172 3033

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Maureen K. Ohlhausen, Acting Chairman

Terrell McSweeny

____________________________________

)

In the Matter of )

)

iSPRING WATER SYSTEMS, LLC ) Docket No. C-4611

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);

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

occurs on 123filter.com website);
2

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 sixth day of April, 2017, has issued 

this Complaint against Respondent.

By the Commission.

Donald S. Clark

Secretary

SEAL: