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This note argues that the Seventh Circuit’s deviation from years of precedent in FTC v. Credit Bureau is an improper interpretation of Supreme Court precedent. For decades, Section 13(b) has allowed the Federal Trade Commission to be able to pursue equitable monetary orders in the form of restitution and disgorgement as ancillary relief to permanent injunctions. The Seventh Circuit put an abrupt end to these powers relying on Supreme Court precedent that has never been used in this manner. If this circuit split continues to exist, it will create a great disparity in the Federal Trade Commission’s ability to bring enforcement actions against those who have wronged consumers and potentially impacts other federal agencies. This Seventh Circuit precedent must be reversed in order to preserve fairness in the marketplace and ensure consumers can be quickly and fully redressed when wrongful acts are committed.

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