Why DOT Should Interpret "Deceptive Practices" Using a "Reasonable Consumer" Standard [The Air & Space Lawyer]

David Heffernan co-authored an article for The Air & Space Lawyer, explaining how the FTC, in applying its test for "deception," determines what constitutes "reasonable" consumer behavior. The article also examines how DOT has at times strayed from a "reasonable consumer" point of reference toward a more expansive approach to regulation and enforcement. Lastly, it concludes that DOT should adopt the FTC's test for "deception" while relying solely on a "reasonable consumer" standard. 

To read the full article, click here.


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David Heffernan

Vice Chair, Transportation & Trade

dheffernan@cozen.com

(202) 463-2537


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