The complaint alleges that Ecobaby Organics misrepresented that its mattresses were certified by an independent third-party certifier when, in fact, the certifier was merely Ecobaby Organics' alter ego. This false advertising scheme is much different than simply making unsubstantiated health or environmental claims and is, or is evidence of, active fraud on the public. Yet the proposed settlement does not take that additional mental culpability into account. In fact, the settlement simply requires Ecobaby Organics to comply with the law -- there are NO punitive measures proposed. When the FTC imposes no punishment for intentional false advertising the consequence is that advertising attorneys lose influence in the conference rooms where advertising decisions are made. I respectfully suggest that the proposed settlement be rejected by the Commission and returned for consideration of the imposition of punitive measures.