In a typical model for FTC intervention in an alleged deception, the second step is:

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The second step in the FTC intervention model for an alleged deception is typically to request substantiation from the advertiser to support their claims. This is important as the burden of proof lies with the advertiser to demonstrate that their advertising claims are truthful and not misleading. Only once the advertiser has provided adequate substantiation will the FTC move on to the next steps, such as issuing a cease and desist order or requesting a consent decree.

In a Typical Model for FTC Intervention in an Alleged