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Credit Bureau Center, LLC, et al. v. Federal Trade Commission

Paid petition · United States Court of Appeals for the Seventh Circuit, No. 18-2847, 18-3310 · judgment August 21, 2019


Certiorari denied · July 9, 2020
Pre-decision estimate: 8% cert probability (95% interval 5%–14%)

Before the decision, about 2× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a circuit split argued in the petition, and a business petitioner.

Question presented

Section 13(b) of the FTCA expressly authorizes the commission to “file suit” to enjoin allegedly false, misleading or deceptive trade practices with a temporary restraining order, preliminary injunction “pending the issuance of an administrative complaint” when an individual or corporation is “violating, or about to violate” the FTCA. If an administrative complaint is not filed within twenty days of issuance of temporary or preliminary injunctive relief, the injunction must be dissolved. Section 19 provides an elaborate enforcement scheme that authorizes the FTC to file direct enforcement actions in the district court for relief including but not limited to consumer redress, refunds, restitution and an unqualified grant of full equitable “relief as the court deems necessary.” The question presented is: Whether Section 13(b)’s second proviso providing that the FTC “may seek” a permanent injunction is an independent grant of authority to “file suit” seeking implied consumer redress remedies circumventing the elaborate enforcement scheme set by Congress?

Counsel of record

For petitioner
Neal Kumar Katyal
Milbank LLP

For respondent
Alden Francis Abbott
U.S. Federal Trade Commission

Case

Conference history
Distributed for 5 conferences

Linked docket
19A528

Proceedings

  1. Jul 09 2020
    Petition DENIED.
  2. Jul 08 2020
    DISTRIBUTED for Conference of 7/8/2020.
  3. Jun 29 2020
    DISTRIBUTED for Conference of 7/1/2020.
  4. Jun 22 2020
    DISTRIBUTED for Conference of 6/25/2020.
  5. Apr 28 2020
    DISTRIBUTED for Conference of 5/15/2020.
  6. Apr 02 2020
    Rescheduled.
  7. Apr 01 2020
    DISTRIBUTED for Conference of 4/17/2020.
  8. Apr 01 2020
    Reply of petitioners Credit Bureau Center, et al. filed.
  9. Mar 23 2020
    Brief of respondent Federal Trade Commission in opposition filed.
  10. Feb 20 2020
    Motion to extend the time to file a response is granted and the time is extended to and including March 23, 2020.
  11. Feb 19 2020
    Motion to extend the time to file a response from February 21, 2020 to March 23, 2020, submitted to The Clerk.
  12. Jan 20 2020
    Petition for a writ of certiorari filed. (Response due February 21, 2020)
  13. Nov 18 2019
    Application (19A528) granted by Justice Kavanaugh extending the time to file until January 18, 2020.
  14. Nov 09 2019
    Application (19A528) to extend the time to file a petition for a writ of certiorari from November 19, 2019 to January 18, 2020, submitted to Justice Kavanaugh.