CRA was retained to assess consumer claims that “Buy One Get One” or “Buy One Get Two” sales practices improperly induce consumer purchases with false and misleading product price information and false time-limits for nutritional products. In particular, CRA assessed Plaintiffs’ claim that such sales practices mislead consumers into believing that they are receiving an extra product as a “free gift.”
Calculating damages in IEEPA tariff refund litigation
But it did not resolve a harder question: Who bore their economic cost? That distinction is now driving two parallel waves of private litigation: commercial...