Second Circuit -- Federal Trade Commission v. Bronson Partners, LLC

Federal Trade Commission v. Bronson Partners, LLC

False advertising - Section 13(b) of the FTC Act permits not merely injunctive relief, but also ancillary remedies, incl. disgorgement.

Extensive discussion of remedies in law v. equity.


Disgorgement can function as an equitable remedy - no tracing to individual victims need be established.


Disgorgement should be of the gross takings, not the net.