Legal Library: Cases and Proceedings

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 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.

The FTC reached a settlement with Apitor Technology over allegations that its app enabled a third party in China to collect geolocation information from children without parental consent.

The Citizens Disability, LLC and its subsidiary will pay a $1 million penalty to resolve FTC allegations that they made tens of millions of illegal calls to consumers and that they misrepresented that they were calling consumers in response to inquiries about their eligibility for Social Security Disability Insurance (SSDI) benefits. 

The Federal Trade Commission sued Zillow and Redfin over an unlawful agreement that eliminates Redfin as a competitor in the market for placing advertising of rental housing on internet listing services (ILSs)—the websites that millions of Americans use to find their next rental home. The complaint alleges that in February 2025, Zillow and Redfin entered into an illegal agreement to dismantle Redfin as a competitor in the ILS advertising market for multifamily rental properties.

Under a final order with the FTC, Seek Capital and its CEO Roy Ferman have been permanently banned from providing business financing, debt relief and credit repair services to settle allegations that the firm deceived entrepreneurs and small business owners seeking business funding.

Dun & Bradstreet agreed to a $5.7 million settlement with the Federal Trade Commission over allegations the firm violated a 2022 order.

The FTC is taking action against the operator of the Sendit anonymous messaging app for unlawfully collecting personal data from children, misleading users by sending messages from fake “people,” and tricking consumers into purchasing paid subscriptions by falsely promising to reveal the senders of anonymous messages.

The Federal Trade Commission took action to resolve antitrust concerns related to Omnicom Group Inc.’s $13.5 billion acquisition of The Interpublic Group of Companies, Inc. (IPG).

The FTC accepted a proposed consent order that will prevent potential anticompetitive coordination by Omnicom, a global advertising agency that facilitates media buying by representing advertisers in negotiations with media publishers over conditions such as pricing, ad placement, and sponsorships, as well as helping execute advertisers’ ad campaigns.

On September 26, 2025, the FTC approved a final order in this matter which further clarifies the order’s scope and imposes a compliance monitor.

The Federal Trade Commission is taking action against Amazon.com, Inc. for its years-long effort to enroll consumers into its Prime program without their consent while knowingly making it difficult for consumers to cancel their subscriptions to Prime.

In a complaint filed today, the FTC charges that Amazon has knowingly duped millions of consumers into unknowingly enrolling in Amazon Prime. Specifically, Amazon used manipulative, coercive, or deceptive user-interface designs known as “dark patterns” to trick consumers into enrolling in automatically-renewing Prime subscriptions.

Amazon also knowingly complicated the cancellation process for Prime subscribers who sought to end their membership. The primary purpose of its Prime cancellation process was not to enable subscribers to cancel, but to stop them. Amazon leadership slowed or rejected changes that would’ve made it easier for users to cancel Prime because those changes adversely affected Amazon’s bottom line. 

The FTC filed a complaint alleging that Mercury Marketing, LLC, and other defendants impersonated substance use disorder treatment clinics in Google search ads to deceptively route consumers trying to call those clinics to defendant clinics.