The FTC got off to a rocky start. In its early years, it was underfunded, hobbled by in-fighting among the commissioners, and was challenged regarding its mission to combat “unfair methods of competition.” In time, the commissioners came to view deceptive advertising as a means of unfair competition, falsely attracting customers from one’s competitors. But the courts were not always sympathetic to this idea. In 1925, the Third Circuit Court took a caveat emptor approach in the case of John C. Winston Co. v. Federal Trade Commission. The Winston Company offered consumers free encyclopedias but required buyers to pay $49.00 for “encyclopedic and research services.” The court wrote that “a very stupid person might be misled by this method of selling books, yet measured by ordinary standards of trade and by ordinary standards of the intelligence of traders, we cannot discover that it amounts to an unfair method of competition.” In order words: let the buyer beware.