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Kristin J. Madigan is a partner in Crowell & Moring’s San Francisco office and a member of the firm’s Litigation and Privacy & Cybersecurity groups. Kristin focuses her practice on representing clients in high-stakes complex litigation with a focus on technology, as well as privacy and consumer protection matters including product counseling, compliance, investigations, enforcement, and litigation that typically involves existing and emerging technologies. In addition, Kristin is well-versed in and counsels clients on California Consumer Privacy Act (CCPA) compliance. Kristin is a Certified Information Privacy Professional/United States (CIPP/US).

Wednesday, November 26, 2025

Bureau of Competition; Competition; Nonmerger; Noncompete

  • The FTC finalized a consent order requiring Gateway Services, Inc. and its subsidiary, Gateway US Holdings, Inc. (collectively “Gateway”) to stop entering into or enforcing noncompete agreements on their employees. The order followed the FTC’s September 2025 complaint, which alleged that Gateway’s noncompete agreements were anticompetitive and suppressed competition. Previously, these agreements prohibited Gateway employees from working in the pet cremation industry anywhere in the United States for one year after leaving the company. Under the consent order, Gateway must stop enforcing its existing noncompete agreements and is prohibited from entering into similar agreements in the future.

Continue Reading Updates November 24 – December 5, 2025

Due to the government shutdown, the FTC is closed aside from essential services.  Therefore, Crowell’s FTC updates will resume after the shutdown ends.

The FTC proposed recommendations to rescind and lighten its own regulations. The agency also published its 47th Annual Hart-Scott-Rodino (HSR) Report summarizing merger enforcement actions in 2024. These stories, and more, after the jump.Continue Reading FTC Updates September 2 – 26, 2025

On July 14, 2025, the FTC announced its enforcement action against telemedicine company NextMed over charges it used misleading prices, fake reviews and deceptive weight-loss claims to sell GLP-1 weight-loss drugs. The FTC has now settled its charges that NextMed used deceptive practices to lure consumers into buying their weight-loss membership programs that had hidden terms and conditions. With the rise of both authentic and counterfeit GLP-1s throughout the nation and the proliferation of the availability of GLP-1s from telemedicine/telehealth companies, online pharmacies and medspas, this announcement is a sign that the federal government will actively monitor these entities to ensure consumers are getting genuine, authentic GLP-1s, that consumers are making informed decisions about weight-loss drugs, and that consumers are not being deceived and duped in the frenzy over GLP-1s.Continue Reading FTC Uses Its Consumer Protection Powers to Regulate Sellers of GLP-1s

The FTC is heading into summer with an active docket. The agency has been keeping its eye on enforcement, issuing warning letters to contact lens prescribers over potential violations of the agency’s Contact Lens and Eyeglass Rules. Over the next few weeks, it plans on hosting a workshop on healthcare advertising and listening sessions on prescription drug pricing and competition. These stories, and more, after the jump. Continue Reading FTC Updates (May 26 – June 16, 2025)

This week, the FTC’s Bureau of Consumer Protection has been busy addressing the “Attention Economy,” false income claims, privacy and data security, and a student debt relief scam. On the competition side, the FTC enforced against raising prices for anesthesiology services. These stories, and more, after the jump.Continue Reading FTC Blog Updates May 19 – May 23, 2025

On March 18th President Trump fired the Federal Trade Commission’s two Democratic Commissioners, Alvaro Bedoya and Rebecca Kelly Slaughter. The news broke when Commissioner Bedoya took to the social media site X, stating, “I am a commissioner at the Federal Trade Commission. The president just illegally fired me. This is corruption plain and simple.”

The FTC has been active in the weeks leading up to a change in administration. The Commission has ordered that companies and the individuals who run them pay refunds paid to consumers they have allegedly misled, doubled down on enforcement against companies attempting to enforce no-hire agreements, and approved revisions to thresholds under Section 7 and 8 of the Clayton Act. These stories and more, after the jump.Continue Reading FTC Updates (December 30 – January 10, 2025)

As the year concludes, the FTC has been quite busy. Not only has the upcoming leadership transition meant the FTC has been working on a variety of matters, the transition has also highlighted stark differences in the Commissioners’ perspectives on enforcement. For example, Commissioners Holyoak and Fergusons published strong dissenting statements regarding the withdrawal of the Collaboration Among Competitors guidance and the first Robinson-Patman Act matter in nearly a quarter century. All this and more –Continue Reading FTC Updates (December 9 – 13, 2024)