FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 1 of 44 * PUBLIC *
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UNITED STATES OF AMERICA
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FEDERAL TRADE COMMISSION
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OFFICE OF ADMINISTRATIVE LAW JUDGES
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________________________________
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In The Matter of:
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DR. LARRY RICKMAN OVERLY, DVM,
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Appellant.
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Docket No.
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9443
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________________________________
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HEARING
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DATE:
Thursday, August 13, 2026
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TIME:
12:58 p.m.
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BEFORE:
Jay Himes, Administrative Law Judge
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LOCATION:
Remote Proceeding
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600 Pennsylvania Avenue, Northwest
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Washington, DC 20580
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REPORTED BY:
Helen Tadesse
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Job No. CS8385695
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A P P E A R A N C E S
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ON BEHALF OF APPELLANT DR. LARRY RICKMAN OVERLY:
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HOWARD JACOBS, ESQUIRE (by videoconference)
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Law Offices of Howard L. Jacobs
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31111 Agoura Road, Suite 225
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Westlake Village, CA 91361
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howard.jacobs@athleteslawyer.com
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(805) 790-8790
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ON BEHALF OF APPELLANT DR. LARRY RICKMAN OVERLY:
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KATY FREEMAN, ESQUIRE (by videoconference)
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Law Offices of Howard L. Jacobs
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31111 Agoura Road, Suite 225
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Westlake Village, CA 91361
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katy.freeman@athleteslawyer.com
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(805) 790-8790
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A P P E A R A N C E S (Cont'd)
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ON BEHALF OF HORSERACING INTEGRITY AND SAFETY
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AUTHORITY:
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ALLISON FARRELL, ESQUIRE (by videoconference)
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Horseracing Integrity & Welfare Unit
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4801 Main Street, Suite 350
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Kansas City, MO 64112
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afarrell@hiwu.org
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(816) 285-1425
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ALSO PRESENT:
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Dana Gross, Legal Assistant For The Office of
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Administrative Law Judges (by videoconference)
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LaShaon Asberry-Beach, Legal Assistant For The
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Office of Administrative Law Judges (by
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videoconference)
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Sarah Botha, From The Office of General Counsel
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(by videoconference)
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E X H I B I T S
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P R O C E E D I N G S
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THE REPORTER:
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And we are on the record, sir.
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THE COURT:
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I'm Judge Himes.
The time is 12:58 p.m.
Thank you.
As most of you know,
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I'm the administrative law judge of the Federal Trade
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Commission assigned to this case: matter of Overly,
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Docket 9443.
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Now, the Commission has remanded this
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case to me in its July 21 order, directing me to
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consider the case consistent with the Commission's
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Serpe decision.
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help inform my response to the Commission's order.
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And this conference is intended to
Let me begin by taking the appearances
15
of the parties.
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Dr. Overly.
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I'll start with the appellant,
MR. JACOBS:
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Honor.
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appellant, Dr. Overly.
Howard Jacobs and Katy Freeman for the
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21
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Good afternoon, Your
THE COURT:
Okay.
And for the
Authority?
MS. FARRELL:
Yes.
Good afternoon,
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Judge.
Allison Farrell on behalf of the Authority.
THE COURT:
Okay.
And you're HIWU
again, doing double duty; right?
4
MS. FARRELL:
5
THE COURT:
That is correct.
Okay.
So this conference
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is, of course, a video conference.
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not identified publicly a feed for members of the
8
public, the proceeding is not confidential.
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member of the public in one way or another has gotten
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the link and logged in, that's fine, but they must
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disable their video and mute their audio.
Although we have
If any
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I don't think there is anybody that I
13
see identified from the public, but if someone comes
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in, as I said, this is not a confidential proceeding.
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We have a court reporter, and so the
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proceeding will be transcribed, and the final version
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will be part of the public docket in this case.
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Can I ask the court reporter to please
identify themself?
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THE REPORTER:
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Helen Tadesse, and I'm the court reporter.
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THE COURT:
Yes, sir.
Thank you.
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My name is
We have staff
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from the Office of the Administrative Law Judges also
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on.
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Well, Sarah Botha, who is that?
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MS. BOTHA:
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I'm from the Office of General Counsel.
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THE COURT:
7
you.
8
you're here.
Hello, Your Honor.
Oh, good.
Yes.
Nice to have
I know we had invited you, and I'm glad to see
Thank you.
9
I will quickly just go through some
10
logistics, and then we'll deal with the substance of
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the conference.
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of days ago.
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Only the attorneys who are authorized to speak during
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the conference should do so on the link.
We sent video instructions a couple
I'm confident you have them in mind.
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If you are counsel speaking today, you
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should keep your video on at all times and your audio
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on while you are speaking.
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identify yourself for the court reporter's benefit.
Before speaking please
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All right, we'll move to the substance.
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I take the Commission's remand order to call on me to
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determine whether a further remand to the arbitrator
22
is appropriate in view of the rulings I made in my
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merits decision, which increased the ineligibility
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period for Dr. Overly and also the fine beyond that
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which the arbitrator had awarded.
4
Now, following the Commission's order,
5
I granted the parties leave to submit briefs on the
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possible effect of Serpe and a subsequent order I
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issued in a case called "Matter of Scott."
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After receiving those briefs, I called
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for this conference to permit further discussion.
10
in doing so, I identified two topics that I wanted the
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parties to be prepared to discuss.
12
And
The first was to explain more
13
specifically what they contend an arbitrator should be
14
asked to consider if a remand is ordered, and to
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discuss whether it would be acceptable if I simply
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affirm the 23-month ineligibility period and the
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$25,000 fine that the arbitrator had arrived at,
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directed that the 23 months apply individually to each
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ADRV and apply consecutively.
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The idea was that perhaps that would
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obviate the need for any remand, and enable Dr. Serpe,
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or, indeed, the Authority, to seek review with the
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Commission without additional proceedings before the
2
arbitrator.
3
Now, by offering these two suggestions,
4
I don't mean to preclude either side from raising any
5
other matter that they think is worthy of discussion
6
here, but let's focus on my topics first.
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I'll start with the second question,
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which I do hope the parties have thought about and
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maybe even conferred.
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So let me ask for Ms. Farrell on behalf
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of the Authority to comment first.
Obviously what I'm
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suggesting is whether there is an ability to really
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facilitate a more prompt conclusion of what I should
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think matters most here, and that is the length of
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ineligibility that Dr. Overly will have to serve.
And
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it's going to be something one way or the other.
Now,
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maybe I'm just plain wrong on that, however.
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So, Ms. Farrell, what's your reaction?
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MS. FARRELL:
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Thank you, Your
Honor.
21
22
Yeah.
Allison Farrell on behalf of the
Authority.
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So to be clear, what the Authority
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understood the second option to be was you would
3
affirm the sanction of the arbitral body.
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in a sense, by saying that the 23 months would apply
5
individually and consecutively, the Authority
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understood that to be an increase of the sanction that
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the arbitrator awarded, if we understand correctly.
8
And given --
9
THE COURT:
And then,
Well, it has that effect,
10
but it's based on a rule construction that I undertook
11
in light of the party's arguments over, which --
12
you'll forgive me if sometimes these rules blend -- I
13
think it was 3228 D, but I could be missing that.
14
MS. FARRELL:
15
THE COURT:
3228 D.
Yeah.
Okay.
So that's how
16
you get from 23 months or whatever to 46 months or 48
17
months; however, you multiply by two.
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that, if I'm understanding you, an ALJ is disabled
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from construing rules in a way that increased the
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sanctions?
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MS. FARRELL:
clear, not certain.
Your view is
The Authority's to be
And so in order to be consistent
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with a conservative interpretation of what the
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Commission ordered in Serpe, the Authority --
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I mean, I'll just cut to the chase and
4
say the Authority's position is that they would choose
5
Option 1 and ask Your Honor to do a partial remand to
6
the arbitral body, rather than agree to what I'll call
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"the compromise" offered in Option Two.
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THE COURT:
Okay.
Let me just say
9
something about that.
10
could go to the Commission and find out once and for
11
all whether I'm right or wrong on the subject of
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construing a rule in the way that I did and producing,
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as a result, an increased sanction over that, which
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the arbitrator awarded.
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If you accepted Option 2, you
The arbitrator here didn't, in fact,
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really reach that issue.
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agree with my Shell 2 ruling that separate violations
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could be charged.
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What the arbitrator did was
And if I'm remembering right, what the
20
arbitrator then did was jump to proportionality and
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say, "I'm going to find the proportionality applies,
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and so I'll only issue a single award of sanctions,"
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without getting to whether the rule itself authorized
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consecutive sanctions.
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the arbitrator's way of thinking.
It was basically academic to
4
I think I've summarized what happened
5
there correctly, but if not, just let me know how you
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see it differently.
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MS. FARRELL:
I don't see it
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differently.
9
of the efficiency of the proposed Option 2, but the
10
Authority would prefer to have a partial remand on the
11
issue of sanction consistent with your finding.
12
I understand what you're saying in terms
THE COURT:
Well, okay.
13
go to Option 2 then directly.
14
maybe I should hear from Mr. Jacobs.
15
I mean, we can
Well, before I do that,
Mr. Jacobs, what do you think about
16
this?
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was, I would worry about, you know, how much time, so
18
to speak, my guy is going to do, and you haven't been
19
able to get the Commission to rule on that.
20
I mean, if I were in your position, and I often
You know, you applied for Commission
21
review, and the Commission technically took the case,
22
but then sent it back to me without ever reaching any
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of the merits of the ruling.
2
the opportunity to get back to the Commission, which
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is where you wanted to be, quicker?
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MR. JACOBS:
So how do you feel about
So I'm coming at it from a
5
slight -- sorry, Howard Jacobs for appellant,
6
Dr. Overly.
7
I've discussed the matter with
8
Dr. Overly.
9
does, but for a different reason.
10
Dr. Overly simply won't agree to the increase, what
11
is, in effect, doubling of his sanction.
12
you're saying, that it ultimately is going to have to
13
be decided, but he doesn't want to be in a position
14
where he's agreed to that, even if it's just to --
15
We come to the same places Ms. Farrell
THE COURT:
And the reason is
I hear what
Oh, I would never ask him
16
to agree to that.
17
procedure that says, you know, "Himes has talked to
18
the parties.
19
And the parties agree that without prejudice to any
20
side's position on any issue in the case, Himes will
21
amend his order."
22
I mean, I think we could fashion a
He took briefs.
Yeah.
He held a conference.
I'm speaking off the cuff.
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mean, the technical language doesn't matter, but,
2
"Himes will say, 'Okay, 23 months, but he believes
3
consecutive sanctions are appropriate under Rule 3228
4
D, and therefore that works out to be 46 months.
5
"'Himes won't bother with the
6
penalty,'" because I don't think HIWU cares terribly
7
much about the money.
8
whatever they want to do in front of the Commission
9
are preserved.
10
accepting consecutive sanctions.
11
And everybody's rights to do
He didn't have to agree that he's
MR. JACOBS:
Well, so I would have to
12
go back to Dr. Overly with that, because I had read
13
the email as essentially requiring acceptance.
14
THE COURT:
Oh, no.
15
MR. JACOBS:
Yeah.
16
THE COURT:
Okay.
17
MR. JACOBS:
And even with the
No.
18
understanding that it would quicken the ultimate, you
19
know, decision on the issue, Dr. Overly is concerned
20
with any appearance that he's agreed to this increased
21
sanction and the effect that may have on other
22
proceedings that he's dealing with.
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THE COURT:
Okay.
Look, if you two
2
could agree, and maybe even if you can't, but if you
3
two could agree, you can certainly propose language to
4
me, Mr. Jacobs, that you think gives Dr. Overly the
5
assurance that, A, he's not agreeing to two times
6
twenty-three, and, B, whatever he's agreeing to
7
doesn't impact him somewhere else.
8
certainly open to considering language that would
9
accomplish that.
10
All right?
MR. JACOBS:
So -I would be open to
11
explore -- I'm sorry, Your Honor.
12
exploring that.
13
think.
14
I mean, I'm
I would be open to
It's going to take some work, I
THE COURT:
Well, okay.
You want to
15
get down to it: It won't take as much work as going
16
back to the arbitrator, which is what we're going to
17
talk about next.
18
As long as I have you, Mr. Jacobs, I
19
I'm going to ask you about that subject, because what
20
you wrote in your brief was that if the ALJ finds that
21
both anti-doping rules have been established, it's
22
submitted that the most the ALJ can do is to remand
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this case for sanctioning consistent with the ALJ's
2
findings.
Okay?
3
My first question is what in that
4
suggestion does "if" mean?
5
need to revisit the liability rulings?
6
MR. JACOBS:
Are you suggesting that I
No, no.
No, Your Honor.
7
I was just saying that the options available to you
8
are to, in essence, from the outset, was to either
9
affirm what the arbitrator did or remand it.
10
"remand it" would be, you know, with guidance from
11
your order as well as presumably the order that
12
followed that.
13
And
Our view is that you can't increase the
14
sanction or the fine.
15
same, or you could reduce it.
16
option.
17
that.
18
reduce it, or remand it.
19
THE COURT:
I forgot.
You can either keep it the
That was the third
It's clear you're not going to do
So the three options were keep it the same,
That's all we were saying.
Okay.
I mean, I don't read
20
anything in Serpe to suggest that I have to revisit
21
the liability findings that I made.
22
that?
You agree with
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MR. JACOBS:
I do.
Yes.
2
THE COURT:
Okay.
Okay.
3
helps.
4
the least?
Now, you say the most that I could do.
5
6
So that
MR. JACOBS:
What's
The least would be to just
affirm what the arbitrator did.
7
THE COURT:
Which was kind of what I
8
was offering in Option 2 that we discussed.
9
MR. JACOBS:
10
it's doubling the sanction.
11
THE COURT:
But not in reality because
It's not -Well, okay.
You're right
You're right about that.
I could accept
12
about that.
13
the ineligibility, but double it.
14
the fines somehow or another just seems to me almost
15
incidental and not worth worrying about here.
16
Okay.
Okay.
And again,
Okay.
So I think I understand what you're saying.
17
Let's assume that I think a remand is
18
necessary.
19
Scott, you know.
20
I can or can't do in this case on the facts of this
21
case, but let's just pass that and not argue it here.
22
Assume I remand it to the arbitrator.
And by the way, I wrote something in
And I may not agree with you on what
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Is there something that you think is missing from the
2
record that the arbitrator had that needs to be
3
filled?
Added?
A deficiency?
4
MR. JACOBS:
I don't believe so.
5
THE COURT:
Okay.
By the way,
6
Ms. Farrell, I mean, do you agree with that?
7
were remand here -- in your approach, it's on
8
proportionality, but let me just ask the same
9
question.
10
for whatever reason, is there something, some
11
deficiency, some defect, something that you think
12
needs to be added other than --
If there
If there were a remand to the arbitrator
13
MS. FARRELL:
To the record?
14
THE COURT:
Yeah, to the record.
15
MS. FARRELL:
No.
16
THE COURT:
No, okay.
17
I've got agreement on something today.
18
Okay.
Good.
So, Mr. Jacobs, if I were to remand and
19
say, "Okay, take a look at sanctions again," what is
20
it the arbitrator's supposed to do?
21
decision presumably.
22
he may agree with me when he reads it all and say,
He'll have my
And he'll see what I said.
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"Okay.
2
him 23, 24 months."
That makes a bit of sense to me.
3
I'll give
I don't think that difference matters
4
much.
And they're consecutive.
5
"No.
I've read it.
6
with what I did."
7
because you think your client showed compelling
8
justification; right?
9
Or he's going to say,
It's interesting.
I'll stick
You're still going to come back
MR. JACOBS:
Well, yes, but whether we
10
would come back or not, I mean, that decision hasn't
11
been made.
12
by January, I think, is when it's up.
13
wrong on that.
14
come back.
15
I mean, at 23 months, I think, is served
I could be
So it may be moot by the time we would
THE COURT:
Well, that counsel against
16
trying to find a better resolution.
17
scenario that I've just gone through sounds like the
18
arbitrator is then reviewing me; right?
19
decision in front of him, and he says, "Okay.
20
nay?"
21
22
MR. JACOBS:
You know, the
He's got my
Yay or
Well, I think a third
option is the arbitrator, she could ask the parties
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for, you know, oral argument on the issue.
2
it's remanded.
I mean,
She could ask the parties for that.
3
THE COURT:
Sure.
4
MR. JACOBS:
But ultimately, the
Sure.
5
arbitrator would be remanded so that the arbitrator is
6
reconsidering her earlier decision with input from
7
your decision as well as any additional argument from
8
the parties.
9
THE COURT:
Yeah.
Right.
I agree.
10
The arbitrator could hear argument; the arbitrator
11
could take more briefs.
12
saying is, "We've given the arbitrator a new data
13
point, and the arbitrator is supposed to decide, 'Gee,
14
is that persuasive or not?'"
15
like what the Commission should be doing.
16
MR. JACOBS:
17
THE COURT:
19
step?
20
all be moot?
22
And that to me sounds
Well, I mean, ultimately,
it may come back to the commissioner.
18
21
But in the end, what you're
It may not.
But why would you want this
Again, only because January may come, and it'll
I guess that's the only reason, huh?
MR. JACOBS:
Well, that and what I had
said earlier, which is a problem that may be solvable,
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which is Dr. Overly doesn't want to be viewed as
2
accepting the doubling of the sanction.
3
THE COURT:
Yeah.
I'm an optimist.
I
4
think a good attorney could solve that; okay?
5
got to say I'm having a bit of difficulty getting what
6
the purpose of the remand is on your formulation of
7
it.
8
So I
But let me go to Ms. Farrell because
9
she's got a different idea.
10
a partial remand for further consideration of the
11
proportionality principle; right?
12
MS. FARRELL:
She says there should be
Yes.
From the
13
Authority's perspective, any remand would be narrow
14
just on the issue of -- I mean, your decision
15
presumably would be, you know, if it's still in line
16
with the decision that you've already issued,
17
proportionality doesn't apply.
18
You've said what you think the law is.
19
And based on these facts -- and the authorities would
20
ask for the remand back to the arbitrator so that she
21
could issue an amended sanction based upon your
22
determinations and your findings sitting, as the FTC
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recognized, in the seat of an appellate body.
2
THE COURT:
Well, see, you've agreed
3
that that's really just an analysis that the
4
arbitrator would make on a remand, presumably either
5
based on briefing or argument or frankly nothing if
6
the arbitrator didn't want to do anything more.
7
Now, you know, you have a
8
proportionality discussion by the arbitrator.
9
the decision.
10
sanctions.
11
my Shell 2 decision, which, of course, the arbitrator
12
didn't have.
That's how the arbitrator got to single
I gave my own view of that.
13
It's in
I interpreted
So now there's a new data point.
But we're back, it seems to me, to the
14
same place.
15
Himes says about Shell 2.
16
I first ruled on this.
17
If I agree, then Dr. Overly's getting 46 months
18
consecutive sanctions.
19
The arbitrator says, "Oh, I see now what
That wasn't before me when
Maybe I agree; maybe I don't.
If I don't, well, too bad."
And again, it sounds like he's
20
reviewing me.
21
doing.
22
benefit of going back to an arbitrator.
That's what the Commission ought to be
I'm not getting what the parties think is the
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MS. FARRELL:
The Authority wants to be
2
conservative in their interpretation of what the FTC's
3
decision was in Serpe.
4
THE COURT:
But if the result of that
5
is to add time and expense, what's the point?
6
Shouldn't we run the proceeding as efficiently as we
7
can?
8
been able to.
9
something appealable in this case besides the --
10
The Commission can decide that the
Dr. Overly tried to get an appeal.
He hasn't
If the Commission thinks there's
11
consecutive sanctions construction of the rule is no
12
good.
13
if you don't like it, you can go to a federal court.
14
If Dr. Overly doesn't like it, so can he.
15
And I just have difficulty
16
understanding what real function a remand serves here,
17
other than, again, takes more time, costs more money.
18
I don't know what sanction's, frankly,
And then you'll get a decision on that, which,
19
in effect right now, given the circumstances, the
20
procedural posture of the case.
21
Authority ought to be thinking a bit about what
22
sanction's in effect because Mr. Jacobs thinks that by
But I mean, the
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January, it's gone.
2
what the Authority would like.
3
for consecutive sanctions.
4
MS. FARRELL:
Doesn't sound exactly like that's
The Authority's argued
I do hear your point,
5
Judge.
I'm not authorized to agree with you at this
6
point.
And so I guess I would say if Attorney Jacobs
7
is going to go back and talk to his client, I could
8
attempt the same.
9
THE COURT:
I mean, I'm just wondering
10
whether we shouldn't just do that when you've heard,
11
you know, each other.
12
seeing -- which is, you know, just kind of this redo
13
of issues that have already been decided, not only by
14
the arbitrator, but by me.
15
to know ultimately is what does the Commission think
16
on this stuff?
17
And the scenario that I'm
And what you really want
So, I mean, unless someone has another
18
idea, I mean, I think, you know, both sides should
19
just go back and, you know, confer with the people
20
they have to confer with, and maybe we can set up a
21
placeholder for a second conference, or both of you
22
can say, "No.
We can't think of any other ideas
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beyond what we've already put forward.
2
"So we'll write you a little email
3
jointly that says that, and you, Himes, decide what
4
you're going to do now."
5
to people?
6
I mean, does that make sense
MR. JACOBS:
So as I said, I'm happy to
7
go back to Dr. Overly and discuss with him and see if
8
we could come up with some sort of proposal that he
9
would be comfortable with, discuss it with
10
Ms. Farrell.
And we'll either come to some agreement,
11
or we won't.
And we can report back to you once we
12
know where we've landed.
13
THE COURT:
Okay.
I mean, does it make
14
sense to set up a placeholder conference as opposed to
15
just an email back?
16
say, "We have some things that we need to talk more
17
about that don't lend themselves to an email."
Because you may come back and
18
MR. JACOBS:
I'm fine with that.
19
MS. FARRELL:
That's fine with me.
20
THE COURT:
21
MS. FARRELL:
22
Pardon me?
That's fine with me as
well.
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THE COURT:
I mean, does a week from
2
today at one o'clock still work?
3
that.
I mean, I'll make myself available.
4
5
MR. JACOBS:
I'm in an arbitration a
week from today.
6
7
There's no magic to
THE COURT:
How long do you think it'll
MR. JACOBS:
I mean, it's scheduled to
last?
8
9
start at -- I'm in Los Angeles at six a.m. here and
10
finish at, I think, eleven a.m. Pacific time, so.
11
THE COURT:
So you'd probably rather
12
not do right before the arbitration, like, the day
13
before or anything like that.
14
know, a week from Monday.
15
know, I want to give you people a reasonable chance to
16
think about it and to see whether there's anything
17
that you can jointly agree on to propose to me.
18
maybe something works.
19
20
I don't care.
I mean, you
And
I mean, does a week from Monday work
better?
21
22
We can do this, you
No?
MR. JACOBS:
then.
I'm in another arbitration
Would Friday, the 21st work by chance?
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THE COURT:
2
MS. FARRELL:
3
It works for me.
Yeah.
That should work
for me as well.
4
THE COURT:
What time would you like?
5
MS. FARRELL:
I could do the eleven
6
o'clock on that day.
7
THE COURT:
That okay, Mr. Jacobs?
8
MR. JACOBS:
Sure.
9
THE COURT:
Okay.
10
MR. JACOBS:
So that's eleven Eastern?
11
THE COURT:
Yeah.
12
MR. JACOBS:
Okay.
13
THE COURT:
Okay.
So we'll do that
14
eleven o'clock.
15
agreement and say, "Here's what we propose," or maybe
16
you'll say, "We can't agree on the time of day, so
17
just go do what you're going to do, Himes."
18
And maybe you will either have an
You know, the conference is set up as a
19
placeholder.
If we don't have to have it, we don't
20
have to have it.
21
can maybe hammer out, then we'll hammer it out, or
22
try.
All right.
If there's something you think we
I mean, all that's fine with me.
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Is there anything else that anyone
2
wants to raise?
3
didn't mean to, you know, sort of truncate what we
4
would talk about, so here's your chance.
5
MR. JACOBS:
For the appellant, nothing
MS. FARRELL:
And nothing additional
6
else for us.
7
8
As long as I've got you, I said I
from the Authority.
9
But thank you, Your Honor.
THE COURT:
Okay.
Well thank you both
10
for making yourself available.
11
I send an email that asks you to talk jointly about
12
alternative dates or times, please talk to each other
13
beforehand.
14
here, even though it was able to be resolved quickly.
15
But, you know, that helps.
16
MR. JACOBS:
Okay.
18
MS. FARRELL:
Yes, Your Honor.
19
THE COURT:
17
20
21
22
Okay?
By the way, next time
It didn't quite happen that way
All right?
Thank you, Your
Honor.
Thank you both, and we'll
stand adjourned.
THE REPORTER:
It is 1:33 p.m., and
we're off the record.
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(Whereupon, at 1:33 p.m., the
2
proceeding was concluded.)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
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21
22
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2
CERTIFICATE
I, HELEN TADESSE, the officer before whom
3
the foregoing proceedings were taken, do hereby
4
certify that any witness(es) in the foregoing
5
proceedings, prior to testifying, were duly sworn;
6
that the proceedings were recorded by me and
7
thereafter reduced to typewriting by a qualified
8
transcriptionist; that said digital audio recording of
9
said proceedings are a true and accurate record to the
10
best of my knowledge, skills, and ability; that I am
11
neither counsel for, related to, nor employed by any
12
of the parties to the action in which this was taken;
13
and, further, that I am not a relative or employee of
14
any counsel or attorney employed by the parties
15
hereto, nor financially or otherwise interested in the
16
outcome of this action.
17
<%34163,Signature%>
18
HELEN TADESSE
19
Notary Public in and for the
20
Commonwealth of Virginia
21
22
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2
CERTIFICATE OF TRANSCRIBER
I, OLIVIA LEREBOURG, do hereby certify that
3
this transcript was prepared from the digital audio
4
recording of the foregoing proceeding, that said
5
transcript is a true and accurate record of the
6
proceedings to the best of my knowledge, skills, and
7
ability; that I am neither counsel for, related to,
8
nor employed by any of the parties to the action in
9
which this was taken; and, further, that I am not a
10
relative or employee of any counsel or attorney
11
employed by the parties hereto, nor financially or
12
otherwise interested in the outcome of this action.
13
14
<%35752,Signature%>
OLIVIA LEREBOURG
15
16
17
18
19
20
21
22
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[& - apply]
&
& 3:5
1
1 11:5
12:58 1:13 5:2
13 1:12
1:33 28:21 29:1
2
2 11:9,17 12:9
12:13 17:8
22:11,15
2026 1:12
20580 1:17
21 5:10
21st 26:22
225 2:5,13
23 8:16,18 10:4
10:16 14:2
19:2,11
24 19:2
25,000 8:17
285-1425 3:9
3
31111 2:5,13
3228 10:13,14
14:3
34163 30:17
350 3:6
35752 31:14
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4
46 10:16 14:4
22:17
48 10:16
4801 3:6
9443 5:8
6
600 1:16
64112 3:7
7
790-8790 2:8
2:16
8
805 2:8,16
816 3:9
9
91361 2:6,14
9443 1:9
a
a.m. 26:9,10
ability 9:12
30:10 31:7
able 12:19 23:8
28:14
academic 12:2
accept 17:12
acceptable 8:15
acceptance
14:13
accepted 11:9
accepting
14:10 21:2
accomplish
15:9
accurate 30:9
31:5
action 30:12,16
31:8,12
add 23:5
added 18:3,12
additional 9:1
20:7 28:7
adjourned
28:20
administrative
1:3,14 3:13,15
5:6 7:1
adrv 8:19
afarrell 3:8
affirm 8:16
10:3 16:9 17:6
afternoon 5:17
5:22
ago 7:12
agoura 2:5,13
agree 11:6,17
13:10,16,19
14:9 15:2,3
16:21 17:19
18:6,22 20:9
22:16,17 24:5
26:17 27:16
agreed 13:14
14:20 22:2
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agreeing 15:5,6
agreement
18:17 25:10
27:15
alj 10:18 15:20
15:22
alj's 16:1
allison 3:4 6:1
9:21
alternative
28:12
amend 13:21
amended 21:21
america 1:1
analysis 22:3
angeles 26:9
anti 15:21
anybody 6:12
appeal 23:7
appealable
23:9
appearance
14:20
appearances
5:14
appellant 1:7
2:2,10 5:15,19
13:5 28:5
appellate 22:1
applied 12:20
applies 11:21
apply 8:18,19
10:4 21:17
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[approach - clear]
approach 18:7
appropriate
7:22 14:3
arbitral 10:3
11:6
arbitration
26:4,12,21
arbitrator 7:21
8:3,13,17 9:2
10:7 11:14,15
11:16,20 15:16
16:9 17:6,22
18:2,9 19:18
19:22 20:5,5
20:10,10,12,13
21:20 22:4,6,8
22:9,11,14,22
24:14
arbitrator's
12:3 18:20
argue 17:21
argued 24:2
argument 20:1
20:7,10 22:5
arguments
10:11
arrived 8:17
asberry 3:14
asked 8:14
asks 28:11
assigned 5:7
assistant 3:12
3:14
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assume 17:17
17:22
assurance 15:5
athleteslawye...
2:7,15
attempt 24:8
attorney 21:4
24:6 30:14
31:10
attorneys 7:13
audio 6:11 7:16
30:8 31:3
august 1:12
authorities
21:19
authority 3:3
5:21 6:1 8:22
9:11,22 10:1,5
11:2 12:10
23:1,21 24:2
28:8
authority's
10:21 11:4
21:13 24:2
authorized
7:13 12:1 24:5
available 16:7
26:3 28:10
avenue 1:16
award 11:22
awarded 8:3
10:7 11:14
b
b 4:1 15:6
back 12:22
13:2 14:12
15:16 19:6,10
19:14 20:17
21:20 22:13,22
24:7,19 25:7
25:11,15,15
bad 22:18
based 10:10
21:19,21 22:5
basically 12:2
beach 3:14
behalf 2:2,10
3:2 6:1 9:10,21
believe 18:4
believes 14:2
benefit 7:18
22:22
best 30:10 31:6
better 19:16
26:20
beyond 8:2
25:1
bit 19:1 21:5
23:21
blend 10:12
body 10:3 11:6
22:1
botha 3:17 7:3
7:4
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bother 14:5
brief 15:20
briefing 22:5
briefs 8:5,8
13:18 20:11
c
c 2:1 3:1 5:1
ca 2:6,14
call 7:20 11:6
called 8:7,8
care 26:14
cares 14:6
case 5:7,10,11
6:17 8:7 12:21
13:20 16:1
17:20,21 23:9
23:20
certain 10:22
certainly 15:3,8
certificate 30:1
31:1
certify 30:4
31:2
chance 26:15
26:22 28:4
charged 11:18
chase 11:3
choose 11:4
circumstances
23:19
city 3:7
clear 10:1,22
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[client - difficulty]
client 19:7 24:7
come 13:8 19:6
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comfortable
25:9
coming 13:4
comment 9:11
commission 1:2
5:7,9 9:1 11:2
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12:21 13:2
14:8 20:15
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24:15
commission's
5:11,13 7:20
8:4
commissioner
20:17
commonwealth
30:20
compelling
19:7
compromise
11:7
concerned
14:19
concluded 29:2
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confer 24:19,20
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6:8,14
consecutive
12:2 14:3,10
19:4 22:18
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consecutively
8:19 10:5
conservative
11:1 23:2
consider 5:11
8:14
consideration
21:10
considering
15:8
consistent 5:11
10:22 12:11
16:1
construction
10:10 23:11
construing
10:19 11:12
cont'd 3:1
contend 8:13
correct 6:4
correctly 10:7
12:5
costs 23:17
counsel 3:17
7:5,15 19:15
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couple 7:11
course 6:6
22:11
court 5:4,20
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26:1,6,11 27:1
27:4,7,9,11,13
28:9,19
cs8385695 1:21
cuff 13:22
cut 11:3
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d 5:1 10:13,14
14:4
dana 3:12
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date 1:12
dates 28:12
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decided 13:13
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defect 18:11
deficiency 18:3
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description 4:2
determinations
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determine 7:21
difference 19:3
different 13:9
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differently 12:6
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difficulty 21:5
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digital 30:8
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disable 6:11
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discuss 8:11,15
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discussed 13:7
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discussion 8:9
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docket 1:8 5:8
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doing 6:3 8:10
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doping 15:21
double 6:3
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doubling 13:11
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dr 1:6 2:2,10
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essence 16:8
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fact 11:15
facts 17:20
21:19
farrell 3:4 5:22
6:1,4 9:10,18
9:19,21 10:14
10:21 12:7
13:8 18:6,13
18:15 21:8,12
23:1 24:4
25:10,19,21
27:2,5 28:7,18
fashion 13:16
federal 1:2 5:6
23:13
feed 6:7
feel 13:1
filled 18:3
final 6:16
financially
30:15 31:11
www.CapitalReportingCompany.com
202-857-3376
find 11:10,21
19:16
finding 12:11
findings 16:2
16:21 21:22
finds 15:20
fine 6:10 8:2,17
16:14 25:18,19
25:21 27:22
fines 17:14
finish 26:10
first 8:12 9:6
9:11 16:3
22:16
focus 9:6
followed 16:12
following 8:4
foregoing 30:3
30:4 31:4
forgive 10:12
forgot 16:16
formulation
21:6
forward 25:1
frankly 22:5
23:18
freeman 2:11
5:18
friday 26:22
front 14:8
19:19
ftc 21:22
ftc's 23:2
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 36 of 44 * PUBLIC *
PUBLIC
Hearing
[function - jacobs]
function 23:16
further 7:21
8:9 21:10
30:13 31:9
g
g 5:1
gee 20:13
general 3:17
7:5
getting 12:1
21:5 22:17,21
give 19:1 26:15
given 10:8
20:12 23:19
gives 15:4
glad 7:7
go 7:9 11:10
12:13 14:12
21:8 23:13
24:7,19 25:7
27:17
going 9:16
11:21 12:18
13:12 15:12,15
15:16,19 16:16
19:4,6 22:22
24:7 25:4
27:17
good 5:17,22
7:6 18:16 21:4
23:12
gotten 6:9
August 13, 2026
Page 5
granted 8:5
gross 3:12
guess 20:20
24:6
guidance 16:10
guy 12:18
h
h 4:1
hammer 27:21
27:21
happen 28:13
happened 12:4
happy 25:6
he'll 18:20,21
hear 12:14
13:11 20:10
24:4
heard 24:10
hearing 1:11
held 13:18
helen 1:18 6:21
30:2,18
hello 7:4
help 5:13
helps 17:3
28:15
hereto 30:15
31:11
himes 1:14 5:5
13:17,20 14:2
14:5 22:15
25:3 27:17
hiwu 6:2 14:6
hiwu.org 3:8
honor 5:18 7:4
9:20 11:5
15:11 16:6
28:8,17,18
hope 9:8
horseracing
3:2,5
howard 2:3,4
2:12 5:18 13:5
howard.jacobs
2:7
huh 20:20
i
idea 8:20 21:9
24:18
ideas 24:22
identified 6:7
6:13 8:10
identify 6:19
7:18
impact 15:7
incidental
17:15
increase 10:6
13:10 16:13
increased 8:1
10:19 11:13
14:20
individually
8:18 10:5
www.CapitalReportingCompany.com
202-857-3376
ineligibility 8:1
8:16 9:15
17:13
inform 5:13
input 20:6
instructions
7:11
integrity 3:2,5
intended 5:12
interested
30:15 31:12
interesting
19:5
interpretation
11:1 23:2
interpreted
22:10
invited 7:7
issue 11:16,22
12:11 13:20
14:19 20:1
21:14,21
issued 8:7
21:16
issues 24:13
it'll 20:19 26:6
j
jacobs 2:3,4,12
5:17,18 12:14
12:15 13:4,5
14:11,15,17
15:4,10,18
16:6 17:1,5,9
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 37 of 44 * PUBLIC *
PUBLIC
Hearing
[jacobs - never]
18:4,18 19:9
19:21 20:4,16
20:21 23:22
24:6 25:6,18
26:4,8,21 27:7
27:8,10,12
28:5,16
january 19:12
20:19 24:1
jay 1:14
job 1:21
jointly 25:3
26:17 28:11
judge 1:14 5:5
5:6 6:1 24:5
judges 1:3 3:13
3:15 7:1
july 5:10
jump 11:20
justification
19:8
k
kansas 3:7
katy 2:11 5:18
katy.freeman
2:15
keep 7:16 16:14
16:17
kind 17:7 24:12
know 5:5 7:7
12:5,17,20
13:17 14:19
16:10 17:19
August 13, 2026
Page 6
19:16 20:1
21:15 22:7
23:18 24:11,12
24:15,18,19
25:12 26:14,15
27:18 28:3,15
knowledge
30:10 31:6
l
l 2:4,12
landed 25:12
language 14:1
15:3,8
larry 1:6 2:2,10
lashaon 3:14
law 1:3,14 2:4
2:12 3:13,15
5:6 7:1 21:18
leave 8:5
legal 3:12,14
lend 25:17
length 9:14
lerebourg 31:2
31:15
liability 16:5
16:21
light 10:11
line 21:15
link 6:10 7:14
little 25:2
location 1:15
logged 6:10
logistics 7:10
long 15:18 26:6
28:2
look 15:1 18:19
los 26:9
m
made 7:22
16:21 19:11
magic 26:2
main 3:6
make 22:4 25:4
25:13 26:3
makes 19:1
making 28:10
marked 4:3
matter 1:5 5:7
8:7 9:5 13:7
14:1
matters 9:14
19:3
mean 9:4 11:3
12:12,16 13:16
14:1 15:7 16:4
16:19 18:6
19:10,11 20:1
20:16 21:14
23:20 24:9,17
24:18 25:4,13
26:1,3,8,14,19
27:22 28:3
member 6:9
members 6:7
www.CapitalReportingCompany.com
202-857-3376
merits 8:1 13:1
mind 7:12
missing 10:13
18:1
mo 3:7
monday 26:14
26:19
money 14:7
23:17
month 8:16
months 8:18
10:4,16,16,17
14:2,4 19:2,11
22:17
moot 19:13
20:20
move 7:19
multiply 10:17
mute 6:11
n
n 2:1 3:1 5:1
name 6:20
narrow 21:13
nay 19:20
necessary
17:18
need 8:21 16:5
25:16
needs 18:2,12
neither 30:11
31:7
never 13:15
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 38 of 44 * PUBLIC *
PUBLIC
Hearing
[new - proceeding]
new 20:12
22:12
nice 7:6
northwest 1:16
notary 30:19
o
o 5:1
o'clock 26:2
27:6,14
obviate 8:21
obviously 9:11
offered 11:7
offering 9:3
17:8
office 1:3 3:12
3:15,17 7:1,5
officer 30:2
offices 2:4,12
oh 7:6 13:15
14:14 22:14
okay 5:20 6:2,5
10:15 11:8
12:12 14:2,16
15:1,14 16:2
16:19 17:2,2
17:11,13,15,16
18:5,16,16,19
19:1,19 21:4
25:13 27:7,9
27:12,13 28:9
28:13,16
olivia 31:2,15
August 13, 2026
Page 7
once 11:10
25:11
open 15:8,10
15:11
opportunity
13:2
opposed 25:14
optimist 21:3
option 10:2
11:5,7,9 12:9
12:13 16:16
17:8 19:22
options 16:7,17
oral 20:1
order 5:10,13
7:20 8:4,6
10:22 13:21
16:11,11
ordered 8:14
11:2
ought 22:20
23:21
outcome 30:16
31:12
outset 16:8
overly 1:6 2:2
2:10 5:7,16,19
8:2 9:15 13:6,8
13:10 14:12,19
15:4 21:1 23:7
23:14 25:7
overly's 22:17
own 22:10
p
p 2:1,1 3:1,1
5:1
p.m. 1:13 5:2
28:21 29:1
pacific 26:10
pardon 25:20
part 6:17
partial 11:5
12:10 21:10
parties 5:15 8:5
8:11 9:8 13:18
13:19 19:22
20:2,8 22:21
30:12,14 31:8
31:11
party's 10:11
pass 17:21
penalty 14:6
pennsylvania
1:16
people 24:19
25:5 26:15
period 8:2,16
permit 8:9
perspective
21:13
persuasive
20:14
place 22:14
placeholder
24:21 25:14
27:19
www.CapitalReportingCompany.com
202-857-3376
places 13:8
plain 9:17
please 6:18
7:17 28:12
point 20:13
22:12 23:5
24:4,6
position 11:4
12:16 13:13,20
possible 8:6
posture 23:20
preclude 9:4
prefer 12:10
prejudice
13:19
prepared 8:11
31:3
present 3:11
preserved 14:9
presumably
16:11 18:21
21:15 22:4
principle 21:11
prior 30:5
probably 26:11
problem 20:22
procedural
23:20
procedure
13:17
proceeding
1:15 6:8,14,16
23:6 29:2 31:4
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 39 of 44 * PUBLIC *
PUBLIC
Hearing
[proceedings - sanctioning]
proceedings
9:1 14:22 30:3
30:5,6,9 31:6
producing
11:12
prompt 9:13
proportionality
11:20,21 18:8
21:11,17 22:8
proposal 25:8
propose 15:3
26:17 27:15
proposed 12:9
public 6:8,9,13
6:17 30:19
publicly 6:7
purpose 21:6
put 25:1
q
qualified 30:7
question 9:7
16:3 18:9
quicken 14:18
quicker 13:3
quickly 7:9
28:14
quite 28:13
r
r 2:1 3:1 5:1
raise 28:2
raising 9:4
rather 11:6
26:11
reach 11:16
reaching 12:22
reaction 9:18
read 14:12
16:19 19:5
reads 18:22
real 23:16
reality 17:9
really 9:12
11:16 22:3
24:14
reason 13:9,9
18:10 20:20
reasonable
26:15
receiving 8:8
recognized
22:1
reconsidering
20:6
record 5:3 18:2
18:13,14 28:22
30:9 31:5
recorded 30:6
recording 30:8
31:4
redo 24:12
reduce 16:15
16:18
reduced 30:7
related 30:11
31:7
relative 30:13
31:10
August 13, 2026
Page 8
remand 7:20
7:21 8:14,21
11:5 12:10
15:22 16:9,10
16:18 17:17,22
18:7,9,18 21:6
21:10,13,20
22:4 23:16
remanded 5:9
20:2,5
remembering
11:19
remote 1:15
report 25:11
reported 1:18
reporter 5:2
6:15,18,20,21
28:21
reporter's 7:18
requiring
14:13
resolution
19:16
resolved 28:14
response 5:13
result 11:13
23:4
review 8:22
12:21
reviewing
19:18 22:20
revisit 16:5,20
rickman 1:6
2:2,10
www.CapitalReportingCompany.com
202-857-3376
right 6:3 7:19
11:11,19 15:9
17:11,12 19:8
19:18 20:9
21:11 23:19
26:12 27:22
28:15
rights 14:7
road 2:5,13
rule 10:10
11:12 12:1,19
14:3 23:11
ruled 22:16
rules 10:12,19
15:21
ruling 11:17
13:1
rulings 7:22
16:5
run 23:6
s
s 2:1 3:1 4:1 5:1
safety 3:2
sanction 10:3,6
11:13 12:11
13:11 14:21
16:14 17:10
21:2,21
sanction's
23:18,22
sanctioning
16:1
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 40 of 44 * PUBLIC *
PUBLIC
Hearing
[sanctions - think]
sanctions 10:20
11:22 12:2
14:3,10 18:19
22:10,18 23:11
24:3
sarah 3:17 7:3
saying 10:4
12:8 13:12
16:7,18 17:16
20:12
says 13:17
19:19 21:9
22:14,15 25:3
scenario 19:17
24:11
scheduled 26:8
scott 8:7 17:19
seat 22:1
second 9:7 10:2
24:21
see 6:13 7:7
12:6,7 18:21
22:2,14 25:7
26:16
seeing 24:12
seek 8:22
seems 17:14
22:13
send 28:11
sense 10:4 19:1
25:4,14
sent 7:11 12:22
separate 11:17
August 13, 2026
Page 9
serpe 5:12 8:6
8:21 11:2
16:20 23:3
serve 9:15
served 19:11
serves 23:16
set 24:20 25:14
27:18
shell 11:17
22:11,15
showed 19:7
side 9:4
side's 13:20
sides 24:18
signature 30:17
31:14
simply 8:15
13:10
single 11:22
22:9
sir 5:3 6:20
sitting 21:22
six 26:9
skills 30:10
31:6
slight 13:5
solvable 20:22
solve 21:4
sorry 13:5
15:11
sort 25:8 28:3
sound 24:1
sounds 19:17
20:14 22:19
speak 7:13
12:18
speaking 7:15
7:17,17 13:22
specifically
8:13
staff 6:22
stand 28:20
start 5:15 9:7
26:9
states 1:1
step 20:19
stick 19:5
street 3:6
stuff 24:16
subject 11:11
15:19
submit 8:5
submitted
15:22
subsequent 8:6
substance 7:10
7:19
suggest 16:20
suggesting 9:12
16:4
suggestion 16:4
suggestions 9:3
suite 2:5,13 3:6
summarized
12:4
supposed 18:20
20:13
www.CapitalReportingCompany.com
202-857-3376
sure 20:3,3
27:8
sworn 30:5
t
t 4:1
tadesse 1:18
6:21 30:2,18
take 7:20 15:12
15:15 18:19
20:11
taken 30:3,12
31:9
takes 23:17
talk 15:17 24:7
25:16 28:4,11
28:12
talked 13:17
technical 14:1
technically
12:21
terms 12:8
terribly 14:6
testifying 30:5
thank 5:4 6:22
7:8 9:19 28:8,9
28:16,19
themself 6:19
things 25:16
think 6:12 9:5
9:14 10:13
12:4,15 13:16
14:6 15:4,13
17:16,17 18:1
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 41 of 44 * PUBLIC *
PUBLIC
Hearing
August 13, 2026
[think - yeah]
18:11 19:3,7
19:11,12,21
21:4,18 22:21
24:15,18,22
26:6,10,16
27:20
thinking 12:3
23:21
thinks 23:8,22
third 16:15
19:21
thought 9:8
three 15:6
16:17
thursday 1:12
time 1:13 5:2
12:17 19:13
23:5,17 26:10
27:4,16 28:10
times 7:16 15:5
28:12
today 7:15
18:17 26:2,5
took 12:21
13:18
topics 8:10 9:6
trade 1:2 5:6
transcribed
6:16
transcriber
31:1
transcript 31:3
31:5
Page 10
transcriptionist
30:8
tried 23:7
true 30:9 31:5
truncate 28:3
try 27:22
trying 19:16
twenty 15:6
two 8:10 9:3
10:17 11:7
15:1,3,5
typewriting
30:7
u
ultimate 14:18
ultimately
13:12 20:4,16
24:15
under 14:3
understand
10:7 12:8
17:16
understanding
10:18 14:18
23:16
understood
10:2,6
undertook
10:10
unit 3:5
united 1:1
week 26:1,5,14
26:19
version 6:16
welfare 3:5
video 6:6,11
westlake 2:6,14
7:11,16
witness 30:4
videoconfere...
wondering
2:3,11 3:4,13
24:9
3:16,18
view 7:22 10:17 work 15:12,15
26:2,19,22
16:13 22:10
27:2
viewed 21:1
works 14:4
village 2:6,14
26:18 27:1
violations
worry 12:17
11:17
worrying 17:15
virginia 30:20
worth 17:15
w
worthy 9:5
want 13:13
write 25:2
14:8 15:14
wrong 9:17
20:18 21:1
11:11 19:13
22:6 24:14
wrote 15:20
26:15
17:18
wanted 8:10
x
13:3
x 4:1
wants 23:1
y
28:2
washington
yay 19:19
1:17
yeah 9:19
way 6:9 9:16
10:15 13:22
10:19 11:12
14:15 18:14
12:3 17:18
20:9 21:3 27:2
18:5 28:10,13
27:11
we've 20:12
25:1,12
v
www.CapitalReportingCompany.com
202-857-3376
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 42 of 44 * PUBLIC *
PUBLIC
Federal Rules of Civil Procedure
Rule 30
(e) Review By the Witness; Changes.
(1) Review; Statement of Changes. On request by the
deponent or a party before the deposition is
completed, the deponent must be allowed 30 days
after being notified by the officer that the
transcript or recording is available in which:
(A) to review the transcript or recording; and
(B) if there are changes in form or substance, to
sign a statement listing the changes and the
reasons for making them.
(2) Changes Indicated in the Officer's Certificate.
The officer must note in the certificate prescribed
by Rule 30(f)(1) whether a review was requested
and, if so, must attach any changes the deponent
makes during the 30-day period.
DISCLAIMER:
THE FOREGOING FEDERAL PROCEDURE RULES
ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.
THE ABOVE RULES ARE CURRENT AS OF APRIL 1,
2019.
PLEASE REFER TO THE APPLICABLE FEDERAL RULES
OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 08/13/2026 OSCAR NO. 616261 -PAGE Page 43 of 44 * PUBLIC *
PUBLIC
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