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Ryuu96 on 24 November 2022
In some situations, the FTC files a complaint under its administrative process instead of taking the case to a federal court. This is called an adjudicative proceeding. The party can decide to settle with us, or they can contest the charges. If they contest the case, it is heard before an administrative law judge in a trial-type proceeding.
Adjudicative Proceedings | Federal Trade Commission
I think this is what Hoeg is talking about, the complaint comes first and then the party decides if they want to settle or contest. We're probably overreacting about FTC preparing a complaint, I'm upping back to 60% until we know what type of complaint they're filing.
