L L.G. Balfour Co. v. F.T.C

In L L.G. Balfour Co. v. F.T.C., 442 F.2d 1, 19 (7th Cir. 1971), the company was charged with unfair trade practices. The Federal Trade Commission held that Balfour had secretly acquired and operated a subsidiary company. There was no allegation in the complaint, however, that Balfour had secretly acquired and operated the subsidiary company. Balfour claimed that it was accordingly deprived of full notice of the charges. The Seventh Circuit concluded that this did not amount to a "claim that Balfour was misled by the complaint, nor is there any evidence in the record that they could have been so misled." L.G. Balfour Co., 442 F.2d at 19. The court noted that an administrative complaint merely requires that "the one proceeded against be reasonably apprised of the issues in controversy ...." Id. . Because the notice satisfied those requirements, the court found that there was no prejudicial error. See id.