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© 2003 Brian F. Schreurs
Even we have a disclaimer.

December 23, 2002

Elaine D. Kolish
Director
Federal Trade Commission
Enforcement Division IBCP
Washington, DC 20580

Re: Federal Trade Commission v. Speedway Motorsports, Inc. and Oil-Chem Research Corp., Civil Action No. 1:01CV00126
Compliance Report

Dear Ms. Kolish:

In anticipation of the Stipulated Final Order (the "Order"), Oil-Chem Research Corp. ("Oil-Chem") and Speedway Motorsports, Inc. ("SMI") submit this initial Compliance Report describing the means by which they will comply with the conduct provisions of the Order. Oil-Chem and SMI also will submit an additional Compliance Report sixty (60) days after the date of service of this Order.

Set forth below are the claims Oil-Chem intends to make in the advertising and promotion of zMAX. As substantiation for each claim, Oil-Chem refers to confidential, Bates-stamped documents produced under seal during the litigation of this action. Oil-Chem and SMI request that the Commission continue to preserve the confidentiality of these documents pursuant to the Protective Order executed by the parties during the litigation.

1. zMAX soaks into metal.
   Substantiation: DX 35, 36
2. zMAX reduces friction.
   Substantiation: DX 15, 16, 18, 19, 20, 21, 22, 23, 24, 39, 40, 46, 49, 50, 51, 52, 53
3. zMAX increases horsepower.
   Substantiation: DX 15, 16, 18, 19, 20, 21, 22, 23, 24, 46, 49, 50, 51, 52, 53
4. zMAX dissipates engine heat.
   Substantiation: DX 15, 16, 18, 19, 20, 21, 22, 23, 24, 35, 36, 46, 49, 50, 51, 52, 53
5. zMAX helps to improve or restore gas mileage and reduce emissions in older cars, by virtue of reducing engine deposits.
   Substantiation: DX 15, 16, 18, 19, 26, 37, 38, 41, 42, 43, 45, 47, 48, 49, 50, 51, 52, 53
6. zMAX helps to maintaing gas mileage and emissions in newer cars, by virtue of reducing engine deposits.
   Substantiation: DX 15, 16, 37, 38, 41, 42, 43, 45, 47, 48, 49, 50, 51, 52, 53
7. zMAX helps to reduce wear on engine valve-stems and guides and piston rings and skits, by virtue of reducing engine deposits.
   Substantiation: DX 15, 16, 28, 32, 33, 34, 39, 40, 41, 42, 49, 50, 51, 52, 53
8. zMAX helps to extend engine life, by virtue of reducing engine deposits.
   Substantiation: DX 15, 16, 28, 32, 33, 34, 41, 42, 49, 50, 51, 52, 53

Oil-Chem and SMI will provide copies o the Order to all employees and agents responsible for the advertising and promotion of zMAX. Oil-Chem and SMI continue to intend to comply with the Federal Trade Commission Act and with Parts I, II, and III of the Order. Oil-Chem and SMI have informed such employees and agents of the companies' high standards for truth and accuracy in all advertising and their commitment to enforcing these standards at all times. More specifically, Oil-Chem and SMI have instructed their employees and agents with responsibility for the advertising and marketing of zMAX that they must comply with Parts I, II, and III of the Order. To ensure such compliance, Oil-Chem and SMI will submit all print and broadcast advertising to outside counsel before such advertising is published for the purpose of obtaining a legal opinion that such advertising complies with Parts I, II, and III of the Order.

Oil-Chem and SMI request guidance from the FTC regarding its response to the claims set forth above. I understand that you will provide me with such a response in a return letter.

Sincerely,

Leiv H. Blad Jr.

cc: O Bruton Smith
William R. Brooks
Ed Rachanski Sr.
Fred Lowrance