This is a letter to the FTC posted at its online page for public comment on the proposed settlement agreement with Facebook. Because no factual record has been established on which to base a settlement, the letter opposes it. The letter quotes Judge Jed Rakoff's recent opinion in the SEC v Citigroup case, which raised themes of regulatory capture and the need for the public interest to take precedence over the interests of corporate entities and regulators to bypass adjudications.
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