From 1934 to 1939, Charles of the Ritz Distributors sold more than $1 million worth of its “Rejuvenescence Cream.” Advertisements for the cosmetic product typically referred to “a vital organic ingredient” and certain “essences and compounds” that the cream allegedly contained. Users were promised that the cream would restore their youthful appearance, regardless of the condition of their skin. How might the FTC analyze the representations made by Charles of the Ritz? What evidence might the FTC consider to determine whether the advertisements are deceptive? Is it important that consumers actually believe that the product will make them look younger? How might the product’s name affect the FTC’s analysis? [Charles of the Ritz Distributors Corp. v. FTC, 143 F.2d 676 (2d Cir. 1944).]