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Will the FTC Need to Rethink Its Enforcement Playbook (Part II)? Circuit Split Casts Doubt on the FTC’s Ability to Seek Restitution in Section 13(b) Suits

Published Jul 17, 2020Updated Jun 20, 2025

The Congressional Research Service is a nonpartisan policy and legal analysis arm of the Library of Congress. CRS reports are written for members of Congress and their staff, not the public — but they’re made available openly through Congress.gov.

Will the FTC Need to Rethink Its Enforcement Playbook (Part II)? Circuit Split Casts Doubt… — Informed