UPDATE 1-Pre-Paid Legal clarifies on US FTC's draft complaint

* Says FTC draft complaint pertains only to ADRS program * Says will continue to cooperate with FTC * Believes no fees at issue subject to disgorgement

Nov 20 (Reuters) - Pre-Paid Legal Services Inc PPD.N said a proposed draft complaint it received on Thursday from the U.S. Federal Trade Commission seeking permanent injunctive relief and disgorgement of proceeds pertained only to one of its marketing programs. "The proposed draft complaint narrowly focuses on our Affirmative Defense Response System (ADRS) marketing program and specific representations regarding identity theft and data privacy issues," the company said in a statement.

The ADRS program, which represents a relatively small percentage of the company's revenue, was introduced in 2006 as a complimentary program for businesses to learn more about its identity theft and data security services, the company said.

On Thursday, the company said it had received a proposed draft complaint from the FTC alleging that its ADRS program and related materials violated the FTC Act regarding asserted misleading representations.

"Regarding the proposed disgorgement of proceeds, we received no fees for the ADRS presentation so we believe there are no fees or proceeds at issue that would be subject to disgorgement," the company said.

Pre-Paid Legal Services said it has responded to each request from the FTC and will continue to cooperate with the regulator to reach a mutually agreeable resolution.

Shares of the Ada, Oklahoma-based company were trading up 7 percent at $35.50 Friday morning on the New York Stock Exchange. (Reporting by Viraj Nair in Bangalore; Editing by Unnikrishnan Nair) ((viraj.nair@thomsonreuters.com; within U.S. +1 646 223 8780; outside U.S. +91 80 4135 5800; Reuters Messaging: viraj.nair.reuters.com@reuters.net))