Based on 10 through 18, above, I find that this representation is false. Each purchaser of respondent's vacation certificate will receive, upon request made within 20 days of receipt of the certificate and accompanied by it, a full refund of the purchase price of the certificate. It is false. The representations found above are material in that their natural tendency is to induce purchases of Respondent's vacation package. The number of complaints, if any, received from the public is not of importance in cases under the false representation statute.
Disclaimers are ineffective to rebut misrepresentations.
A money-back guarantee is no defense to this kind of proceeding. I find that such expectations are encouraged by the misrepresentations made by Respondent in its solicitation and vacation certificate. Accordingly, a mail stop order in the form attached should be issued against Respondent.