Category Archives: Direct Response

Third Circuit to FTC: You Cannot Sue Over Past Violations

In “Has the FTC Lost Its Legal Mojo – Again?” (Nov. 2018), I wrote about the decision last October in FTC v. Hornbeam Special Situations kicking the Federal Trade Commission out of federal court over a consumer protection complaint that … Continue reading

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CBD Is Now Legal – Kind Of, Sort Of

The burgeoning industry around CBD, the non-intoxicating part of the cannabis plant, is euphoric.  After decades of being unfairly lumped with marijuana as a banned controlled substance, Congress had the good sense – and common sense – to separate hemp-derived … Continue reading

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To Be or Not To Be An Autodialer? That is the TCPA Question

In “Telemarketers Celebrate Rare Regulatory Win” (April 2018), I discussed the D.C. Circuit Court of Appeals decision in ACA International v. FCC invalidating key parts of the Federal Communications Commission’s (“FCC”) 2015 Omnibus Order interpreting certain provisions of the Telephone … Continue reading

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