Software-enabled price fixing schemes are pervasive in the economy, and are likely driving high prices. Why is it so hard to challenge these conspiracies under antitrust law?
Oct 27, 2023·edited Oct 27, 2023Liked by Matt Stoller
One has to wonder, how all these major corporations utilizing the same pricing software and presumably the software using their feedback on their reservation rates/sales collectively to adjust it's recommendations isn't in essence an unofficial monopoly.
In other industries where I've worked, you might have an aggregation of competitor's pricing on many items and play a guessing game as to whether you should match, beat, or go higher on pricing given your OWN sales data, costs, and availability. But you wouldn't have a ghost in the machine basically giving you a hidden inference as to what to do, because it ALSO in essence has access to your competitor's sales info.
That last piece is what brings this into the realm of price fixing and market collusion.
Read Justin Joque, "Revolutionary Mathematics: Algorithms, Statistics, and the Logic of Capitalism". Prices are what Marx called an aspect of "commodity fetishism", or "reification", the creation of a composite, quasi-natural phenomenon, that is really just a stand-in for a host of social relationships and a resultant of numerous power struggles. The "price.of.labor" was determined by the success of feudal landlords turned cash crop farmers of enclosing and violently displacimg peasant cultivators from their lands. The price of rents is determined by the ability of property owners to use police to evict tenants for nonpayment. Etc. Software simply adds yet another layer of mystification on top of all the existing ones of customs, laws, and ultimately brute force.
Fascinating article. And certainly an important issue to watch. A bit of context. It's common in industries for companies to share sales data with retail sales aggregators like NPD. In return for sharing some of your own data, you learn about the sales and average selling price of competitor products. But this does not mean you update your prices to match theirs or collude in any way. In fact, the data can tell you when there is a race to the bottom and lowering prices is bad for your business so you should get out of a category or avoid it altogether. One exception to this, which is not covered in this article, is Big Tech. Big Tech firms often do not report to these aggregators, because their pricing is often at or below cost. They don't need the data. They can already see what sells on their sites (on e-commerce) or they're using the product to simply draw customers into their ecosystem and they're not price sensitive.
Awesome, as always. In the future, try not to link just words like “here”. Blind readers listening via screen reading software often navigate by links and that link text doesn’t tell us anything about the destination.
Yay web accessibility! Keep up the hard work! I wish every American read this.
I find myself wondering why the CEOs and C-suite aren't the first ones being replaced by AI for all that juicy efficiency and cost savings. High salaries being paid out to people with a myopic fixation on maximizing profits at any cost with no sense of decency, longevity, or whether they are destroying our planet and democracy in the process.
Surely a heartless machine can do this job just as well, and maybe would even accidentally stumble upon the myriad ways their short term thinking is pennywise, but pound foolish for the longterm viability and profitability of the company... and *gasp* makes better choices! :P
I empathize with your concern about profit motives Crystal but I would reevaluate your mental model because there’s a lot in here that’s emotionally fueled and not rooted in reality nor first principles. An accurate view of history and the causes of inflation as well as the makeup of our financial system would better inform the rightful anger you have towards inflated prices. Lax anti-trust is a factor, which is why I always appreciate this Substack but the truth is rooted in a dysfunctional culture captured by ideology among other more prominent issues. In any case, the jobs that will go when prices equilibrate are the bloated HR departments, compliance, filing, many software jobs and almost any task that requires binary thinking or produce ~0 value for customers. Am I saying C-suites making 350x the average wage is fair? No way! But it’s asinine to think their job is even remotely replaceable in the next 50-100 years.
There's a bright side of AI. It may become hard to deny truths that it discovers...
What if AI gets more access to data and sees that corporations are money laundering schemes who extract wealth to shareholders taken from consumers via higher prices and worse service?
What if AI sees that finance capitalism is parasitic and produces nothing?
What if AI determines that certain utilities, like healthcare and energy are best served by public entities that can better distribute risk and gain?
What if AI starts realizing that propaganda creates distrust these days?
Sorry, the link you share leads to a writer who is an anti-vaxxer and uses psychological concepts loosely and at times inaccurately to support a paranoid view of Operation Warp Speed. Didn’t expect that here.
Did you know that if you're injured by it, there's no liability for pharma?
It's not just the covid shots. So where's the incentive for safety, like we have with drugs, which can be sued for?
The vaccine courts which are funded by fees paid by the client, not pharma, have a ridiculously low maximum settlement of 250k. Is that enough to pay even medical bills for a bad injury? No.
But yet, mandates were pushed for the covid shots which we found later do not prevent transmission. The mandates are what woke me up to look into this.
Some links about liability pre covid. The covid shots are even more restricted as they are under the PREP act.
If you expect a vaccine to prevent transmission rather than reduce it, you don’t understand what most vaccines do, i.e., the yearly flu vaccine. Mandates are appropriate in certain settings to reduce spreading a pathogen in public health emergencies. I was fully vaccinated and finally caught COVID after three years because healthcare settings like my dentist’s office under public pressure and to save the mighty dollar didn’t install filtering and air barriers to prevent patients with mouths open for hours from breathing aerosols of others in the office. Because of my vaccinations and with the help of Paxlovid, I was not severely ill despite being in my seventies with an underlying chronic condition that renders me vulnerable if I get a severe respiratory illness.
How a society that is politically divided and assaulted by disinformation and propaganda handles public health emergencies is a whole other issue when we had a grifter president over-ruling seasoned public health physicians like Dr. Fauci.
Then there’s the shallow idea that you can adequately explain propaganda and its effects via Erickson’s confusion technique in hypnosis or Festinger’s cognitive dissonance. So much more is known and was known even when those old models were presented in the last century. You would need to find the link, but The NY Times, I believe, did an at-length piece on Russia’s disinformation strategies. And lots is known about what divides us from other sources like Jonathan Haidt, Robert Jay Lifton, Robert Altemeyer sometimes writing with John Dean, and more.
There’s a better place to discuss vaccine concerns, a FaceBook group called Vaccine Talk.
Did you get all the boosters? Most of those that I know got the shots had COVID multiple times. They stopped after the first booster, since it was not mandated and there are concerns of side effects. You still aren't addressing the point that there's no liability for big pharma. That's why I decided to not get it in 2021. I can't afford to be ill and I find the mandates to be fascist as it violates the Nuremberg code which is supposed to allow for people to say NO without repercussions like losing their job.
BTW, You're the one that brought up vaccines in response to that article which was about the whole shebang of war, etc. Don't gaslight me like I was arguing about it first. I just linked an article that I found interesting regarding the current world situation and propaganda, especially about the war.
I chimed in with liability issues to remind you and others that sorry, but no, vaccines are not safe if pharma isn't liable. They have no incentive to make them safe. That's why I lost trust in them. I am perplexed how even Bernie Sanders, who I wanted to win last primaries could call out big pharma only to blindly support them with a new vaccine that has no long term safety data.
I'll answer your calm question up front. I got all of the boosters, not expecting 100% immunity, and I don't blame an mRNA vaccine for my getting COVID, which is a very adaptive pathogen. I believe that mRNA technology will give us breakthroughs in harnessing the immune system to fight terrifying illnesses like pancreatic cancer.
I didn't address the reduced liability for big pharma directly, because that opens a long and multifaceted conversation about how we as a divided society and government handle our dysfunctional healthcare industry and public health emergencies. I personally would like to see us with universal healthcare as it's done with cost savings and better outcomes in peer nations. See the SubStack newsletter by Alan Unell called "Healthcare Advocacy."
If you believe mandates are fascist, how do you feel about the mandate to not drive a car if you're above a legal limit of alcohol consumption? When a pandemic is rapidly spreading, some mandates are appropriate, such as vaccination of workers in nursing homes.
I brought up vaccines because you had linked an anti-vaxxer who also cites an astrologer, something I didn't mention. If you think that I am gaslighting because I highlight the speciousness of that author, sorry, I am challenging her credibility. Gaslighting is also a personal accusation and is unwarranted on this forum. To take this in a more relevant direction, when you're dealing with disinformation about vaccines, the sources of that disinformation will lead us in many directions so that there is always another avenue for skepticism about public health directives that are based on the best scientific findings available in an evolving situation of unknown and partially knowns. It benefits our enemies to have us divided and ruled by cranks and cons instead of being unified to oppose them.
Then you land back on your assertion that vaccines aren't safe. Almost all medical interventions, drugs, procedures, etc., have known risks. Just read the prescriber's sheet for most common medications, including statins. Because these medications go through clinical trials and testing, they will report some adverse events. But these medications and other treatments are approved because their benefits are seen to far outweigh their risks to a population that may receive that treatment. If it's later discovered that more risks emerge, those medications are pulled. That's what happens as more is known.
BTW, if Bernie Sanders supported the vaccine mandates in force at the time, you are choosing to call him blind rather than give him some benefit of the doubt. It's okay to not know for certain and to do a deeper exploration of sources you would tend to agree with, who disagree with you. That's the premise of learning to recognize anomalies in your own modeling and is a basis for breakthroughs in science (see Thomas Kuhn's writing on paradigm change).
So, it's like HAL, an algorithmic Bob . . not with low morals, but None at All, right for the job .. and no need . . with conniving sleaze ball types . .to hob nob . .. #the space takes . .
I am against judges “re-writing” any laws passed by Congress, anti-trust or immigration. Who gave Judge Du the authority to declare a century-old law racist? Nobody. Can’t wait for Matt to return.
Judges interpret the laws written by Congress. It happens all the time. Look at what the supreme court did with roe vs wade or what Bork and the Chicago school did to the antitrust via the judiciary. Whether you're against it or not that's what judges do -- interpret the laws.
I strive to be careful in the words I use, and I don’t want to come across as snarky, but I wasn’t commenting on interpreting the law. I was commenting on judges (not justices) re-writing or abolishing the law. And your example of Roe v. Wade is proving my point. A majority of justices in a body of nine found something in the constitution that didn’t exist. They made law on a controversial issue that should have been decided by the people through their state legislatures and/or congress. That overreach disenfranchised roughly half the population and led to fifty years of avoidable social conflict and tens of millions of dead babies. Such are the fruits of an activist judiciary.
I'm not making a normative argument as much as explaining that it's a function of the judiciary to interpret laws. But to be clear, I think that discretion should be limited, for the exact reason that the judiciary lacks the same form of direct accountability as other law-making branches of government. Further, laws that use vague standards for liability, like a "reasonableness" standard, are not easy for people to understand. And if you can't understand a law, how are you supposed to comply with it?
Anyway, judicial discretion is a reality, and my point is that it has been inappropriately exercised to limit the reach of antitrust laws.
Isn’t the whole point of SCOTUS to adjudicate on what the states can and cannot do based on their interpretation of what some men agreed on, intended, and wrote down centuries ago (there often being three different things there). If you ask me, it’s a ludicrous state of affairs for a nation as immense, in all ways, as the US.. but there we go. The difference between interpretation, extrapolation, and activism all mainly depends on which side you take on a particular issue. The school of thought that the Constitution should evolve and encompass rights that were not considered at the time of the founding has no less and no more grounding than the one that the founders thought that their words and opinions should be strictly enforced for eternity. If the law simply ‘is’, and the judges simply tell us what it is, how come the political sides fight to vigorously to have ‘their’ people occupying benches.
The specific case you’re concerned with is way OT. And there are plenty of comparable ones that offend different groups of people for different reasons. As an observer from overseas who is, nonetheless, very interested in SCOTUS and the politics behind it (after all, the effects of that system and it’s impact on the US reach far beyond US borders) I do read criticisms like yours and generally find that the only ones that seem in good faith are the ones that find fault with the whole goddamn setup.. but most seem to come from a place of people happy with system, just pissed at the times it didn’t agree with them.
It's worse than we think. They spend millions analyzing how to raise prices based on your behavior. Cable and phone providers perfected it - they know who will quit and who will stay. If you stay they will raise prices continuously. The treat to leave the service is no longer a threat - it's cost of doing business - they don't care.
Healthcare is so gamed - you have to think the worst and they are even worse than that. I say "Keep gov'ment in my healthcare!".
Cannot the FTC make investigative demands, pre-litigation, to obtain the documentation and other evidence needed to substantiate more particular evidence to support its factual allegations in its next Complaint?
One has to wonder, how all these major corporations utilizing the same pricing software and presumably the software using their feedback on their reservation rates/sales collectively to adjust it's recommendations isn't in essence an unofficial monopoly.
In other industries where I've worked, you might have an aggregation of competitor's pricing on many items and play a guessing game as to whether you should match, beat, or go higher on pricing given your OWN sales data, costs, and availability. But you wouldn't have a ghost in the machine basically giving you a hidden inference as to what to do, because it ALSO in essence has access to your competitor's sales info.
That last piece is what brings this into the realm of price fixing and market collusion.
Read Justin Joque, "Revolutionary Mathematics: Algorithms, Statistics, and the Logic of Capitalism". Prices are what Marx called an aspect of "commodity fetishism", or "reification", the creation of a composite, quasi-natural phenomenon, that is really just a stand-in for a host of social relationships and a resultant of numerous power struggles. The "price.of.labor" was determined by the success of feudal landlords turned cash crop farmers of enclosing and violently displacimg peasant cultivators from their lands. The price of rents is determined by the ability of property owners to use police to evict tenants for nonpayment. Etc. Software simply adds yet another layer of mystification on top of all the existing ones of customs, laws, and ultimately brute force.
Fascinating article. And certainly an important issue to watch. A bit of context. It's common in industries for companies to share sales data with retail sales aggregators like NPD. In return for sharing some of your own data, you learn about the sales and average selling price of competitor products. But this does not mean you update your prices to match theirs or collude in any way. In fact, the data can tell you when there is a race to the bottom and lowering prices is bad for your business so you should get out of a category or avoid it altogether. One exception to this, which is not covered in this article, is Big Tech. Big Tech firms often do not report to these aggregators, because their pricing is often at or below cost. They don't need the data. They can already see what sells on their sites (on e-commerce) or they're using the product to simply draw customers into their ecosystem and they're not price sensitive.
Is Rainmaker a software company that was acquired by Cendyn? Seems like even the price fixing software marketplace is getting rolled up
https://hotelbusiness.com/cendyn-acquires-the-rainmaker-group/
Yup, that's the one.
Awesome, as always. In the future, try not to link just words like “here”. Blind readers listening via screen reading software often navigate by links and that link text doesn’t tell us anything about the destination.
Yay web accessibility! Keep up the hard work! I wish every American read this.
What happens when AI simply does this with no human input because it "knows" how to optimize profit?
It's going to happen very soon, and frankly probably is happening already.
I find myself wondering why the CEOs and C-suite aren't the first ones being replaced by AI for all that juicy efficiency and cost savings. High salaries being paid out to people with a myopic fixation on maximizing profits at any cost with no sense of decency, longevity, or whether they are destroying our planet and democracy in the process.
Surely a heartless machine can do this job just as well, and maybe would even accidentally stumble upon the myriad ways their short term thinking is pennywise, but pound foolish for the longterm viability and profitability of the company... and *gasp* makes better choices! :P
I empathize with your concern about profit motives Crystal but I would reevaluate your mental model because there’s a lot in here that’s emotionally fueled and not rooted in reality nor first principles. An accurate view of history and the causes of inflation as well as the makeup of our financial system would better inform the rightful anger you have towards inflated prices. Lax anti-trust is a factor, which is why I always appreciate this Substack but the truth is rooted in a dysfunctional culture captured by ideology among other more prominent issues. In any case, the jobs that will go when prices equilibrate are the bloated HR departments, compliance, filing, many software jobs and almost any task that requires binary thinking or produce ~0 value for customers. Am I saying C-suites making 350x the average wage is fair? No way! But it’s asinine to think their job is even remotely replaceable in the next 50-100 years.
when I say jobs producing 0 value I mean either that they actually are useless or that they can be replaced by AI
There's a bright side of AI. It may become hard to deny truths that it discovers...
What if AI gets more access to data and sees that corporations are money laundering schemes who extract wealth to shareholders taken from consumers via higher prices and worse service?
What if AI sees that finance capitalism is parasitic and produces nothing?
What if AI determines that certain utilities, like healthcare and energy are best served by public entities that can better distribute risk and gain?
What if AI starts realizing that propaganda creates distrust these days?
https://meredithmiller.substack.com/p/induction-by-confusionthe-sequel
Sorry, the link you share leads to a writer who is an anti-vaxxer and uses psychological concepts loosely and at times inaccurately to support a paranoid view of Operation Warp Speed. Didn’t expect that here.
Did you know that if you're injured by it, there's no liability for pharma?
It's not just the covid shots. So where's the incentive for safety, like we have with drugs, which can be sued for?
The vaccine courts which are funded by fees paid by the client, not pharma, have a ridiculously low maximum settlement of 250k. Is that enough to pay even medical bills for a bad injury? No.
But yet, mandates were pushed for the covid shots which we found later do not prevent transmission. The mandates are what woke me up to look into this.
Some links about liability pre covid. The covid shots are even more restricted as they are under the PREP act.
https://www.hoover.org/research/vaccines-and-liability-0
https://www.pbs.org/newshour/show/supreme-court-weighs-whether-vaccine-makers-can-be-sued
If you expect a vaccine to prevent transmission rather than reduce it, you don’t understand what most vaccines do, i.e., the yearly flu vaccine. Mandates are appropriate in certain settings to reduce spreading a pathogen in public health emergencies. I was fully vaccinated and finally caught COVID after three years because healthcare settings like my dentist’s office under public pressure and to save the mighty dollar didn’t install filtering and air barriers to prevent patients with mouths open for hours from breathing aerosols of others in the office. Because of my vaccinations and with the help of Paxlovid, I was not severely ill despite being in my seventies with an underlying chronic condition that renders me vulnerable if I get a severe respiratory illness.
How a society that is politically divided and assaulted by disinformation and propaganda handles public health emergencies is a whole other issue when we had a grifter president over-ruling seasoned public health physicians like Dr. Fauci.
Then there’s the shallow idea that you can adequately explain propaganda and its effects via Erickson’s confusion technique in hypnosis or Festinger’s cognitive dissonance. So much more is known and was known even when those old models were presented in the last century. You would need to find the link, but The NY Times, I believe, did an at-length piece on Russia’s disinformation strategies. And lots is known about what divides us from other sources like Jonathan Haidt, Robert Jay Lifton, Robert Altemeyer sometimes writing with John Dean, and more.
There’s a better place to discuss vaccine concerns, a FaceBook group called Vaccine Talk.
Did you get all the boosters? Most of those that I know got the shots had COVID multiple times. They stopped after the first booster, since it was not mandated and there are concerns of side effects. You still aren't addressing the point that there's no liability for big pharma. That's why I decided to not get it in 2021. I can't afford to be ill and I find the mandates to be fascist as it violates the Nuremberg code which is supposed to allow for people to say NO without repercussions like losing their job.
BTW, You're the one that brought up vaccines in response to that article which was about the whole shebang of war, etc. Don't gaslight me like I was arguing about it first. I just linked an article that I found interesting regarding the current world situation and propaganda, especially about the war.
I chimed in with liability issues to remind you and others that sorry, but no, vaccines are not safe if pharma isn't liable. They have no incentive to make them safe. That's why I lost trust in them. I am perplexed how even Bernie Sanders, who I wanted to win last primaries could call out big pharma only to blindly support them with a new vaccine that has no long term safety data.
I'll answer your calm question up front. I got all of the boosters, not expecting 100% immunity, and I don't blame an mRNA vaccine for my getting COVID, which is a very adaptive pathogen. I believe that mRNA technology will give us breakthroughs in harnessing the immune system to fight terrifying illnesses like pancreatic cancer.
I didn't address the reduced liability for big pharma directly, because that opens a long and multifaceted conversation about how we as a divided society and government handle our dysfunctional healthcare industry and public health emergencies. I personally would like to see us with universal healthcare as it's done with cost savings and better outcomes in peer nations. See the SubStack newsletter by Alan Unell called "Healthcare Advocacy."
https://healthcarereformau.substack.com/p/medicare-issues
If you believe mandates are fascist, how do you feel about the mandate to not drive a car if you're above a legal limit of alcohol consumption? When a pandemic is rapidly spreading, some mandates are appropriate, such as vaccination of workers in nursing homes.
I brought up vaccines because you had linked an anti-vaxxer who also cites an astrologer, something I didn't mention. If you think that I am gaslighting because I highlight the speciousness of that author, sorry, I am challenging her credibility. Gaslighting is also a personal accusation and is unwarranted on this forum. To take this in a more relevant direction, when you're dealing with disinformation about vaccines, the sources of that disinformation will lead us in many directions so that there is always another avenue for skepticism about public health directives that are based on the best scientific findings available in an evolving situation of unknown and partially knowns. It benefits our enemies to have us divided and ruled by cranks and cons instead of being unified to oppose them.
Then you land back on your assertion that vaccines aren't safe. Almost all medical interventions, drugs, procedures, etc., have known risks. Just read the prescriber's sheet for most common medications, including statins. Because these medications go through clinical trials and testing, they will report some adverse events. But these medications and other treatments are approved because their benefits are seen to far outweigh their risks to a population that may receive that treatment. If it's later discovered that more risks emerge, those medications are pulled. That's what happens as more is known.
BTW, if Bernie Sanders supported the vaccine mandates in force at the time, you are choosing to call him blind rather than give him some benefit of the doubt. It's okay to not know for certain and to do a deeper exploration of sources you would tend to agree with, who disagree with you. That's the premise of learning to recognize anomalies in your own modeling and is a basis for breakthroughs in science (see Thomas Kuhn's writing on paradigm change).
So, it's like HAL, an algorithmic Bob . . not with low morals, but None at All, right for the job .. and no need . . with conniving sleaze ball types . .to hob nob . .. #the space takes . .
The very first time I heard the term “price point” I started to become more and more aware of the declining relationship between cost and value.
Good stuff. You should dig into airline ticket prices, and the scam that goes on with those...
I am against judges “re-writing” any laws passed by Congress, anti-trust or immigration. Who gave Judge Du the authority to declare a century-old law racist? Nobody. Can’t wait for Matt to return.
Judges interpret the laws written by Congress. It happens all the time. Look at what the supreme court did with roe vs wade or what Bork and the Chicago school did to the antitrust via the judiciary. Whether you're against it or not that's what judges do -- interpret the laws.
I strive to be careful in the words I use, and I don’t want to come across as snarky, but I wasn’t commenting on interpreting the law. I was commenting on judges (not justices) re-writing or abolishing the law. And your example of Roe v. Wade is proving my point. A majority of justices in a body of nine found something in the constitution that didn’t exist. They made law on a controversial issue that should have been decided by the people through their state legislatures and/or congress. That overreach disenfranchised roughly half the population and led to fifty years of avoidable social conflict and tens of millions of dead babies. Such are the fruits of an activist judiciary.
I'm not making a normative argument as much as explaining that it's a function of the judiciary to interpret laws. But to be clear, I think that discretion should be limited, for the exact reason that the judiciary lacks the same form of direct accountability as other law-making branches of government. Further, laws that use vague standards for liability, like a "reasonableness" standard, are not easy for people to understand. And if you can't understand a law, how are you supposed to comply with it?
Anyway, judicial discretion is a reality, and my point is that it has been inappropriately exercised to limit the reach of antitrust laws.
Isn’t the whole point of SCOTUS to adjudicate on what the states can and cannot do based on their interpretation of what some men agreed on, intended, and wrote down centuries ago (there often being three different things there). If you ask me, it’s a ludicrous state of affairs for a nation as immense, in all ways, as the US.. but there we go. The difference between interpretation, extrapolation, and activism all mainly depends on which side you take on a particular issue. The school of thought that the Constitution should evolve and encompass rights that were not considered at the time of the founding has no less and no more grounding than the one that the founders thought that their words and opinions should be strictly enforced for eternity. If the law simply ‘is’, and the judges simply tell us what it is, how come the political sides fight to vigorously to have ‘their’ people occupying benches.
The specific case you’re concerned with is way OT. And there are plenty of comparable ones that offend different groups of people for different reasons. As an observer from overseas who is, nonetheless, very interested in SCOTUS and the politics behind it (after all, the effects of that system and it’s impact on the US reach far beyond US borders) I do read criticisms like yours and generally find that the only ones that seem in good faith are the ones that find fault with the whole goddamn setup.. but most seem to come from a place of people happy with system, just pissed at the times it didn’t agree with them.
Seems to me the easiest way to solve problems like these is a maximum wage.
No one needs, or deserves, the money our oligarch creates in the grift economy.
Thanks for being an antitrust lawyer! It's essential work and I'm sure makes no friends at the antitrust bar nor gets invites to the cocktail parties.
Important, and really crappy information that should be shared all over the place.
It's worse than we think. They spend millions analyzing how to raise prices based on your behavior. Cable and phone providers perfected it - they know who will quit and who will stay. If you stay they will raise prices continuously. The treat to leave the service is no longer a threat - it's cost of doing business - they don't care.
Healthcare is so gamed - you have to think the worst and they are even worse than that. I say "Keep gov'ment in my healthcare!".
Cannot the FTC make investigative demands, pre-litigation, to obtain the documentation and other evidence needed to substantiate more particular evidence to support its factual allegations in its next Complaint?
Great to read!