The FCC issues new consumer privacy rules
The Federal Communications Commission (FCC) issued new rules that limit how Internet Service Providers (ISPs) use and sell customer data. The FCC's new rules recognize the fact that ISPs are increasingly looking to use and share their customers' personal information for targeted advertising. The rules are based on the premise...
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Investigative Interviews in Colorado
What happens during investigative interviews in Colorado?
Like the Wyoming Attorney General's Office, the Colorado Attorney General's Office conducts formal interviews in its investigations under the Consumer Protection Act. What happens during these interviews?
The interviews may be held in various...
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Investigative Interviews Wyoming
What happens during investigative interviews in Wyoming?
The State of Wyoming Attorney General's Office often uses investigative interviews in its investigations under the Consumer Protection Act. What happens during these interviews?
The interviews are usually held in Cheyenne, Wyoming. This happens to be the local...
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Consumer complaints up in Colorado, Wyoming and Alaska
The Consumer Financial Protection Bureau (CFPB) recently released a report about complaints that it receives from consumers. The CFPB is a consumer protection agency that focuses on consumer financial issues, like debt collection, mortgages, pay day lending, and auto loans. Interestingly, the CFPB found that complaints rose...
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Those that help faciliate deceptive marketing can also be held liable
On September 23rd, 2016, the U.S. Court of Appeals for the Second Circuit affirmed a lower court ruling that LeadClick Media, LLC is liable for assisting third party affiliate marketers in the deceptive marketing of a weight-loss supplement. LeadClick recruited affiliate marketers that utilized fake news sites to direct online consumers to...
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Should I dissolve my company if it is under investigation?
When faced with an investigation by the Attorney General's Office, a common consideration for single owner limited liability companies is whether to dissolve. It may seem that logic would dictate that dissolution would end the investigation, and consequently, any liability or civil penalties that might flow from the investigation. Moreover, in the...
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Substantiation for Advertising Claims
Substantiation for Advertising Claims
Companies making claims about the efficacy of their products must have a reasonable basis for those claims. The claims must be supported prior to publishing of the advertising claim. This is called "substantiation." It has long been a requirement for advertising claims, but has...
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What happens when a consumer files a complaint with the Wyoming Attorney General’s Office?
What happens when a consumer files a complaint with the Wyoming Attorney General's Office?
Each state has its own system for dealing with consumer complaints made to the Attorney General's Office. A state develops a complaint intake system and handling procedures based upon (1) its population and volume...
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FTC again highlights the importance of “Clear and Conspicuous” disclosure of the material terms
The Federal Trade Commission (FTC) yet again took action against a company for failing to clearly and conspicuously disclose the terms of its product offers. NutraClick is involved in marketing nutritional supplements. After receiving thousands of consumer complaints against NutraClick, LLC, the FTC took action against the company to...
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Defending against a Wyoming Attorney General Subpoena
The Wyoming Attorney General has strong subpoena power. However, there are limits to the Attorney General's subpoena power. The consumer protection act provides grounds for resisting a subpoena.
The Wyoming Consumer Protection Act provides that a person served with a subpoena may petition "for an order modifying or setting...
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