Legal Library: Cases and Proceedings

The Federal Trade Commission, along with 22 agencies from 19 states, stopped a deceptive charity fundraising scheme and its operators who made false or deceptive claims to U.S. donors.

Kars-R-Us.com, Inc. (Kars) and its operators, Michael Irwin and Lisa Frank, solicited charitable donations nationwide on behalf of United Breast Cancer Foundation, Inc. (UBCF), a charity that claims to assist individuals affected by breast cancer, according to a complaint filed by the FTC and states (link to complaint).

Under a proposed settlement order reached with the FTC and its state partners, Kars and its operators face restrictions on future fundraising activities and Irwin, Kars’s President and co-owner until 2022, will be permanently banned from fundraising.

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 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 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.

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.

CVS agreed to settle allegations that its acquisition of Revco would substantially reduce competition for the retail sale of pharmacy services to health insurance companies and other third-party payers in Virginia and in the Binghamton, New York metropolitan area. The consent order requires the divestiture of 114 Revco stores in Virginia and 6 pharmacy counters in Binghamton.

In March, 1998, CVS Corporation agreed to pay a $600,000 civil penalty to settle Federal Trade Commission charges that the company violated a 1997 consent order and asset maintenance agreement it signed with the agency to settle charges stemming from CVS's 1997 acquisition of Revco D.S., Inc.

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.

The FTC and seven states sued Ticketmaster and Live Nation alleging they deceived artists and consumers by engaging in bait-and-switch pricing through advertising lower prices for tickets than what consumers must pay to purchase tickets; deceptively claimed to impose strict limits on the number of tickets that consumers could purchase for an event, even though ticket brokers routinely and substantially exceeded those limits; and sold millions of tickets, often at much higher cost to consumers, on its resale platform that those brokers obtained in excess of artists’ ticket limits.

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 judgements, 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 Federal Trade Commission announced that Chegg Inc. will be required to pay $7.5 million to settle FTC allegations that the education technology provider made it extremely difficult for consumers to cancel recurring subscriptions while also failing to honor consumers’ cancellation requests. 

The Federal Trade Commission has stopped a scheme that allegedly bilked millions of dollars out of consumers burdened with student loan debt by pretending to be affiliated with the U.S. Department of Education in violation of the FTC’s Impersonation Rule, collecting illegal advance fees, and making other deceptive claims.

The U.S. District Court for the District of Nevada entered a temporary restraining order on November 22, 2024 and a preliminary injunction against corporate defendant Superior Servicing on December 6, 2024.  

The Federal Trade Commission filed an amended complaint adding corporate defendants Sunrise Solutions USA LLC, Alumni Advantage LLC, Student Processing Center Group LLC, SPCTWO LLC, Accredit LLC and individual defendants Eric Caldwell and David Hernandez. 

In September 2025, the FTC announced that Caldwell and Hernandez will be permanently banned from the debt relief industry and will be required to turn over their assets to resolve FTC charges that they helped operate an illegal student loan debt-relief operation. Additionally, Caldwell will be banned from the telemarketing industry, and Hernandez will be prohibited from violating the Telemarketing Sales Rule.

Litigation continues against Merdjanian and the corporate defendants.

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.

Disney will pay $10 million to settle Federal Trade Commission allegations that the company allowed personal data to be collected from children who viewed kid-directed videos on YouTube without notifying parents or obtaining their consent as required by the Children’s Online Privacy Protection Rule (COPPA Rule).