On July 1, 2021, the Federal Trade Commission (FTC) voted to rescind a 2015 Commission “Statement of Enforcement Principles Regarding ‘Unfair Methods of Competition’ Under Section 5 of the FTC Act.” WLF filed comments with theĀ  Commission arguing that allowing a mere 6 days of public comment on such a significant enforcement-policy decision undermines that laudable goal. We also explained that the legislative history underlying the FTC Act’s passage supports the principles expressed in the 2015 Statement, and we attached to our comment a 2014 WLF Working Paper entitled “‘Unfair Methods of Competition’: The Legislative Intent Underlying Section 5 of the FTC Act” which supports our argument.


WLF comment