Legal Library: Cases and Proceedings

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.

In January 2026, the Federal Trade Commission sued JustAnswer LLC and its CEO, alleging the online question-and-answer service deceives people seeking expert advice into enrolling in a monthly recurring subscription without obtaining consumers’ affirmative consent.

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.

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.

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 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 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 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 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. 

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.

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 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.

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.

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.