Legal Library: Cases and Proceedings

Online cash advance company Cleo AI has agreed to pay $17 million to settle the Federal Trade Commission’s allegations that the company deceived consumers about how much money they could get and how fast that money could be available. The complaint, filed in federal district court along with the proposed settlement order, also alleges that Cleo made it difficult for consumers to cancel Cleo’s subscription service.

As a result of a Federal Trade Commission lawsuit, Publishers Clearing House (PCH) has agreed to a proposed court order will require it to pay $18.5 million to consumers who spent money and wasted their time, and make substantial changes to how it conducts business online.

In a complaint against PCH, the FTC charges that the company uses “dark patterns” to mislead consumers about how to enter the company’s well-known sweepstakes drawings and made them believe that a purchase is necessary to win or would increase their chances of winning, and that their sweepstakes entries are incomplete even when they are not. The FTC also charges that the company has added surprise shipping and handling fees to the costs of products, misrepresented that ordering is “risk free,” used deceptive emails as part of its marketing campaign, and misrepresented its policies on selling users’ personal data to third parties prior to January 2019. Many consumers affected by these practices are older and lower-income.

In April 2025, the FTC sent more than $18 million in refunds to consumers harmed by misleading claims made by Publishers Clearing House (PCH).

In April 2025, the FTC issued a proposed order requiring Workado, LLC to stop advertising the accuracy of its artificial intelligence (AI) detection products unless it maintains competent and reliable evidence showing those products are as accurate as claimed. The settlement will be subject to public comment before becoming final.

In January 2025, the FTC announced a complaint and proposed order require software provider accessiBe to pay $1 million to settle allegations that it misrepresented the ability of its AI-powered web accessibility tool to make any website compliant with the Web Content Accessibility Guidelines (WCAG) for people with disabilities. The Commission approved the order as final in April 2025.

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 took action to resolve antitrust concerns related to Chevron Corporation’s acquisition of rival oil producer Hess Corporation by approving a proposed consent order that would prohibit Chevron from appointing Hess CEO John B. Hess to its Board of Directors.

The FTC’s complaint alleges that Mr. Hess communicated publicly and privately with the past and current Secretaries General of the Organization of Petroleum Exporting Countries (OPEC) and an official from Saudi Arabia. In these communications, Mr. Hess stressed the importance of oil market stability and inventory management and encouraged these officials to take actions on these issues and speak about them at different events, the complaint alleges.

The Federal Trade Commission moved to block Tempur Sealy International, Inc.’s (Tempur Sealy) proposed $4 billion acquisition of Mattress Firm Group Inc. (Mattress Firm).

The Commission issued an administrative complaint and authorized a lawsuit in federal court to block the acquisition, alleging that Tempur Sealy—the world’s largest mattress supplier and manufacturer—will have the ability and incentive to suppress competition and raise prices for mattresses for millions of consumers once it acquires Mattress Firm.

Enbridge Inc. and Spectra Energy Corp agreed to settle FTC charges that their proposed merger likely would harm competition in the market for pipeline transportation of natural gas in three production areas off the coast of Louisiana. According to the FTC’s complaint, the merger likely would reduce natural gas pipeline competition in three offshore natural gas producing areas in the Gulf of Mexico—Green Canyon, Walker Ridge and Keathley Canyon—leading to higher prices for natural gas pipeline transportation from those areas. In portions of the affected areas, the FTC alleged, the merging parties’ pipelines are the two pipelines located closest to certain wells and, as a result, are likely the lowest cost pipeline transportation options for those wells. According to the FTC, the merger would give Canada-based Enbridge an ownership interest in both pipelines, which will give it access to competitively sensitive information of the Discovery Pipeline, as well as significant voting rights over the Discovery Pipeline. Access to its competitor’s competitively sensitive information and significant voting rights would provide Enbridge with the incentive and opportunity to unilaterally increase pipeline transportation costs for natural gas producers located in the affected areas. The exchange of information also may increase the likelihood of tacit or explicit anticompetitive coordination between the Walker Ridge Pipeline and the Discovery Pipeline. Under the settlement with the FTC, the companies have agreed to conditions that will preserve competition in those areas.The consent agreement requires Enbridge to establish firewalls to limit its access to non-public information about the Discovery Pipeline. Board members of the Spectra-affiliated companies that hold a 40 percent share in the Discovery Pipeline must recuse themselves from any vote involving the pipeline, with two limited exceptions. Also under the order, Enbridge must notify the Commission before acquiring an ownership interest in any natural gas pipeline operating in the Green Canyon, Walker Ridge and Keathley Canyon areas, or increasing the 40 percent ownership interest of Spectra affiliate DCP Midstream Partners, LP in the Discovery Pipeline.

In April 2025, the FTC approved a petition by Enbridge Inc. to reopen and set aside the Commission’s 2017 final consent order related to Enbridge’s merger with Spectra Energy Corp.

In October 2021, the FTC sued Xlear, Inc., a Utah-based company, for violating the COVID-19 Consumer Protection Act, alleging that it falsely pitched its saline nasal sprays as an effective way to prevent and treat COVID-19. DOJ filed the complaint on the FTC’s behalf. In March 2025, the DOJ agreed to dismiss the case with prejudice. 

The Federal Trade Commission, jointly with the Department of Justice and the U.S. Food and Drug Administration, have sued a New York-based marketer of herbal tea, seeking to permanently block deceptive ads that claim its Earth Tea is clinically proven to treat, cure, and prevent COVID-19.

At the request of the Federal Trade Commission, a federal court temporarily halted  a business opportunity scheme known as Click Profit, which took millions from consumers by falsely promising consumers that they could earn big profits through online sales.

In a complaint, the FTC alleged that Click Profit and its owners deceived consumers by promising they could make large sums in “passive income” using a proprietary system powered by artificial intelligence. The system supposedly enables consumers to sell goods through online platforms such as Amazon, Walmart, and TikTok. Click Profit also deceived consumers by claiming to be affiliated with major companies like Nike and Disney as a ploy to convince consumers to turn over tens of thousands of dollars each, according to the complaint.

In July 2024, the FTC took action against online used car dealer Vroom for misrepresenting that it thoroughly examined all vehicles before listing them for sale and failing to obtain consumers’ consent to shipment delays or provide prompt refunds when cars weren’t delivered in the time Vroom promised. The company agreed to a proposed settlement that would require the company to pay $1 million to refund consumers harmed by the company’s conduct.

In March 2025, the FTC sent more than $934,000 in refunds to consumers who were harmed by online used car dealer Vroom’s shipment delays.

In July 2024, the FTC announced that online career-training company, Career Step, LLC has been ordered to pay $43.5 million in debt cancellation and cash to resolve charges brought by the Federal Trade Commission that alleged the company lured consumers, specifically servicemembers and their families, with deceptive ads that falsely touted inflated employment outcomes, job placement, and partnerships with prominent companies.

In March 2025, the FTC sent more than $15.5 million in refunds to consumers who were harmed by Career Step’s deceptive advertising.