Cliffdale Associates, Inc. (Cliffdale) (defendant) sold a product called the Ball-Matic Gas Saver Valve (Ball-Matic). The Ball-Matic was advertised as improving automobile gas mileage by allowing additional air into the car’s engine. Specifically, Cliffdale’s advertisements stated that customers could expect an approximate 20 percent improvement in fuel efficiency, which was roughly four miles per gallon. Cliffdale also claimed “every car needs one” and that the Ball-Matic was “the most significant automotive breakthrough in the last 10 years.” The Federal Trade Commission (FTC) (plaintiff) filed a complaint, arguing Cliffdale violated § 5 of the Federal Trade Commission Act (FTC Act). The FTC alleged that the Ball-Matic was similar to existing products that had been sold by other companies for years. The FTC claimed that the Ball-Matic performed the same basic function as standard engine carburetors. The FTC argued that the fuel-efficiency claims were demonstrably false and that the scientific tests Cliffdale cited as evidence of the advertisements’ fuel efficiency claims did not support Cliffdale’s claims. The administrative-law judge held that Cliffdale had engaged in a deceptive trade practice in violation of § 5 of the FTC Act, and Cliffdale appealed to the full Commission.