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Extract to table / ftc-ca-ag-inquiry-summary-memo.docx
ftc-ca-ag-inquiry-summary-memo.docx
Parties
Cascade Retail Holdings Inc
Harkness LLP
Fieldhaven Consulting Group LLC
Ridgeview Digital LLC
OnPoint Data Solutions Inc
Peakview Analytics Inc
Thornbridge Media Corp
Associates LLP
Dates
June 20, 2025
June 2, 2025
December 31, 2025
August 15, 2025
May 19, 2025
January 31, 2025
September 14, 2023
January 1, 2021
October 14, 2023
November 13, 2023
Amounts
$3.87
$7,500
$2,500
$18.4
$25
$50
$1,340,000
$2,600,000
$3,150,000
$1,440,000
Obligations
Any new opt-out mechanisms, consent flows, or DSR interfaces deployed as part of Cascade's compliance program must be designed and rigorously tested to ensure they are clear, conspicuous, and free of manipulative or deceptive design elements
Regulatory Posture and Enforcement Risk Although both the FTC and California AG matters were resolved (in the case of the FTC) or effectively concluded (in the case of the AG) without formal enforcement action, Cascade's regulatory history creates a heightened enforcement-risk profile that must inform the design and prioritization of the compliance program
The FTC's ongoing and expanding focus on dark patterns means that any new consumer-facing opt-out mechanisms, consent flows, or DSR interfaces deployed as part of the compliance program must be designed and tested with heightened care
As a publicly traded company, Cascade is required to disclose material risk factors in its periodic filings on Forms 10-K and 10-Q, as well as material legal proceedings under Item 103 of Regulation S-K
All new consumer-facing opt-out and consent interfaces — including the OnPoint CMP deployment, the DSR portal enhancements, and the mobile-app consent flows — must be designed in compliance with the FTC's published guidance on dark patterns and tested for usability before deployment