The Medical Messiahs:
A Social History of Health Quackery
in Twentieth-Century America

Chapter 13: Mail-Order "Health"

James Harvey Young, PhD


"No other country in the world begins to approach our national use of direct selling by mail. The public has amazing confidence in products so advertised. . . . The quacks with their nostrums, the miracle makers who can bring new sexual vigor to old men, grow hair or make it permanently' vanish, develop the bust, cure every ill from cancer to hemorrhoids, produce pills to make skinny people fat or fat people skinny, persist in their efforts, but we believe we have made the going considerably tougher. . . . The Promoters of these schemes always think up a new wrinkle when we put them out of business, and it is amazing the diversity and the novelty of the schemes that are involved."

—Abe M. Goff, General Counsel, Post Office Department, 1957 [1]


While the chemotherapeutic revolution brought an increasing array of new and effective drugs to treat the ailments of mankind, quackery's ineffective nostrums still flourished. The most outlandish and unscrupulous of therapeutic claims reached would-be customers through the comparative privacy of direct mail advertising. In the Post Office Department, a yeoman's guard of inspectors and lawyers sought to stem this vicious tide.

In 1938, the year of the new food and drug law, broadgauge cure-alls led the list of actions initiated by the Department. Some 28 purported panaceas, with curative promises running through the whole range of human disease, were entered on the solicitor's docket. Next in order of frequency came male-weakness remedies, heirs as it were of Man Medicine, which had engaged the Department's attention a quarter of a century before. Some 25 of these alleged rejuvenators were docketed in 1938. Cures for obesity, baldness, cancer, diabetes, tuberculosis, piles, and a score of other ailments and conditions required attention [2].

A decade later the pattern remained much the same. Panaceas still sought to cure all ills. Diseases like cancer and diabetes, promoters said, could still be eradicated with recipes sent by mail. Busts could be built up, virility quickened. In the never-never land of direct mail promotion, anything was possible. Regardless of changes in medical science, in legal regulation, in educational expansion, the same old utopian assurances, reminiscent of quackery's most ancient days, continued to gull the credulous and enrich the unconscionable [3].

In fighting medical mail frauds, the Post Office Department continued to use its time-tested procedures. Clues as to suspicious promotions came from various sources: from surveys of magazine advertising; from come-on letters sent to inspectors whose earlier test letters had gotten their names on new mailing lists; from consumer complaints; from suggestions made by other regulatory agencies, the American Medical Association, the National Better Business Bureau. Assuming the role of customer, under fictitious names, inspectors received the full range of promotional build-up and bought the product. Under the long liaison with the Food and Drug Administration, the Department secured analyses of drugs and expert scientific counsel in comparing real therapeutic value, if any, of drugs and devices with claims made in the advertising. When the data were all assembled, a Post Office lawyer wrote the promoter a pre-citation letter, explaining precisely what was wrong with his advertising. If the scheme seemed obviously fraudulent, the letter requested a voluntary abandonment of the whole enterprise. The Department might ask in response merely a letter saying the scheme had been given up—and later an inspector would check to make sure. Or the Department might require the promoter to sign an affidavit of discontinuance. The affidavit pledged the promoter to return money received in response to objectionable advertising and to abandon further use of such advertising. Should the promoter disobey, the document stated, postal officials could issue a fraud order immediately. In cases not wholly disreputable, the pre-citation letter suggested what particular advertising claims struck the Department as wrong. Post Office officials might accept an affidavit that was less than 100 per cent desirable in order to get quick action on stopping the worst claims, realizing how long the proprietor could continue these claims to the detriment of the public welfare if he chose to fight the Department through the protracted machinery of formal action. Some 60 to 70 per cent of cases initiated were settled by compromise [4].

Formal action began with a fraud complaint served on the proprietor. This document was resorted to immediately to launch a case against a perennial offender or one engaged in a scheme so large or hazardous as to make it a matter of serious public concern. The complaint listed specifically alleged violations of the law and usually summoned the promoter to a hearing. Before 1951 the same procedures were followed as in the Man Medicine case: the same lawyer might assemble the evidence, conduct the hearing, and make recommendation for action to the Postmaster General. In that year, however, the Supreme Court ruled that the Post Office Department must follow the provisions of the Administrative Procedure Act, passed by Congress in 1946 to ensure fair treatment of those brought to the bar of quasi-judicial proceedings by administrative agencies. This led to the creation in the Department of hearing examiners, impartial "judges" selected by the Civil Service Commission and insulated from the Department lawyers who prepared and presented the Department's case. Following prescribed procedures, the examiner conducted a hearing based on the complaint, taking testimony from witnesses appearing for both the Department and the remedy promoter and then rendering an initial decision, which became final unless either party decided to appeal. The Department's chief legal officer acted for the Postmaster General in rendering a decision on the appeal. Loopholes in the Department's organizational structure, found by ingenious counsel for defendants and made the basis of successful court action, led to the creation of a Judicial Officer, separate from the General Counsel, to act as the Department's appellate judge. Thus in 1958 the prosecuting and judicial functions were clearly separated. From the Judicial Officer's decision, the Department had no further appeal. A proprietor, if not satisfied that justice had been done, could carry his case on into the federal courts [5].

In the days of Man Medicine, proceedings had been more summary. The new procedures, while protecting the promoter's rights, gave him enhanced opportunities for stalling tactics. "When you get one of these fellows who is really in the business," the General Counsel stated at a Congressional hearing in 1957, "he delays the proceeding and files all kinds of motions and objections because he can continue to operate until we issue a final order." Clever proprietors, Post Office attorneys were convinced, planned a campaign with an eye on the calendar. Knowing they could push their advertising and maintain their selling while the administrative and court proceedings went their deliberate ways, promoters manufactured just enough of their "health" product to last until the final word was in. And their sales price was inflated to encompass the cost of lawyers' and court fees and possible fines in case of criminal conviction, which they tended to regard as a standard expense of doing business. If the final word was a fraud order, their stock of merchandise was exhausted anyway. And new promotions beckoned [6].

Indeed, since settlement by compromise was possible at any point during the administrative process, promoters often hung on until the midnight hour, reaping profits from sales, then agreed to an affidavit of discontinuance, thus avoiding even the stigma of a fraud order. Not infrequently they had begun a new venture even while the old was still in litigation [7].

Despite the dilatory tactics of besieged proprietors and despite the Department's small staff of inspectors and lawyers devoted to medical mail fraud work, their pace of action was creditable. "The Post Office Department," concluded the Blatnik subcommittee of the House after its 1957 hearings on the advertising of obesity remedies, "has a reasonably laudable overall record in expeditiously handling fraud cases." Still, the elapsed time from the receipt of a complaint to a final decision within the Department—with court appeal still possibly to come—averaged nearly 200 days [8].

For some years the Postmaster General had held the view that he possessed the authority, when the public interest was great enough, to issue a temporary impounding order. This prevented a concern from receiving its mail until a fraud proceeding should be established against him. This power was very rarely used, and scarcely at all in medical fraud cases. Its legal basis was vague, and in 1959 a circuit court decided that the postal laws did not permit it. The next year Congress sought to remedy this weakness. In cases involving serious public interest, the new law authorized the Department to go to a district court and plead for an injunction. This would temporarily tie up a promoter's incoming mail until the question of fraud could be settled by the more time-consuming regular procedures. The Department, anxious that its first test case under the law be a solid one, moved warily. Up to 1966, no effort to secure an injunction had been brought in court [9].

Just as court decisions forced the Post Office Department to institute more elaborate judicial proceedings, so too did a crucial Supreme Court decision place upon the Department a more difficult burden of proof in securing a fraud order against a promoter of medical wares. The Department had recognized that, when it asked the Department of justice to launch a criminal case against a proprietor, clear-cut evidence of fraudulent intent must be established. But, from early in the century into the 1940's, in Departmental proceedings aimed at fraud orders, less demanding standards were set. If therapeutic claims for a drug or device could be shown to be false, fraud was presumed. Fraud orders issued on the basis of such logic were not questioned by the courts. In 1949, however, justice Hugo Black, speaking for the nation's highest tribunal in a case without dissent, changed all that. Barring the receipt of a person's mail, he indicated, was a harsh penalty. In order to warrant this severe step, Black ruled, "proof of fraudulent purposes is essential—an 'actual intent to deceive."' Proof that an incorrect statement had been made as part of the promotion was not sufficient [10].

"That's the case that killed us," a Post Office attorney noted later. For proving the fraudulent state of a promoter's mind in the 1950's was as difficult a task for the Post Office Department as the same burden had been in the 1920's for the Food and Drug Administration. The circumstances led to the prebuilt alibi. Before launching a promotion, the proprietor would seek scientific counsel from doctors of questionable reputation, and, being assured that a given ingredient possessed therapeutic merit, he would initiate his scheme. When hailed to a Departmental bearing, he could assume the role of injured innocence. If his claims were false, he had made them in all good faith, relying on his "experts." [11]

Justice Black, in the Reilly v. Pinkus decision, did enunciate one method by which it would be possible to establish fraud from the facts presented in a case. "An intent to deceive might be inferred," be suggested, "from the universality of scientific belief that advertising representations are wholly unsupportable." This ruling provided a further clarification of the significant McAnnulty decision that had influenced all governmental efforts to combat quackery since 1902. The McAnnulty rule did not bar a finding of fraud, Black stated, "whenever there is the least conflict of opinion as to the curative efforts of a remedy," but, in such a case, the promoter's fraudulent intent must be established. When medical knowledge became "crystallized in the crucible of experience," however, and that knowledge denied that a given drug could benefit a given ailment, then one who sold that drug to treat that ailment perpetrated a fraud [12].

Black's lesson for the shrewd promoter was plain: avoid remedies purporting to cure cancer, diabetes, tuberculosis, concerning which knowledge had "crystallized in the crucible." Seek out instead the grey zone, in which, even though medical opinion leaned heavily in one direction, a minority position might at least be vigorously argued and honest intent asserted. Then postal authorities must prove state of mind.

That promoters learned this lesson well, the trend in fraud cases demonstrated. Surging to the top in almost equal numbers were three types of grey zone schemes: arthritis remedies; vitamins and other nutritional promotions—often a new vehicle for conveying ancient sexual prowess claims; and drugs and devices offered for weight reduction [13].

It had been an obesity treatment that lay behind the Supreme Court's ruling in Reilly v. Pinkus, "I'm the only man,",loseph J. Pinkus later told a reporter, "who ever beat the Post Office in the Supreme Court of the U.S. by a unanimous decision." And he conveyed the impression to the reporter that his victory had been won on grounds of medical efficacy. Such was certainly not the case. The Pinkus triumph was procedural. In the Post Office hearing, his attorney had not been permitted ,to cross-examine physicians who testified for the Department concerning statements in other medical works than the volumes they had referred to. As to the value of Pinkus' product, justice Black asserted, the evidence was sufficient to support the Postmaster General in finding that advertising claims misrepresented its power to take off weight. But proving fraud required something more [13].

The case had begun five years before. Pinkus, through his American Health Aids Company, vended a product known as Kelpidine, along with counsel on reducing sent with the drug to customers. Extensive advertising in magazines and on the radio offered an easy road to loss of weight. Picturing a shapely young woman in a bathing suit, one advertisement promised:

REDUCE SAFELY

NO EXERCISE
NO REDUCING DRUGS
ABSOLUTELY HARMLESS
LOSE 3 to 5 lbs. a WEEK yet eat plenty!
Follow the KELPIDINE REDUCING PLAN
Simply take a half teaspoonful of KELPIDINE with any meal
(preferably at breakfast).
EAT AS YOU USUALLY DO. DON'T CUT OUT fatty,
starchy foods, just CUT DOWN on them.
'Mat's all there is to it! [15]

Kelpidine was dried seaweed from the Pacific Ocean. The prescribed diet offered to customers cut down their eating to in between 800 and 1,200 calories a day. No matter what the advertising promised, nothing in the labeling of Kelpidine referred to it as a reducing agent or as an adjunct to a reducing diet. It was, the label said, a "nutritional supplement for increasing daily intake of iodine from ocean vegetation." Ocean kelp and any iodine it contained, two physicians testified at the hearing, possessed no value in treating obesity. A doctor appearing for Pinkus asserted that the iodine in kelp was an "anti-fat for reducing," but be admitted that he had never prescribed it for that purpose nor knew of any other doctor who did. The only test he ever had made of kelp, he said, was putting some in his mouth and swallowing it with water. Nor, said the Post Office medical witnesses, could kelp "reduce the feeling of hunger" by adding "bulk" to a diet low in calories, as some of Pinkus' advertising claimed. A daily diet of 1,000 calories, these witnesses testified, was "rigid" and "severe," and Pinkus' physician agreed. Even this diet, if it could be followed, would not ordinarily take off as much weight as three pounds a week. Loss of weight at this rate, in any case, might well prove harmful, especially to patients with heart and kidney disease. None of the advertising, however, conveyed to the would-be customer that he would be buying advice to curtail his eating so drastically. The regimen would certainly not let him "eat plenty, or eat as be "usually does," as the American Health Aids advertising promised. So a fraud order was issued in 1945.

What Pinkus wanted to have read into evidence to question the Department's medical witnesses about were certain old medical works and dictionaries in which kelp had been suggested as having some value in reducing. Being denied this privilege by the hearing examiner, Pinkus sued for an injunction to prevent the fraud order from being put into effect. He won his point in the district court and, when the government appealed, in the circuit court and finally in the Supreme Court [16].

Kelpidine was by no means the only drug of contention between Joseph Pinkus and postal authorities. A peripatetic scholar, Pinkus had attended a college of osteopathy in Missouri, Montclair State Teachers College in New Jersey, New York University, Harvard, Columbia (where Teachers College awarded him the Master of Arts degree). Teaching for a time at both high school and college levels, Pinkus found his true métier as mail-order promoter. "He seems to direct all of the tremendous amount of nervous energy stored in his wiry frame," noted a trade press reporter, "into new ideas for his business." And Pinkus was remarkably fecund. Like an expert juggler, be skillfully kept many items going simultaneously. His range of interest was broad—perfumes, guns, dolls, gems, hit tunes, lingerie, reproductions of Confederate currency. Health items, however, led to his main controversies with the Post Office Department [17].

Postal authorities got Pinkus to sign affidavits, either to stop his business or tone down his claims, for such promotions as Stop Smoke Chewing Gum; Hairgon Exolator, a device for the removal of excess hair; and T-M-X tablets, which were lauded in advertising for their quick restoration of "vim, vigor and vitality" and their power to enable, any user "to start enjoying life to the full again." Pinkus lost a court challenge when he sought an injunction to stop a fraud order leveled against his Spot Reducer, a vibrating gadget. His misrepresentations, the judge ruled, must be intentionally false because for one of his earlier obesity remedies, the drug Fucine, Pinkus had represented to the public that a vibrating device could not reduce weight. Within this defeat, however, Pinkus won a sort of victory. Post Office attorneys at the hearing had sought to present evidence that Pinkus' device could neither reduce total weight nor, as he claimed, take pounds and inches away safely from "most any part of your body where it is loose and flabby." The departmental decision, however, ruled that the spot-reducing claims were not at issue, only the matter of total weight. So promoters were given a green light on selling devices promising to massage ugly dimensions down to graceful size [18].

A more significant Pinkus triumph involved a proposition offered to the public not for making the fat slender but for making the skinny put on pounds. It was in the More-Wate case that Pinkus' lawyer found the loopholes in Post Office Department organization after the methods of operation had been changed to fit the Administrative Procedure Act. Because investigatory and judicial functions were not properly separated, and because the changed structure had not been published in the Federal Register, he argued, the legal requirements of the act had not been met. A judge agreed. Other cases were lost on these same grounds, and promoters with fraud orders lined up at the Department to have the orders rescinded. So a great deal of effort went for nought. In due course, after the Department had remedied these faults, a new case was initiated against More-Wate, and Pinkus signed an affidavit agreeing to modify his claims [19].

Pinkus' promotions brought millions of dollars to his post office box in Newark. And other mail-order promoters, through their frequent contact with Post Office lawyers, became almost as familiar faces as the postal inspectors on the floors below. Maye Russ, then director of the Food, Drug, and Cosmetic Division of the National Better Business Bureau, chronicled for the Blatnik subcommittee the complicated careers of several of these perennial litigants. "Sometimes," she said, "the names of relatives of a person whose activities have been curbed by postal-fraud actions, appear as principals of new companies which engage in similar practices. Such techniques permit multiple offenses without the appearance of the promoter's name in a succession of violations, thus encumbering effective prosecution of the undisclosed principal." [20]

Promotions did not necessarily end with the securing of fraud orders. If a promoter forsook direct mail solicitation and marketed his wares through retail drugstores, his product could sell on. Indeed, he could continue to get grudging help from the postal service. For a fraud order did not permit the Post Office Department to restrict a proprietor's mailing of third-class handbills and brochures. So advertising containing the very claims condemned in a fraud order could be delivered by mailmen to the mail boxes of the citizenry announcing the worthless drug or device for over-the-counter sale at a local store [21].

Nor did the citizen into whose box such a circular was delivered have much chance of knowing that the product had been tested by postal authorities and found wanting. "What publicity," Congressman Blatnik asked the inspector in charge of mail fraud investigations, "is given to these mail fraud orders and to affidavits of discontinuance?" [22]

"Frankly," Inspector William Callahan replied, "not as much as I would like to see given them." They were published in the Postal Bulletin, sent to all postmasters, and a public record was made available to members of the press. But newspapers were not much interested in publishing news of this kind. Such indifference had led to the discontinuance of press releases, which the Department had issued some years before. Shortly after the Blatnik hearing, a press release service was resumed. Newspaper reporting of fraud orders, however, remained-minimal. While, even with their frustrations and their failures, the Department saved the public millions of dollars by stopping shady promotions, the public remained largely ignorant of this measure of protection [23]

The American people learned little about either the grey-zone repeaters or the imaginative individualists, whose amazing therapeutic doctrines found their way into postal archives -like those, for example, of "Saint George," whose gospel of health went forth from "Faith Farm." Although he had received no training in either theology or medicine, Saint George, alias Morris Katzen, claimed to have had a vision from God while in a trance aboard a ship in the Persian Gulf. The vision instructed him that Jesus Christ, the all-powerful healer, was not a person but a mythical personification of the sexual fluid within the body. "The best natural healing," Saint George wrote, "is accomplished by retaining the sexual fluid; by retaining the wind; and by not being too hasty with bowel movements." Such a regimen would purify the blood, vanquish common ailments, banish nervous disorders, and provide the best chance for curing cancer. Katzen's direct mail advertising summarized his basic doctrines and offered for sale books he had written, Keys to Life and The Elixir of Life, in which the theories were more fully elaborated so that, he said, they could be practiced by the purchaser to his everlasting benefit. Katzen fought a fraud order on constitutional grounds, asserting that the order would violate the first amendment's prohibition against governmental establishment of religion. But the Post Office judicial Officer did not agree, citing an earlier court decision: "A religious ingredient is no better defense to a charge of fraud than to a charge of murder" [24]

It is understandable that Post Office inspectors and attorneys, while proud of their successes, should sometimes fall prey to the feeling that they were ploughing the sea. The main business of the Department, after all, was to deliver the mail. Fighting fraud was an incidental, if significant, sideline. Postal inspectors had some 250 different types of investigations for which they were responsible, medical mail fraud being only one. Procedures were more complicated and legally demanding than they once had been. Hard-won victories did not seem to diminish the number of potential foes. The repeaters kept repeating, learning from their experience, so new cases were often more difficult to develop than earlier ones. New promoters entered the medical mail-order game day by day. Criminal action, sometimes resorted to, proved not to be a compelling deterrent. In many jurisdictions, indictments were difficult to obtain. Cases were always time-consuming. Fines, when imposed, amounted to only a small percentage of the profits from the ventures. Jail sentences were infrequent and usually short. The hardened promoter sometimes continued to carry on his operations from his cell [25].

The Postmaster General, in 1957, announced that the use of the mails to promote medical quackery was at the highest level in history. Medical mail frauds, he asserted, were more lucrative than any other criminal activity. Facing such a challenge, the Blatnik committee learned, the Department had three inspectors devoting their full-time energies to medical mail fraud work. Other inspectors helped with individual cases, and a handful of lawyers sought to carry the heavy legal load. Despite some enlargement of the medical mail fraud staff, the contest continued woefully uneven [26].

"Because of the widespread plying of the fake medicine trade," another Postmaster General stated in 1961, "it is imperative that we use our limited resources wisely.... For this reason, our inspectors have been instructed to concentrate their efforts on the more serious perpetrations, which affect the most people in the worst way, rather than to be diverted by 'fringe' cases, which might consume more time and labor than their investigation and prosecution justify." Of all types of fraud, he indicated, the sale of specious drugs and devices was the most difficult to prosecute. "The peddling of fake medical cures," despite the dedicated efforts of the Department's small staff, continues to be "the most prominent fraudulent activity conducted through the U.S. mails today." [27]

References

  1. False and Misleading Advertising (Weight-Reducing Preparations), Hearings before a Subcommittee of the Committee on Government Operations, House of Representatives (85 Cong., 1 ses., 1957), 67.
  2. Calendar year 1938, Fraud and Lottery Docket, vol. 11, Office of the Solicitor for the Post Office Dept., Records of the Post Office Dept., RG 28, NA.
  3. Calendar year 1948, ibid., vols. 16 and 17.
  4. Interview with Abraham Levine, attorney in the Office of the General Counsel, Apr. 5, 1961; Procedures of the Post Office Department, Rules of Practice in Proceedings Relative to Fraud and Obscenity Orders . . . Amended Effective February 24, 1960; Hearings before House Subcommittee, 73.
  5. Ibid., 89; Levine interview; Cates v. Haderlein, 342 U.S. 804 (1951); Reilly, Postmaster, v. Pinkus, trading at American Health Aids Co., 338 U.S. 269; Pinkus v. Reilly, 157 Fed. Supp. 548 (1957); Columbia Research Corporation and Allerton Pharmacal Corporation v. Schaffer, 256 Fed. (2d) 677 (1958); Vibra Brush Corp. v. Schaffer, 256 Fed. (2d) 681 (1958); FDC Reports, Jan. 20, 1958, 17; Sep. 22, 1958, 7-8; Procedures of the Post Office Department . . . Relative to Fraud and Obscenity Orders, 1960. Prior to 1951 hearings in fraud cases were considered optional with the Department.
  6. Hearings before House Subcommittee, 42, 66; Levine interview.
  7. Hearings before House Subcommittee, 42.
  8. False and Misleading Advertising (Weight-Reducing Remedies), House Report 2553 (85 Cong., 2 ses., 1958), 15.
  9. Frederick M. Hart, "The Postal Fraud Statutes: Their Use and Abuse," FDC Law Jnl., 11 (May 1956), 248-53; Greene v. Kern, 269 Fed. (2d) 344 (1959); Levine interview; interview with Ralph B. Manherz, attorney in the Office of the General Counsel, July 26, 1962; Levine to author, Jan. 20, 1966. The act providing the authority to appeal for an injunction, 74 U.S. Stat, 553 , became law July 14, 1960.
  10. Hearings before House Subcommittee, 71-72; Reilly v. Pinkus, 338 U.S. 269.
  11. Levine interview; Hearings before House Subcommittee, 79. Efforts in Congress to eliminate the obligation upon the Department to prove fraudulent intent on the part of a promoter in order to issue a fraud order have so far failed, most recently in 1966, when the House unanimously passed H.R. 16706 but the Senate did not bring the measure to a vote. Wash. Post, Aug. 16, 1966; Levine interview, Nov. 1, 1966; False or Misleading Mail b Matter: Hearings before the [House] Subcommittee on Postal Operations (89 Cong., 2 ses., 1966).
  12. Reilly v. Pinkus, 338 U.S. 269; Edgar R. Carver, Jr., "The Rule in the McAnnulty Case," FDC Law Jnl., 5 (Aug. 1950), 508-12.
  13. Levine interview, Apr. 5, 1961.
  14. Advertising Age, 23 (Nov. 3, 1952), 66; Reilly v. Pinkus, 338 U.S. 9.
  15. Fraud Order jacket 7343, Records of the Post Office Dept., RG 28, NA; Fraud and Lottery Docket 14/303 and State and District Court Docket 1/36, ibid.; Fraud Order 27,936, May 7, 1945.
  16. Ibid.; Pinkus v. Walker, 61 Fed. Supp, 610 (1945); Pinkus v. Reilly, 71 Fed. Supp. 993 (1947); Pinkus v. Reilly, 170 Fed, (2d) 786 (1948); Reilly v. Pinkus, 338 U.S. 269 (1949).
  17. Advertising Age, 23 (Nov. 3, 1952), 66-68; Hearings in [later] American Healthaids Co., Solicitor's Docket, 1/319; Spot Reducer Co., Solicitor's Docket, 1/63; NBBB Service Bull., Periodical No. 1652, Nov. 24, 1958.
  18. Stop Smoke Co., Solicitor's Docket 7/33 (1955); Hairgon Exolator, General Counsel's Docket 1005 (1960); T-M-X Co., General Counsel's Docket 1524, Post Office Dept. Docket 2/30 (1961); Spot Reducer Co., Solicitor's Docket 1/63 (1951-60); Pinkus v. Reilly, 178 Fed. Supp. 399 (1959).
  19. Pinkus v. Reilly, 157 Fed. Supp. 548 (1957); FDC Reports, Jan. 20, 1958, 17 and Sep. 22, 1958, 7-8; More-Wate Co., General Counsel's Docket 1155 (1960).
  20. Spot Reducer Co., Solicitor's Docket 1/63; Hearings before House Subcommittee, 43-45.
  21. House Report 2553 (85 Cong., 2 ses., 1958),
  22. Hearings before House Subcommittee, 81-82.
  23. Ibid. The Post Office Department Information Service issues frequent releases entitled "Enforcement Action: Fraud and Mailability."
  24. Post Office Dept. Docket 2/73; Fraud Order 62-258 (1962).
  25. Levine interview, Apr. 5, 1961; Miriam Ottenberg, The Federal Investigators (Englewood Cliffs, N.J., 1962), 310.
  26. Postmaster General Arthur E. Summerfield cited in Post Office Dept. release, May 12, 1957, reproduced in Hearings before House Subcommittee, 170-71; ibid., 80.
  27. Postmaster General J. Edward Day, mimeographed text of Oct. 6, 1961, address.

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