Legal Library: Cases and Proceedings

In January 2026, at the Federal Trade Commission’s request, a U.S. district court in Florida has temporarily stopped the operations of a web of companies and individuals that the FTC alleges caused tens of millions of dollars in harm through the deceptive marketing of health care plans. 

The Federal Trade Commission has sued Facebook, alleging that the company is illegally maintaining its personal social networking monopoly through a years-long course of anticompetitive conduct. The complaint alleges that Facebook has engaged in a systematic strategy—including its 2012 acquisition of up-and-coming rival Instagram, its 2014 acquisition of the mobile messaging app WhatsApp, and the imposition of anticompetitive conditions on software developers—to eliminate threats to its monopoly. The Commission vote to authorize staff to file for a permanent injunction and other equitable relief in the U.S. District Court for the District of Columbia was 3-2. Commissioners Noah Joshua Phillips and Christine S. Wilson voted no.

In July 2020, the Federal Trade Commission filed a complaint in federal court against the California-based marketers and promoters of bogus treatments for serious medical conditions.  The defendants are two corporations headquartered in Porterville, California, and two of their executives: Huu Tieu, president and CEO of both companies; and Stephen Meis, Medical Director and board member of Golden Sunrise Nutraceutical.  The complaint alleged that defendants have promoted and sold a variety of products through "plans of care" ranging in price from $23,000 to $200,000, which falsely claim to treat or cure COVID-19, cancer, Parkinson's disease, etc. On June 14, 2021, the FTC announced a proposed order barring the defendants from making bogus health claims. In January 2024, the FTC announced the process defrauded consumers can use to seek refunds. In February 2026, the FTC announced it was sending refund checks to eligible consumers, as well as an online process for eligible consumers who have not yet submitted a claim to do so. 

To settle Federal Trade Commission charges that it engaged in deceptive and unfair practices, Dun & Bradstreet (D&B) has agreed to an order requiring substantial changes in the firm’s operations that will benefit small- and mid-sized businesses. Under the proposed order, D&B will also provide refunds to certain businesses that purchased the company’s products in the belief that using the products would improve their business credit scores and ratings.

The Federal Trade Commission announced that grocery delivery provider Instacart will pay $60 million in refunds to consumers to settle allegations that the company engaged in numerous unlawful tactics that harmed shoppers and raised the cost of grocery shopping for Americans. Instacart will be required to cease its deceptive practices under a proposed FTC order, and consumers who were charged for Instacart+ without their express informed consent will receive refunds as a result of the settlement.

In July 2025, the Federal Trade Commission announced that the operators of telemedicine company Southern Health Solutions, Inc., doing business as Next Medical and NextMed, have agreed to settle the FTC’s charges that they used deceptive claims about costs and weight loss, fake reviews, and fake testimonials to lure consumers into buying their weight-loss membership programs that had hidden terms and conditions.

The proposed order requires NextMed and its principals to pay $150,000, which is expected to be used to provide refunds to consumers.

The FTC has taken action against NGL Labs, LLC and two of its co-founders, Raj Vir and Joao Figueiredo, for a host of law violations related to their anonymous messaging app, including unfairly marketing the service to children and teens.

In July 2024, the FTC took action against NGL Labs, LLC and two of its co-founders, Raj Vir and Joao Figueiredo, for a host of law violations related to their anonymous messaging app, including unfairly marketing the service to children and teens. 

In January 2026, the Commission announced the claims process through which potentially defrauded consumers could see refunds from the FTC.

The FTC is taking action against Illusory Systems Inc. for failing to implement adequate data security measures, leading to a major security breach in which hackers stole $186 million from consumers.

The Federal Trade Commission sued to block Henkel AG & Co. KGaA (Henkel), the manufacturer of the industry-leading Loctite brand construction adhesives, from acquiring Loctite’s main competitor, Liquid Nails. The FTC alleges that the merger would eliminate fierce competition between Loctite and Liquid Nails, leading to higher prices, lower quality, and reduced innovation, all of which would be detrimental to American consumers.

In July 2024, NRRM, LLC, which does business as CarShield, along with American Auto Shield, LLC, the administrator of its vehicle service contracts, agreed to pay $10 million to settle FTC charges that its advertisements and telemarketing for VSC are deceptive and misleading, and that many purchasers found that many repairs were not “covered,” despite making payments of up to $120 per month. The FTC also alleges CarShield’s celebrity and consumer endorsers made false statements in its ads. In December 2025, the FTC announced it was sending $9.6 million to defrauded consumers.  

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 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 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 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.

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. 

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.