The Drake Hair Braiding Company sold plastic braiding tools that made it appear easy to arrange long hair into complicated French braids. The company sold the braiding tools through sales agents and direct mailings that showed consumers how the sophisticated braids could be made in three easy steps. In reality, the Drake Company knew that the average consumer could not operate the tools correctly and easily.

Can the Drake Company be prosecuted under the mail fraud statute for making faulty claims, or is Drake involved in mere puffery about the braiding tools, which is not criminally actionable?

(Use IRAC)