The Federal Trade Commission (“FTC”) released a new Policy Statement of its enforcement priorities for Section 5 of the FTC Act, which makes unlawful “unfair methods of competition.” Since the passage of the FTC Act in 1914, the FTC has struggled to define with precision what conduct violates § 5 beyond conduct that is unlawful under other antitrust laws. If implemented as drafted, the Policy Statement would mark a significant expansion of antitrust enforcement. However, past FTC efforts at expansive § 5 enforcement have been rejected in the courts.