stand proudly 

The quality of the tank top and hat 

are top notch. Fit us great and 

comfortable. I got multiple 

compliments an night long on my 

outfit and what it represents. 

Lions Not Sheep OG Hilt (All Black) 

-MESH BACK 

Jessie R. Vnifird B~r 

~ Share 

Wuthishelpful? .. 0 .. 0 

• I recommend this product 

Extremely Happy!! 

Ordered 3 hats great quality!! Time 

to order some hoodies and shirts 

Lions Not Sheep OG Hat (All Black) 

- MESH BACK 

Nathan 0. Vrrifkd B~r 

Was this helpful? .. 0 'f 0 

***** 

.. I recommend this product 

My Awesome New Hat Got Stolen! 

Great product, great message. fast 

shipping and attentive postpurchase follow up. 

My only complaint is that the hat is 

so cool that my little dude 6 year old 

stole It from me and now he wears 

it all the time! Guess I'll be getting 

another one. 

One thing .. .for S30 a hat y'all should 

be doing free shipping, or at least 

Q Ask a Question [Z Write a Review 

.. I recommend this product 

My husband loves it! 

I bought him this hat when your 

on1ine shop first opened up, and 

little did I know that he was going to 

love it and wear it so much! You 

were sold out for a while but I got 

him another one as soon as they 

were back in stock. It's sturdy, 

durable (he wears it a lot!), good 

quality. Great buy! 

Lions Nol Sheep OG Hal (All Black) 

- MESH BACK 

Denise R. Verified Buyrr 

Wasthishtdpful? .. 0 'f 0 

Exhibit A 

p. 3 of 6 
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than that. I have no complaints and 

will be ordering at least one more to 

replace the one my son stole! 

Lions Not Sheep OG H.1t (All Black) 

• MESH BACK 

Samuel M. Verified Buyer 

e ShMe 

Was this helpful? .. 0 .. 0 

2 3 4 5 6 7 8 9 10 

o 2021 Lions Not Sheep e. 

-

Exhibit A 

p. 4 of 6 
Exhibit A 

p. 5 of 6 
C O i https://www.pinterest.com/pin/588071663839226652/?d=t&mt=login 

@ Pinterest Today Explore Q. Search for easy dinners, fashion. etc 

.!. Visit . 

From lionsnotsheep.com 

15% OFF Lions Not Sheep OG 

Get t he Lions Not Sheep OG Tee for 15% OFF with code 

PIN15. Limited time deal! us Made in America! @ Over 

20,000+ Happy Customers * 1,000+ 5-Star Reviews! S

Now: LionsNotSheep.com 

• 

Lions Not Sheep Apparel 0 

329 followers 

Made In America Mens Tees Lions Sheep Shop Now C

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-

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UONS NO'I' SHEEP" 

HOME MENS v WOMENS v KIDS HATS & ACCESSORIES v LIMITED EDITION DROPS TRACK ORDER BLOG 

Frequently Asked Questions 

Are you located in the United States? 

Yes, our warehouse and fulfillment facility is in Salt Lake City, Utah. 

Are your products USA Made? 

Our apparel is printed and/or embroidered in the United States. We purchase all of our supplies and materials from local businesses in Utah and other 

surrounding states. 

Do your sizes run small or are they true to US sizes? 

How does The Lions Den work? How can I sign up? 

What are your payment methods? 

What is the exchange process? 

What is the refund process? 

Can I make changes to my order once it is placed? 

Why is my tracking showing in pre-shipment? 

Do you offer overnight/express shipping? 

Do you sell curved caps and not flat brims? 

C 2021 Lions Not Sheep ® . 

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ja Page created - August 8, 2015 

O Page manager locations: United States, 

Pakistan 

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JERSEY JUNE IS JUST GETTING STARTED! 

100% AMERICAN MADE. 

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• lionsnotsheep Made in U.S.A us 

Some folks are confused about wh

"MADE IN USA" means. 

This should clarify for ya. 

To all our customers, supporters a

fans THANK YOU! 

We love this country and we love 

making apparel that represents ou

beliefs and passions! 

We will never stop loving America

supporting our POTUS, vets and LE

and we will never stop making the 

BEST DAMN AMERICAN MADE GE

ON THE PLANET! 

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JUNE 30, 2020 

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