Legal Library: Cases and Proceedings

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.

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 ordered building services contractor Adamas Amenity Services LLC (Adamas) and its affiliated businesses to cease their enforcement of no-hire agreements.

Adamas used anticompetitive no-hire agreements that restrict building owners and management companies across New Jersey and New York City from directly hiring workers employed by Adamas without a significant penalty, according to the FTC’s complaint. Adamas is required to immediately cease enforcing all existing no-hire agreements under a proposed FTC order. 

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.

To view the FTC v. Meta trial exhibits, click here. Please note there is a two-business day delay in uploading exhibits. 

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.

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 Uber Technologies, Inc. and Uber USA LLC (collectively, “Uber”) for alleged violations of Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence
Act (“ROSCA”). Among other things, the complaint alleges that Uber charges consumers for its subscription service, Uber One, through a negative option feature but has failed to provide a simple mechanism to stop recurring charges. The complaint also alleges Uber has charged consumers without their consent in violation of the FTC Act and ROSCA. Further, the complaint alleges Uber falsely claims that consumers can cancel Uber One at “any time” with no additional fees. 

The FTC filed a lawsuit today against Uber, alleging the rideshare and delivery company charged consumers for its Uber One subscription service without their consent, failed to deliver promised savings, and made it difficult for users to cancel the service despite its “cancel anytime” promises.

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.  

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.

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 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 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 Federal Trade Commission will require The Boeing Company (Boeing) to divest significant Spirit AeroSystems Holdings, Inc. (Spirit) assets to resolve antitrust concerns surrounding Boeing’s $8.3 billion acquisition of Spirit.