iSpring Complaint

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);

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 Tues day 26 April, 2005

_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

2345678910 Next

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

Help Send feedback Privacy Terms

"built in usa" site: 123filter.com

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.

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

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

l / / 6

Exhibit B

Exhibit C



Exhibit C

p. 1 of 11

/ Appliances / Water Coolers & Filter Systems / Results For: "ispring"Home
22 results found for "ispring"
& marketplace
(22)
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Category
k
(15)
Under Sink
(3)
Water Coolers
(2)
Countertop
(2)
Faucet Mounts
Price
k
(5)
y
$0 - $75
(4)
y
$75 - $225
(6)
y
$225 - $300
(4)
y
$300 - $425
(3)
y
$425 & above
to
Current Offers
k
(21)
y
All Items On Sale
iSpring RCC7AK -
Built in USA, WQA
Certified Reverse
  
  
    
  
Sold by 2Shop
$264.99
compare now
z
iSpring #RCC7AK 6-
stage 75 GPD
Reverse Osmosis
 
  
    
 
Sold by iSpring Water …
See price
$299.99
compare now
z
iSpring RCS5T 500
GPD Tankless Side-
Flow Commercial 5-
 
  
Sold by iSpring Water …
$699.99
$599.99
compare now
z
iSpring 300GPD
Commercial Reverse
Osmosis Water Filter
    
 
Sold by iSpring Water …
$599.99
$549.99
compare now
z
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Exhibit C 
p. 2 of 11
66
gogo
SearchSearch

(19)
y
Free Shipping
Discount
k
(21)
y
All Discounted Items
(8)
y
20% off and more
(4)
y
30% off and more
(1)
y
50% off and more
New Arrivals
h
User Ratings
h
Store Pickup & Delivery
h
Sears & Other Sellers
h
Shop Your Way MAX
h
iSpring WGB32B
Three Stage 20-Inch
Big Blue Whole House
 
  
  
Sold by iSpring Water …
$599.99
$469.99
add to compare
y
iSpring F15-400
Tankless RO System
Replacement Filter Set
Sold by Factory Advant…
$452.39
$400.19
add to compare
y
iSpring 100GPD 7-
Stage Reverse
Osmosis RO UV
  
  
Sold by iSpring Water …
$459.99
$399.99
add to compare
y
iSpring RCC1UP -
100GPD 6-Stage
Reverse Osmosis
  
    
  
  
Sold by iSpring Water …
$459.99
$365.99
add to compare
y
iSpring F25U75 3-Year
Replacement Filter Set
for 6-Stage 75GPD UV
 
 
  
Sold by Factory Advant…
$341.89
$302.44
add to compare
y
iSpring WGB22B 2-
Stage 20-Inch Big Blue
Whole House Water
  
Sold by iSpring Water …
$329.99
$299.99
add to compare
y
iSpring RCC7P-AK -
WQA GOLD SEAL - 6-
Stage 75GPD Reverse
  
  
  
Sold by iSpring Water …
$399.99
$289.99
add to compare
y
iSpring #RCC1P USA
Top Brand 100 GPD 5-
stage Reverse
  
  
    
Sold by iSpring Water …
$359.99
$289.99
add to compare
y
advertisement
Exhibit C 
p. 3 of 11

iSpring RCC7P - WQA
GOLD SEAL - 5
Stages 75GPD
 
  
Sold by iSpring Water …
$299.99
$269.99
add to compare
y
iSpring MC4+NW14
2.8-Inch x 12-Inch
400GPD Commercial
 
 
Sold by Factory Advant…
$253.49
$224.24
add to compare
y
iSpring RCC7 5-Stage
Residential Under-Sink
Reverse Osmosis
    
  
  
AAAAA
(1)
Sold by iSpring Water …
$219.99
$199.00
add to compare
y
iSpring CU-A4 - US
Legendary - 4-Stage
0.1 Micron Ultra-
 
  
 
Sold by iSpring Water …
$288.99
$169.99
add to compare
y
iSpring WCC31 3-
Stage Undercounter
Water Filter System
Sold by Factory Advant…
$165.09
$146.04
add to compare
y
iSpring FP15X25 5
micron Sediment Filter
Cartridges, NSF
   
 
Sold by Factory Advant…
$72.79
$64.39
add to compare
y
iSpring 2S-20BB-5M
Big Blue Whole House
Water Filter with 4.5-
    
  
Sold by Big Electron Li…
$65.81
$59.83
add to compare
y
iSpring #CKC1-New
Wav New Wave Enviro
Portable Single-Stage
 
Sold by iSpring Water …
$59.99
$40.99
add to compare
y
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

add to compare

iSpring LittleWell

Faucet Mount Water

Filter Cartridge with

Sold by iSpring Water …

$15.99

$9.99

add to compare

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