Legal Library: Cases and Proceedings

In March 2026, the FTC announced that it secured a settlement against Xponential Fitness for Franchise Rule violations and related deceptive practices, including $17 million that will be returned to franchisees, which is the largest amount ever to go back to consumers in a franchise case.

The FTC alleged that Xponential Fitness, which sells franchises for popular fitness studios brands such as Club Pilates, Pure Barre, YogaSix, StretchLab, and BFT, misrepresented key information about the costs, risks, time to open and operate studios, and essential details about the company’s operations, leaving many franchisees and prospective franchisees in the dark about their investment.

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.

In November 2018, the FTC announced that a federal district court in Maryland issued an order temporarily shutting down the largest overseas real estate investment scam the FTC has ever targeted. According to the FTC, the scam was established by Andris Pukke, a recidivist scammer currently living in California, and he perpetuated it even while serving a prison sentence for obstruction of justice. The alleged scheme took in more than $100 million, marketing lots in what supposedly would become a luxury development in Central America known by several names, including Sanctuary Belize, Sanctuary Bay, and The Reserve. The FTC alleged that the defendants misled consumers when selling these lots, lying about how risky investments in the development were, how the development was funded, what would be done with money paid for lots, what amenities the development would have, the timeframe those amenities would be built, consumers’ ability to resell lots, and Andris Pukke’s involvement. Several defendants settled prior to the January 2020 trial.

In late August 2020, the district court issued its verdict, finding in favor of the FTC. In early 2021, the court issued final orders against Andris Pukke, Peter Baker, Luke Chadwick, John Usher, and the corporate defendants, limiting what types of business they can engage in moving forward and entering a $120.2 million judgment against them. The defendants appealed and largely lost. During the appeal, Luke Chadwick settled, turning over certain assets and agreeing to a modified order further limiting the types of business he can engage in. After the appeal, the district court entered an order confirming that Andris Pukke, Peter Baker, and John Usher must turn over $120.2 million as well as the corporate defendants and their assets to compensate their victims.  In August 2023, the FTC sent approximately $10 million to consumer defrauded by the Sanctuary Belize investment scheme. In February 2026, the FTC announced a second redress mailing to consumer victims of the scheme.

The Federal Trade Commission issued an administrative complaint to block medical device supplier Edwards Lifesciences Corp.’s (Edwards) proposed acquisition of JenaValve Technology, Inc. (JenaValve) due to concerns that the acquisition would limit patient access to lifesaving medical devices used to treat a potentially fatal heart condition. On January 9, 2026, after a six-day trial, the U.S. District Court for the District of Columbia granted the FTC’s request for a preliminary injunction to temporarily prevent Edwards from acquiring JenaValve.

According to the FTC’s complaint, Rytr’s service generated detailed reviews that contained specific, often material details that had no relation to the user’s input, and these reviews almost certainly would be false for the users who copied them and published them online. In many cases, subscribers’ AI-generated reviews featured information that would deceive potential consumers who were using the reviews to make purchasing decisions. The complaint further alleges that at least some of Rytr’s subscribers used the service to produce hundreds, and in some cases tens of thousands, of reviews potentially containing false information.

The proposed order settling the Commission’s complaint is designed to prevent Rytr from engaging in similar illegal conduct in the future. It would bar the company from advertising, promoting, marketing, or selling any service dedicated to – or promoted as – generating consumer reviews or testimonials. 

On December 22, 2025, the FTC issued an order to reopen and set aside a 2024 final consent order involving Rytr LLC.

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 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 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 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 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.

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. 

At the FTC’s request, a federal court has temporarily halted the operation of a sprawling business opportunity scheme that has taken in millions of dollars from consumers with bogus promises of huge returns. The scheme has operated since at least 2018 under several names, including “Blueprint to Wealth,” according to the FTC’s complaint. Three individuals and a company owned by one of them -- Business Revolution Group -- are charged in the complaint with operating the scheme. The defendants in the case agreed to settlements with the FTC that include monetary judgments, industry bans, and prohibitions on certain conduct. 

In September 2025, the FTC announced it was returning $666,631 to consumers defrauded by a sprawling business opportunity scheme.

In September 2025, the FTC announced that Whaleco, Inc., which operates the online marketplace Temu, will pay $2 million to resolve Federal Trade Commission allegations that it violated the INFORM Consumers Act of 2023, by failing to provide consumers with required information and tools to help them avoid and report stolen, counterfeit, or unsafe goods while shopping online.

The FTC is taking action against Arise Virtual Solutions for misleading consumers about the money they could make on Arise’s platform and marketing its business opportunity without complying with the FTC’s Business Opportunity Rule.

In August 2025, the FTC sent more than $6.7 million to consumers impacted by the gig work company’s deceptive earnings claims.

The FTC sued a ticket broker operation for allegedly using unlawful tactics to exceed ticket purchasing limits for many popular events, including Taylor Swift’s Eras Tour, and resell the tickets at significantly higher prices, generating millions in revenue. The operators include Key Investment Group and its affiliated companies, which have done business under such names as Epic Seats, TotalTickets.com LLC, and Totally Tix LLC, as well as Key Investment Group’s CEO, Yair D. Rozmaryn, Chief Financial Officer, Elan N. Rozmaryn, and Chief Strategic Officer, Taylor Kurth.

The FTC alleges that Grand Canyon Education (GCE), Inc., Grand Canyon University (GCU) and Brian Mueller—the CEO of GCE and president of GCU—deceived prospective doctoral students about the cost and course requirements of its doctoral programs and about being a nonprofit, while also engaging in deceptive and abusive telemarketing practices. The FTC announced on August 15, 2025 it had voted to dismiss the case.

In August 2025, the FTC announce Assurance IQ, LLC and MediaAlpha, Inc. will pay a total of $145 million to settle that they misled millions of consumers seeking to buy comprehensive health insurance. The FTC alleged that both Assurance and MediaAlpha deceived consumers and led them to purchase plans that did not provide the promised health care coverage, and bombarded consumers with telemarketing and robocalls. 

In August 2025, the FTC announce Assurance IQ, LLC and MediaAlpha, Inc. will pay a total of $145 million to settle that they misled millions of consumers seeking to buy comprehensive health insurance. The FTC alleged that both Assurance and MediaAlpha deceived consumers and led them to purchase plans that did not provide the promised health care coverage, and bombarded consumers with telemarketing and robocalls. 

In June 2024, the FTC filed suit against FBA Machine and Bratislav Rozenfeld (also known as Steven Rozenfeld and Steven Rozen) alleging that, in a business opportunity scheme, they falsely guaranteed that consumers could make money operating online storefronts using AI-powered software. The defendants allegedly failed to deliver on the promised earnings claims and defrauded consumers out of over $15 million.

As a result of the FTC’s complaint, a federal court issued an order temporarily halting the scheme and putting it under the control of a receiver.

The FTC later added Amanda Peremen, Rozenfeld’s wife, as a relief defendant in the case. The amended complaint alleged that, though not directly involved in the scheme, she received proceeds from it.

In July 2025, the FTC announced that Rozenfeld will be permanently banned from selling business opportunities in settlement of FTC’s allegations and will be required to turn over the contents of multiple financial accounts and any funds realized upon the sale of real estate property. The proceeds will be used for consumer redress.