New York, NY – March 19, 2009 – The Electronic Retailing Self-Regulation Program (ERSP) will refer direct response advertising by  Premier Partners, marketer of the Dr. Millner’s Minute White Professional Strength  Tooth Whitening System, to the Federal Trade Commission (FTC) following the marketer’s failure to participate in an ERSP inquiry. The marketer’s advertising came to ERSP’s attention pursuant to its ongoing monitoring efforts.

Claims at issue in the initial inquiry included:

• “The most powerful home tooth whitener available”
• “… keep your teeth their whitest, forever.”
• “In studies,  he has found that at-home treatments  outperform all tested in-office products”
• “…The   first   ever  professional strength tooth whitener now available  for home use  and  without  an expensive  trip  to the dentist”
• “…only  needs to be applied for minutes a session  and is  simply the most convenient and cost effective  way  to  whiten  and brighten your teeth today without a trip to the dentist”
• “Nothing has gotten my teeth whiter faster than Minute White!”

The marketer did not offer a substantive response to ERSP’s original inquiry within

15 calendar days, as set forth in the ERSP  Procedures.The marketer was afforded a second ten-day period in which to submit a substantive response. The marketer again did not submit a written response to the inquiry and pursuant to section 2.6 (B) of the ERSP Policies and Procedures, this matter has been referred to the FTC.