REASONS FOR SETTLEMENT

This statement accompanies the Consent Decree executed by defendant Dell Computer Corporation, in settlement of an action brought to recover penalties and equitable relief from the defendant for engaging in acts or practices in violation of the Commission's Trade Regulation Rule entitled "Mail and Telephone Order Merchandise" 16 C.F.R. Part 435 (the "Mail Order Rule").

Pursuant to Section 5(m)(3) of the Federal Trade Commission Act, 15 U.S.C. § 45(m)(3), the Commission hereby sets forth its reasons for settlement by entry of a Consent Decree and injunction:

On the basis of the allegations contained in the attached Complaint, the Commission believes that the payment of a $800,000 civil penalty constitutes an appropriate amount upon which to base a settlement. The civil penalty amount should assure compliance with the law by the defendant and others who might otherwise violate the Mail Order Rule. Further, defendant is permanently enjoined from engaging in acts or practices that are prohibited by the Mail Order Rule. With the entry of this Consent Decree, the time and expense of litigation will be avoided.

For the foregoing reasons, the Commission believes that the settlement by entry of the attached Consent Decree with the defendant is justified and well within the public interest.