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Seventh Circuit Reminds District Court That Civil Penalty Factors Must All Be Considered

As we anticipate the forthcoming changes at the FTC and what enforcement will look like, one area that is often overlooked is the award of civil penalties in FTC cases....more

When Can the FTC Get $50,000 for a Consumer Review Snafu? Key Things to Know about the Rule on the Use of Consumer Reviews and...

The Final Trade Regulation Rule on the Use of Consumer Reviews and Testimonials was issued yesterday. It becomes effective 60 days after the rule is published in the Federal Register, which has not happened yet so no clock is...more

Money, Money, Money - How Does the FTC Get Money Back to Consumers?

For those of you enjoying the summer weather and listening to ABBA on repeat (or maybe that’s just me), you might have missed that earlier this month the Federal Trade Commission (FTC) released its Annual Report on Refunds to...more

Money, Money, Money - Recent Decision Shows a Court Wrestling with the Proper Amount of Civil Penalties to Award the FTC

Much ink has been spilled over the impact of the Supreme Court’s AMG decision on the Federal Trade Commission (FTC). That decision held that Section 13(b) of the FTC Act did not authorize a federal court to award equitable...more

FTC Reverts to Penalty Letters, Threatening 670 Companies with Penalties for Unsubstantiated Health Claims and Maybe More

Advertisers likely recall that back in 2021, the Federal Trade Commission (FTC) created quite the stir when it sent to more than 700 companies warning letters that threatened penalties if companies engaged in deceptive...more

Roomster Gets a One-Star Review from the FTC and Six States

​​​​​​​2022 continues to be the Year of the Review for consumer protection law enforcers. We have seen several cases already this year, and the latest suit has the added bonus of the Federal Trade Commission (FTC) teaming up...more

Bamboozling Part II: The FTC Brings Back Retro Penalty Offense Letters like Bell Bottoms and Big Hair

What do bamboo fabric and green claims have to do with toys, weight loss, car rentals and fur coats? Sounds like the start of a Dad joke, but unfortunately this is no laughing matter. It is the FTC reaching back to bygone...more

No Time to Weight and Watch for Children’s Data Compliance

The Federal Trade Commission (FTC) recently settled with Weight Watchers (WW) and its subsidiary Kurbo for alleged violations of the Children’s Online Privacy Protection Act  (COPPA). COPPA requires websites, apps and other...more

All Eyes on Us - the Latest FTC Case Involves Contact Lenses plus an Important Lesson About Incentivized Reviews

Up until now, most of the FTC’s law enforcement involving the Contact Lens Rule (Rule) has focused on sellers of cosmetic or decorative lenses. Indeed, safety concerns about decorative lenses were newsworthy in 2010, when...more

Understanding the FTC Penalty Box

Much like an artist looking for a muse, I keep up with consumer protection developments and ponder – is this blog-worthy? Well, the other day, the Federal Trade Commission (FTC) announced the annual updates to its civil...more

Legal Marketing Resolutions for 2022 — Better Coffee for All

I made my last New Year’s resolution 10 years ago in 2012. Technically, it wasn’t a resolution; maybe it was more of a lifestyle choice. I vowed that I would no longer drink the coffee that was sold in the Federal Trade...more

A Stumble out of the Section 19 FTC Gate

As many of our readers know, the U.S. Supreme Court decision in AMG dramatically changed things with respect to the ability of the Federal Trade Commission (FTC) to obtain certain monetary remedies. A lot has been written and...more

A Synopsis by Any Other Name Is Still an Important Thing To Consider

Whether you are old-school and call them Synopses or you use the new, more in-your-face term Notices of Penalty Offenses, the fact is that this tool has dramatically and quickly increased in significance under Chair Lina...more

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