A direct mail piece from Viridian Energy to residential customers at National Grid in Massachusetts prominently includes the text, "Save More Than $1,200 Over 3 Years!*"

The Viridian letter promotes a 36-month fixed rate of 11.99 cents per kWh. As noted more fully below, the mailer includes a disclaimer noting that National Grid's rates beyond April 2015 are not known.

The asterisk accompanying the phrase "Save More Than $1,200 Over 3 Years!" indicates that:

"Comparison based on National Grid's Basic Service rate of 16.18¢ versus Viridian's 3 year fixed rate of 11.99¢ and an average annual usage of 10,000 kWh over three years. Comparison assumes National Grid's Basic Service Charge rate will not change during the comparison period. National Grid's rate beyond April 2015 is not known. National Grid's rate has increased 141% for the period May 2012 to November 2014. Past performance does not necessarily predict future results. National Grid Customers may be subject to a Basic Service Billing Adjustment when switching to a competitive supplier. Viridian's Everyday Green electricity provides 50% renewable energy in addition to state requirements."

While the $1,200 figure is based on future projections, Viridian's product does guarantee that if the sum total of Viridian's charges are higher than what it terms the "Utility Price Index" for National Grid during the same period, Viridian will rebate the customer up to 110% of the difference.

Viridian provided the following statement to RetailEnergyX.com concerning the mailer:

"With Massachusetts consumers facing a significant increase in electricity prices, Viridian Energy was compelled to make them aware of their energy options with our 3DOM™ long-term fixed rate plans.

"Given that the estimated $1,200 savings with 3DOM is based on point-in-time market conditions and average usage, our mailer explicitly details the assumptions and calculations behind the approximated savings over the three years.

"Further, Viridian is so confident that customers will benefit from the price certainty offered by 3DOM, we also offer transparency into our back-end rebate -- which includes up to 110% of the difference should the customer end up paying more with Viridian.

"Since market volatility and extreme weather are the new normal, Viridian Energy is committed to providing ongoing consumer education and fulfilling its obligation as a responsible provider of affordable, renewable energy. "