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No more bad-mouthing of electrolysis by Lucy P.

The advertising messages of Lucy Peters Ltd., and Lucy Peters’ “Integrated System,” have been a thorn in the side of the electrolysis establishment for two decades, and the advertising claims of that company have, at one time or another, drawn the ire of hundreds of electrologists in the United States. Large glossy ads, boldly proclaiming “Electrolysis without regrowth,” and “Immediate Permanent Results,” have prompted the country’s major electrolysis associations to elicit the help of authorities such as the U.S. Federal Trade Commission (FTC), and the Council of Better Business Bureau, Inc. (BBB), in putting a stop to LP’s inaccurate and misleading ads. Especially annoying has been the implication that the LP “System” is in some way superior or different to that which other electrologists are capable of producing.

In the last few years the American Electrology Association (AEA) has persistently appealed to NAD (the National Advertising Division of BBB) to censor LP for its use of phrases like: “Get traditional electrolysis, the hair grows back” and “The Integrated System is the only way to be rid of unwanted hair for the rest of your life.”

Early in 1999 the AEA vigorously challenged the advertiser’s claims that the LP technique is “exclusive,” or that it employs different equipment to that used by other electrologists around the world.

In September 1999, LP’s official response to the AEA complaint was received by NAD, and the agency began formulating its decision. On concluding its investigation the advertiser was given up to 10 days to add an Advertiser’s Statement, if it so desired, before the decision was made public. Finally, in April 2000, NAD’s findings – together with the Advertiser’s Statement – were published in NAD News.

In the “Summary of Conclusions” of its eight page final case decision, NAD says:
“Recognizing that there are too many variables that influence the successful or unsuccessful electrolysis process, NAD concluded that the evidence in the record was insufficient to support broad unqualified claims that categorically deny the possibility of success by alternate systems/methods, and in such a comparative context, proclaim the guaranteed performance of the advertised method. Therefore, the NAD suggested that these claims be modified or discontinued.”

Without getting a legal opinion as to the exact meaning of this summary statement, Hair Route interprets this to mean that NAD would be pleased if LP would stop bad-mouthing electrolysis, and saying it doesn’t work, while continuing to laud LP’s system (which uses an LPS 1118 Epilator combined with insulated bulbous needles) and guaranteeing its performance 100 percent.

In its “Advertiser’s Statement,” LP says: “Conventional electrolysis entails numerous treatments, with intervening periods of hair regrowth, before the hair removal may eventually become permanent. Comparatively, Lucy Peters’ Integrated System provides ‘immediate permanent results, without regrowth,’ a statement that the NAD found to be substantiated in a previously challenged non-comparative Lucy Peters advertisement.

“Advertiser agrees that in future advertisements, that while it may advertise the demonstrated superiority of the Integrated System as compared to conventional forms of electrolysis, it will not make broad, unqualified claims which categorically deny the possibility of success of conventional electrolysis. The challenged language at issue in this proceeding was used once and the advertiser had already determined not to run it again.”

Reduced to a few words, this seems to say that conventional electrolysis requires lots of treatments and has some hair regrowth before it becomes permanent, while LP’s system provides “immediate permanent results, without regrowth” (a statement that NAD decided was OK in a 1994 ad, when LP explained that new hairs would grow only in those follicles that were not correctly treated). But LP promises that in the future when it advertises the “demonstrated superiority” of its system, it will not go so far as to say that “conventional electrolysis” is no good. Oh, and not to worry; that advertisement you really hated – the one about “Get traditional electrolysis, the hair grows back” – LP says it had already decided it didn’t want to run that one again.

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