When Unclear Retail Rent-To-Own Terms Draw FTC Ire

Law360 (May 28, 2020, 6:18 PM EDT) -- A proposed stipulated settlement in April received little attention in part because on its face, it appeared to be a simple case where the marketing language of the offer misstated the nature of the service offered.

But the Federal Trade Commission's settlement of charges against Progressive Leasing LLC reveals several important signals for national advertisers concerning FTC priorities and enforcement trends including: the intersection of online and offline representations; the materiality and the commission's inferences about raw complaint volume; the strong commission consensus for muscular enforcement, including financial penalties and consequences; and even more aggressive partisan considerations, including a desire for...

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