The Edmisten Webb & Hawes Law Firm on behalf of J.A.G. Rents, LLC and Red Zone Investment Group, Inc.
Proposed Consent Agreement In the Matter of Red Zone Investment Group, Inc., also doing business as ColorTyme, FTC File No. 1123151
On behalf of our clients J.A.G. Rents, LLC and Red Zone Investment Group, Inc. we hereby submit the following comment regarding the Analysis of Proposed Consent Orders to Aid Public Comment (“Analysis”): There has not been a scintilla of evidence presented that either RTO store “secretly photographed the private conduct of consumers in their homes” which “included pictures of children, household visitors, individuals not fully clothed, and couples engaged in intimate activities.” Moreover, there is not a shred of evidence that either RTO store received any “images of visitors, children, family interactions, partially undressed individuals, and couples engaged in sexual activities”. We hereby respectfully request that the FTC amend its Analysis accordingly.