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Most FTC enforcement actions are initially filed under seal along with an ex parte application for Temporary Restraining Order (TRO). Typically, TRO seeks an asset freeze with respect to all merchant funds, and typically extends to all third parties in possession or control of funds attributable to the marketer or its principals – including all banks and payment facilitators. Most TROs also seek the appointment of a temporary receiver to take control of the marketer’s business and assets to prevent further consumer fraud and ensure that such funds are preserved for the purposes of consumer redress. In short: You lose control completely. Let our experienced FTC defense lawyers help you with your case.
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