-Caveat Lector-

from:
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<A HREF="http://www.parascope.com/articles/0397/sublimdw.htm">The Subliminal
Threat Scare </A>
-----

Rep. Dawson on Subliminal Telecasts

This collection of materials was entered into the Congressional Record
on January 28, 1958 by Representative William Dawson, who led the
legislative fight against subliminal advertising when the technique
first came into use. In a statement included here, Dawson gives his
arguments for banning subliminals. Also included are several letters
between Dawson and the chairman of the Federal Communications
Commission, in which the two men debate the FCC's power to clamp down on
the use of subliminals.

[doc begins]

Proceedings and Debates of the 85th Congress, Second Session
Volume 104 -- Part 1, pp. 1228-1230.
House of Representatives, January 28, 1958

NEED FOR REGULATING USE OF SUBLIMINAL PERCEPTION TELEVISION ADVERTISING
Representative William Dawkins (R-UT): Mr. Speaker, I hate to add to the
current troubles of the Federal Communications Commission. But I feel
that it is my duty to inform the Members of the House of my to-date
unsuccessful campaign to get the Commission to take action to protect
the public from a new television-advertising technique, at least until
such time as it can definitely be determined whether the technique is
effective.

I refer to the so-called subliminal projection advertising, or sneak
pitch, as I prefer to regard it. Using this technique, a television
station flashes a slogan of advertising message on the television screen
so instantaneously that the viewer cannot see it. The promoters of this
technique, however, maintain that the message infiltrates the viewer's
subconscious and is all the more effective because the viewer does not
realize that he has been subjected to salesmanship or propaganda.

This technique should not be used until it is definitely determined by a
controlled experiment whether or not it works. If it does not work,
television stations should be so informed. If it does work, it should be
strictly regulated, if permitted at all. Heaven knows, the blandishments
of visible advertising are hard enough to resist. Contemplate, if you
will, the effect of an invisible but effective appeal to drink more beer
being poured into the subconsciousness of teen-age television viewers.

I first called this matter to the attention of the FCC in early October.

At that time and again on November 5 and still again on December 17, I
asked the Commission to advise stations against using this SP
advertising technique until its effectiveness could be determined.
As I said in my most recent letter -- as yet unanswered -- the
Commission should make its position clear.

I wrote--
"In the present limbo, television stations are not sure whether they can
use subliminal advertising, but the public is not sure they cannot. I
see no reason for extending this ambiguous situation when most of the
television industry itself agrees that the process should not be used
until it has been fully evaluated."

In defense of the FCC's inaction, I can say that the Commission has
received assurance that it will not be used over the major networks. It
does not have the assurance, however, that SP will not be used by
independent stations. And because of the nature of the advertising, the
viewer himself does not when he is being subjected to it.

Now, apparently emboldened by the FCC's inaction, at least one
independent station is going for sneak pitch propaganda. I submit to the
RECORD a copy of an Associated Press story which appeared in the
Alexandria, Va., Gazette, January 24.

Once again, I urge Members of the House and particularly those in the
Interstate and Foreign Commerce Committee to join me in getting the FCC
to take a definite position on subliminal advertising.

For the information of the House I also am submitting a chronological
copy of my letters to the FCC and replies thereto.

[From the Alexandria (Va.) Gazette of January 24, 1958]
SUBLIMINAL PERCEPTION: LATEST METHOD OF COMMUNICATION
HOLLYWOOD. -- Let's suppose, now, that in a couple of months some
strapping young chap springs from his chair in front of the TV, grabs
his coat and streaks downtown to join the Army -- without knowing why.
Well, some people might say it was a simple case of subliminal
perception.

This hard-to-pronounce combination is actually nothing more than a
somewhat creepy device for sneaking things into your head without your
conscious knowledge.

Television station KTLA here says that in 60 days or so it will become
the first station in the country to undertake a planned program of
subliminal communication.

To pull the trick off, the station will employ special transmitting
equipment that will an image or a message across the screen. It will be
on and off so fast that the home viewer won't consciously know he's
seeing anything. But, if it works, the flash will leave an impression in
his mind.

Lew Arnold, KTLA's general manager, said the gimmick will be used at
first only for public service messages. "We'll flash on something like
'Join the Army' of Give to the 'March of Dimes.'"

"The next step would be to promote our own shows. Then -- and I have a
feeling this in a long way off -- we might go into the commercial end of
it."

HOUSE OF REPRESENTATIVES
Washington, D.C., October 5, 1957
John C. Doerfer,
Chairman, Federal Communications Commission, Washington, D.C.

Dear Chairman Doerfer:

Publicity has been given recently to a new device in television
advertising -- the so-called subliminal perception, usually referred to
as SP, for brevity's sake.

Secret pitch perhaps would be more meaningful to the uninitiated. An
advertising symbol or slogan is flashed on the television screen so
instantaneously that the viewed cannot see it. Allegedly, however, the
message infiltrates the viewer's subconscious, all the more effectively
because the viewer does not realize he has been subjected to
salesmanship.

A call to your Commission has disclosed that the Commission has no
official knowledge of this new process and that there is some doubt
whether the Commission would have the authority to regulate or supervise
such advertising methods.

The purpose of this letter is to request that you look officially into
the entire proposal under your general regulatory powers, determining
whether controls are necessary and whether additional legislation would
be required to provide such controls, if needed.

If this revolutionary advertising means is as effective as claimed, it
offers some worrisome, if not frightening, aspects. Put to political
propaganda purposes it would be made to order for the establishment and
maintenance of a totalitarian government. Even in the commercial usage
for which it is intended, surely the potential customer has a right to
know he is being advertised at. His prerogative of exercising buyer's
resistance is as much an American tradition as the advertising industry
itself.

Sincerely yours,
William A. Dawson,
Member of Congress.
____________________________________________
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC, October 10, 1957.
Hon. William A. Dawson,
House of Representatives,
Washington, D.C.

Dear Congressman Dawson:

This is with reference to your letter of October 5, 1957, concerning
subliminal projection advertising. You request information concerning
this matter.

You may be interested to know that I have referred this matter to the
staff to determine whether this method of advertising may be adapted for
use on television under our present rules and, if so, what further
action on the part of the Commission may be necessary or advisable in
handling this problem. I will advise you of the developments in this
matter.

Sincerely yours,
John C. Doerfer,
Chairman.
____________________________________________
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC, November 1, 1957.
Hon. William A. Dawson,
House of Representatives,
Washington, D.C.

Dear Congressman Dawson:

This is in further reference to your letter of October 5, 1957,
concerning subliminal perception advertising, and to the telephone
conversations between our staff and the Commission's staff concerning
the subject.

Subliminal perception advertising appears to be a new technique
concerning which the Commission has little information and no
experience. According to the trade press, subliminal perception is
described as "the faculty of absorbing fleeting visual information
without being consciously aware of it." It is stated that the technique
was tested by having the symbols of a nationally known soft drink
flashed for one three-thousandths of a second once every 5 seconds
during a dramatic film presentation in a theater. At this writing, there
is some indication in the trade press that the above technique may have
been used on television.

The Commission is, of course, interested in the above matter and its
staff is accumulating pertinent available information on the subject.
When sufficient data has been acquired, it will be studied by the
Commission. Please be assured that the matter will receive the
Commission's most careful consideration, consistent with its authority
under the Communications Act of 1934, as amended. As you may know, under
existing law, the Commission does not determine the particular programs
or types of programs to be presented over the air, the content of
advertising copy, or the manner of its presentation. Indeed, under the
provisions of section 326 of the Communications Act, the Commission is
prohibited from exercising the power of censorship over broadcast
material. Accordingly, the selection and presentation of program
material, including advertising, is the responsibility of the individual
station licensees. However, such licensees are required to operated in
the public interest and periodically, usually upon application for
renewal of license, the Commission reviews the overall operation of
station licensees to determine whether their obligation to operate in
the public interest has been met. If, for example, it were determined
that a particular station had knowingly or deliberately engaged in
fraudulent or deceptive advertising, or permitted its facilities to be
so used, or to be used for some other unlawful purpose, a substantial
question would be raised as to the station's continuing ability to serve
the public interest. The Commission would consider such activities in
the course of its licensing proceedings involving the station.

As we have indicated above, this problem is so new that specific data is
not readily available and no conclusive information has been received
which we can predicate an informed opinion. At the present time, we are
unable to state whether controls are necessary or whether additional
legislation may be required in the event controls are needed. I am sure
you will understand that, as additional facts are made known to us, we
will be in a position further to evaluate the situation and to arrive at
a definitive position. You may be sure that you will be advised or our
ultimate determination.

Sincerely yours,
John C. Doerfer,
Chairman
____________________________________________
HOUSE OF REPRESENTATIVES
Washington, DC, November 5, 1957.
Mr. John C. Doerfer,
Chairman, Federal Communications Commission,
Washington, D.C.

Dear Mr. Doerfer:

Thank you for your letter of November 1 (reference 8420) advising me of
the present status of your staff's investigation into the new television
advertising technique, subliminal perception.

I can appreciate the difficulties of compiling substantial information
about such a new and little-known process, and I commend you for the
progress made so far.

However, I am concerned -- as I am sure you are -- at your finding that
SP may already have been used on television. Reports reaching me
indicate that the device is being perfected and actively promoted by at
least two commercial firms. It would certainly seem anomalous to permit
random usage of this device during the very time a study is being made
to determine whether the the public interest requires its regulation.
For that reason I strongly urge the Commission to protect the buying
public against any possible advertising abuses by advising all
television stations and networks that subliminal perception is under
investigation and requesting them to forego its usage until a
determination has been made. I am sure the stations would lend their
cooperation in the public interest upon which their licenses are based.

The bulk of the mail which I have received has been in definite
opposition to this type of invisible selling. I am convinced that the
general public feels it is entitled to know when it is being subjected
to advertising. If subliminal projection techniques are eventually
allowed to be used at all, a minimum regulation should require prominent
announcement during the program of products being so advertised.

Again let me congratulate you and the Commission staff on the energetic
and direct way in which you have addressed this problem.
May I be advised whether you agree that the television stations should
be asked to reject subliminal advertising pending your study?

Sincerely yours,
William A. Dawson,
Member of Congress.
____________________________________________
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC, November 12, 1957.
Hon. William A. Dawson,
House of Representatives,
Washington, D.C.

Dear Congressman Dawson:

This is with reference to your letter of November 5, 1957, concerning
subliminal perception advertising. In your letter you urge that, to
protect the buying public from possible abuses by this advertising
technique, the Commission advise all television stations and the
networks that subliminal perception advertising is being investigated by
the Commission and request the stations and networks to forgo its usage
until a determination has been made.

As you are doubtless aware, the determination to take the action you
recommend could be made only by all of the Commissioners. Accordingly,
you will be interested to know that I have made arrangements to have
your recommendation presented to the full Commission. I wish to assure
you that the Commission will give careful consideration to the views you
have expressed in your letter in arriving at a decision.

I appreciate your writing to me concerning this matter. You will, or
course, be advised promptly of the disposition of this problem.

Sincerely yours,
John C. Doerfer,
Chairman.
____________________________________________
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC, November 27, 1957.
Hon. William A. Dawson,
House of Representatives,
Washington, D.C.

Dear Congressman Dawson:

This letter concerning subliminal perception advertising is with further
reference to your letter of November 5, 1957, and supplements the
response thereto dated November 12, 1957. In your letter, you urge that
the Commission advise all television stations and the networks that
subliminal perception advertising is being investigated by the
Commission and request that they forgo its usage until a determination
has been made.

At the outset, it should be pointed out that on November 21, 1957, the
Commission was advised that one station in Bangor, Maine, had tried the
technique of subliminal messages with respect to station promotional
announcements and hadn't been able to make them work. The Commission
knows of no other television station which has engaged in subliminal
perception advertising. As you indicate in your letter, tow companies
are known to be promoting the above technique. They are the Subliminal
Projection Co., Inc., and Experimental Films, Inc. Since the previous
letter to you, we have communicated with the first-named firm and have
been advised that there has been no demonstration of the technique on a
television broadcast station; that the firm has used the facilities of a
private closed circuit system for testing the technical operation of its
apparatus; and that the firm is prepared to demonstrate the technique on
a closed circuit system should the Commission so desire. This offer is
being considered by the commission.

We have also communicated with the local representative of the second
company and are awaiting a reply to specific questions submitted to him
for transmittal to the company.

As you may know, on November 13, 1957, the television code of the
National Association of Radio and Television Broadcasters announced that
it had recommended to its subscribers that any proposals to use the
television medium in the process called subliminal perception be
referred to the board immediately for review and consideration. The
board stated that "experimentation or the use of the process should not
be permitted on the television broadcast medium pending such review and
consideration." Additionally, we have communicated with representatives
of each of the major television networks and have been advised that have
not used the above technique.

The Commission, at this time, with the exception of the unsuccessful
attempt noted above, is not aware that subliminal perception advertising
has been used by any television broadcast station. In view of this, and
the fact that the Commission's consideration of this matter includes
consideration of the extent of its statutory powers with respect to
thereto, it is believed that a caveat to the licensees may be
inappropriate at this time. In this connection, we would like to point
out that the Communications Act contains no provisions which deal
specifically with subliminal perception. From present indications,
however, it seems fair to say that reasonable protections may be
available to the public under the general provisions of the act. For
instance, by the Commission's licensing procedures the United States
maintains control of and regulates radio transmission in the channels of
interstate commerce. Various sections of the act, including sections
303, make it clear that in exercising the power of control and reg
ulation the Commission must be guided by public interest, convenience,
or necessity. It would appear that the use of the subliminal perception
technique may be subject to our control under such provisions of section
303 as subparagraph (b) on the nature of the service to be rendered by
each station; subparagraph (e) on the type of apparatus to be used;
subparagraph (g) authorizing studies of new and experimental uses; and
subparagraphs (f) and (r), as well as section 4, subparagraph (i),
giving the Commission wide authority to make rules and regulations in
carrying out its functions and the provisions of the act.

As you may know, under existing law the Commission does not determine
the particular programs or types of programs to be presented over the
air, the content of advertising copy, or its presentation. Moreover, the
act prohibits the Commission from exercising the power of censorship
over broadcast material, which includes advertising. However, at this
time it does not appear that the regulation of this particular technique
would necessarily constitute censorship.

It may be pertinent to draw attention to section 317 of the
Communications Act of 1934, as amended, which reads as follows:
"All matter broadcast by any radio station for which service, money, or
any other valuable consideration is directly or indirectly paid, or
promised to or charged or accepted by, the station so broadcasting, from
any person, shall, at the time the same is so broadcast, be announced as
paid for or further furnished, as the case may be, by such person."
Undoubtedly section 317 would prohibit broadcasters from subjecting
audiences to messages received from undisclosed sources.

We have attempted to discuss the question with you fully at this time
even though the matter is in its formative stage. We are sure you will
understand that as additional facts are made known to us, we will be in
a position to further evaluate the situation and to arrive at a
definitive position. You may be assured that you will be advised of our
ultimate determination herein.

By direction of the Commission:
John C. Doerfer,
Chairman.
____________________________________________
HOUSE OF REPRESENTATIVES
Washington, DC, December 17, 1957.
Hon. John C. Doerfer,
Chairman, Federal Communications Commission,
Washington, D.C.

Dear Chairman Doerfer:

Recently I suggested that, in view of the widespread interest in, and
the apparent imminence of, subliminal advertising, the Commission put
the television broadcasting industry on official notice that this
technique is being investigated by the Commission to determine what
regulation may be needed in the public interest.

Your reply indicated that the Commission feels "a caveat to the
licensees may be inappropriate at this time." You go on to say, however,
that reasonable protections may be available to the public under the
general provisions of the act.

It is true that a major part of the television broadcasting industry,
including the major networks and the television code board, voluntarily
have recognized the potential dangers of subliminal advertising.

Nonetheless, my mail continues to reflect widespread public concern over
this method of manipulating minds.

That these fears are not entirely baseless is implied in the enclosed
article from the Wall Street Journal of December 5, 1957, concerning the
reaction of one of the subliminal projection firms to the networks' ban
on the secret pitch. I direct your attention to the quotation attributed
to one of the company's vice presidents:

"We never tried to sell TV networks subliminal advertising. All we
wanted was an industrywide test. But if they don't want to use it, we've
still got plenty of interested independent stations."

In view of the concern over premature usage of this invisible selling
method, it would appear timely to me for the Commission to remove the
uncertainty by a definite prohibition against television use of
subliminal advertising until your investigation has been completed and a
final determination made.

In your letter of November 17 you point out that one of the available
protections is section 303 of the Communications Act giving the
Commission control over services rendered and apparatus used by
stations. Another is section 317, requiring sponsor identification,
which you say "undoubtedly would prohibit broadcasters from subjecting
audiences to messages received from undisclosed sources."

Since the Commission does have this authority, I recommend that
subliminal advertising be specifically prohibited for the duration of
your present study.

In the present limbo, television stations are not sure whether they
could use subliminal advertising but the public is not sure they could
not. I see no reason for extending this ambiguous situation when most of
the television industry itself agrees that the process should not be
used until it has been fully evaluated.

May I be advised whether there is any reason why this definite
prohibition should not be put into effect?

Kind regards and best wishes for a joyous holiday season.

Sincerely yours,
William A. Dawson,
Member of Congress
-----
Aloha, He'Ping,
Om, Shalom, Salaam.
Em Hotep, Peace Be,
Omnia Bona Bonis,
All My Relations.
Adieu, Adios, Aloha.
Amen.
Roads End
Kris

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