Legal Library: Cases and Proceedings

In July 2024, a U.S. district court in central Florida unsealed a Federal Trade Commission complaint charging two related groups of defendants with defrauding consumers nationwide by enrolling them, without their knowledge, into continuity plans where they are shipped and charged repeatedly for personal care products that they did not agree to purchase.

The defendants allegedly deceived consumers with ads for “free” CBD and Keto-related personal care products, billing many for products they did not consent to purchase, signing many up for unwanted continuity plans, and debiting money from their bank accounts without prior authorization. In September 2024, the FTC announced three orders settling the Commission’s complaint. In December 2025, the FTC announced it was returning 27.6 million to defrauded consumers. 

The FTC approved a proposed order banning SpyFone and its CEO Scott Zuckerman from the surveillance business over allegations that the stalkerware app company secretly harvested and shared data on people’s physical movements, phone use, and online activities through a hidden device hack.

The FTC denied a petition to vacate or modify the FTC’s 2021 order.

The FTC filed a lawsuit against the three largest prescription drug benefit managers (PBMs)—Caremark Rx, Express Scripts (ESI), and OptumRx—and their affiliated group purchasing organizations (GPOs) for engaging in anticompetitive and unfair rebating practices that have artificially inflated the list price of insulin drugs.

The Federal Trade Commission sued 7-Eleven, Inc and its parent company, Seven & i Holdings Co., Ltd., alleging the convenience store chain violated a 2018 FTC consent order by acquiring a fuel outlet in St. Petersburg, Fla. without providing the Commission prior notice.

On December 8, 2025, the FTC announced that 7-Eleven, Inc. and its parent company, Seven & i Holdings Co., Ltd., (collectively 7-Eleven) will pay $4.5 million to settle the Commission's lawsuit. 

The Federal Trade Commission will require The Boeing Company (Boeing) to divest significant Spirit AeroSystems Holdings, Inc. (Spirit) assets to resolve antitrust concerns surrounding Boeing’s $8.3 billion acquisition of Spirit.

The Federal Trade Commission will require education technology provider Illuminate Education, Inc. to implement a data security program and delete unnecessary data to settle allegations that the company’s data security failures led to a major data breach.

The Federal Trade Commission is acting against a large automotive dealer group, Asbury Automotive, for systematically charging consumers for costly add-on items they did not agree to or were falsely told were required as part of their purchase. The FTC also alleges that Asbury discriminates against Black and Latino consumers, targeting them with unwanted and higher-priced add-ons.

In an administrative complaint, the FTC alleges that three Texas dealerships owned by Asbury that operate as David McDavid Ford Ft. Worth, David McDavid Honda Frisco, and David McDavid Honda Irving, along with Ali Benli, who acted as general manager of those dealerships, engaged in a variety of practices to sneak hidden fees for unwanted add-ons past consumers. These tactics included a practice called “payment packing,” where the dealerships convinced consumers to agree to monthly payments that were larger than needed to pay for the agreed-upon price of the car, and then “packed” add-on items to the sales contract to make up that difference.

The Federal Trade Commission filed a complaint against Gateway Services and its subsidiary Gateway US Holdings, Inc., (collectively referred to as Gateway), which alleges that Gateway imposed noncompete agreements on almost all of its employees, which typically prohibited employees from working in the pet cremation service industry anywhere in the U.S. for one year after leaving Gateway.

Under a proposed FTC consent order, Gateway must, among other terms, immediately stop enforcing all existing noncompete agreements.

On November 25, 2025, the FTC finalized the consent order in this matter.

The Federal Trade Commission issued an administrative complaint to challenge GTCR BC Holdings, LLC’s acquisition of Surmodics, Inc., alleging that the deal, which seeks to combine the two largest manufacturers of critical medical device coatings, is anticompetitive. The FTC charges that private equity firm GTCR’s proposed acquisition of Surmodics would create a combined company controlling more than 50% of the market for outsourced hydrophilic coatings. These coatings are often used by medical device manufacturers and are applied to lifesaving medical devices such as catheters and guidewires.

The Federal Trade Commission filed an amended complaint adding the states of Illinois and Minnesota as co-plaintiffs in the Commission’s lawsuit challenging GTCR BC Holdings, LLC’s (GTCR) acquisition of Surmodics, Inc. (Surmodics). The amended complaint also adds GTCR, LLC as an additional defendant in the case. 

The Federal Trade Commission took action to protect Americans from paying higher prices at the pump by resolving antitrust concerns surrounding Alimentation Couche-Tard Inc.’s (ACT) proposed $1.57 billion acquisition of 270 retail fuel outlets from grocery store chain Giant Eagle, Inc. Under the proposed consent order, the FTC will require ACT to divest 35 gas stations, which will be acquired by Majors Management, LLC. The consent order settles FTC charges that ACT’s deal with Giant Eagle is anticompetitive and will likely lead to higher fuel costs for consumers across Indiana, Ohio, and Pennsylvania. On November 19, 2025, the FTC finalized the consent order in this matter. 

The Federal Trade Commission will require automotive services company Valvoline Inc. and private equity firm Greenbriar Equity Fund V., L.P. (Greenbriar) to divest 45 quick-lube oil change shops to resolve antitrust concerns surrounding their $625 million deal. Main Street Auto, LLC will acquire the divested outlets from Greenbriar under the terms of the FTC’s proposed divestiture order.

In July 2024, the Federal Trade Commission announced that it stopped the operators of a scheme that it says tricked financially strapped consumers seeking student loan relief into paying hundreds of dollars in junk fees. The operators often targeted Spanish-speaking consumers in Puerto Rico, pretended to be affiliated with the Department of Education and its loan servicers, and made false promises of low, permanently fixed monthly payments and loan forgiveness.

A federal court temporarily halted the scheme and froze its assets at the request of the FTC.

In May 2025, the FTC announced that the operators of the scam have agreed to be permanently banned from the debt relief industry and to turn over their assets to resolve allegations that they misled consumers.

The Federal Trade Commission will require Synopsys, Inc. and Ansys, Inc., under a proposed consent order, to divest certain assets to resolve antitrust concerns surrounding their $35 billion merger. The proposed consent order settles FTC allegations that Synopsys’s acquisition of Ansys is anticompetitive across three markets – optical software tools, photonic software tools for designing and simulating photonic devices, and RTL power consumption analysis tools. The FTC finalized the consent order on October 17, 2025.