The FTC presents no actual evidence that consumers were harmed by the Institute of Store Planners' ethics code.  Instead, the Commission relies on a false interpretation of the ethics code’s intent and application, and from there proceeds to make a number of speculative, unprovable, and ultimately arbitrary conclusions. In the process, the FTC violates the First Amendment by imposing a government-enforced prior restraint on ISP’s present and future speech. The precedent set by this consent order, as well as other recently adopted FTC consent orders against private associations, will have a chilling effect on the First Amendment rights of all Americans.  For these reasons, entry of the proposed consent order should be rejected.

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