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The division of responsibility among the Federal Trade Commission (FTC), the courts, and the jury in civil suits for violations of FTC cease and desist orders' has been the subject of recent controversy. The problem arises because in combatting unfair or deceptive business practices2 it may be necessary for the FTC to do more than issue a cease and desist order if it is to insure that such practices will be discontinued . An FTC order becomes final and effective either after the passing of a statutorily prescribed period of time4 or following enforcement by a circuit court of appeals; 5 the Commission is then empowered to seek judicial sanctions to prevent further violations of its order. To this end, it may initiate a civil suit in district court for consumer redress, 6 for equitable relief, or for statutorily prescribed civil

The Nature of Judicial Involvement in Civil Penalty Proceedings to Execute FTC Cease and Desist Orders