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Administrative Procedure Act Rulemaking Process FTC Act

Kelley Drye & Warren LLP

Can Two FTC Commissioners of the Same Party Constitute a Quorum?

Tuesday, President Trump fired the two Democratic members of the Federal Trade Commission, Commissioners Alvaro Bedoya and Rebecca Kelly Slaughter. President Trump’s action leaves Chair Andrew Ferguson (R) and Commissioner...more

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

Venable LLP on

Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more

Troutman Pepper Locke

Fifth Circuit Vacates FTC’s CARS Rule

Troutman Pepper Locke on

Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in...more

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