Proposed Consent Agreement In the Matter of ADT, LLC, also d/b/a ADT Security Services #00004

Submission Number:
00004
Commenter:
Guisinger
State:
Arizona
Initiative Name:
Proposed Consent Agreement In the Matter of ADT, LLC, also d/b/a ADT Security Services
Matter Number:

1223121

The proposed order does not specify a monetary fine as part of the order — only that "Each violation of [the] order may result in a civil penalty of up to $16,000." There's little doubt that the illegal paid endorsements generated sales, and thus profits for ADT. ADT should not be allowed to retain those ill-gotten gains; thus an appropriate monetary fine should be assessed and included as part of the proposed order as a means to nullify those gains.