Facts

Following its investigations, the Federal Trade Commission filed a complaint against True Ultimate Standards Everywhere Inc. dba TRUSTe Inc.

COMPLAINANT'S CONTENTIONS:
The FTC alleged that respondent advertised or otherwise offered for sale, privacy services and other compliance tools. Respondent also offered Privacy Seal Programs. Respondent advertised itself as "the [number] 1 privacy brand." Respondent also represented that its seal had global recognition and demonstrated "best practices" in privacy.

The FTC alleged that from 2006 until January 2013, respondent did not conduct annual recertification of some clients holding the seal. However, such clients continued to display the seal. As such, the FTC alleged that respondent misrepresented certification status of its clients by expressly or impliedly representing that it had recertified the clients that displayed the seal. Respondent also allegedly misrepresented that display of the seal denoted ongoing compliance with the program requirements.

Result

The parties entered into a consent order to settle the dispute. The order provided both for injunctive and monetary relief. TRUSTe agreed to comply with the terms of the order, including payment of $200,000 as disgorgement.

Other Information

COMMISSIONERS: Edith Ramirez, Chairwoman, Julie Brill, Maureen K. Ohlhausen, Joshua D. Wright and Terrell McSweeny.