[seanhunter]

This complaint seems somewhat unlikely to lead to an actual FTC action. The criticism is about unfair or deceptive business practices under the FTC act. The FTC has a fairly specific definition of what constitutes unfair or deceptive business practises[1]

  >  “Deceptive” practices are defined in the Commission’s Policy Statement on Deception as involving a material representation, omission or practice that is likely to mislead a consumer acting reasonably in the circumstances. An act or practice is “unfair” if it “causes or is likely to cause substantial injury to consumers which is not reasonably avoidable by consumers themselves and not outweighed by countervailing benefits to consumers or to competition.” 

[1] https://www.ftc.gov/about-ftc/mission/enforcement-authority