The ordering information is transmitted directly to the dealer, who fulfills the order. The dealers are responsible for making the disclosures. Although the dealers allow the trade association to control the contents of the site, each dealer offers appliances for sale. That makes each dealer responsible for disclosing the energy efficiency information. Q. A portal operates a shopping area.
Visitors click to a page where they can select a category of appliances.
After choosing a category, they get descriptions of the models offered by several dealers, with links to each dealer. Visitors can order appliances through the portal, which forwards the information to the dealer. The dealer is responsible for posting the disclosures. The dealer is advertising in a catalog by virtue of the content it maintains on its own site. Q. A website offers information about a variety of appliances and recommends specific models.