• On November 1, 2012, United States District Courts in Florida and Arizona granted the FTC’s applications for temporary restraining orders (TROs) against a host of companies alleged to have engaged in a fraudulent robocalling scheme in violation of the FTC’s Telemarketing Sales Rule and Trade Regulation Rule. The FTC alleges that five companies based in Arizona and Florida are responsible for making millions of illegal pre-recorded calls from “Rachel” and “Cardholder Services,” offering to lower the call recipient’s credit card rates and saving them thousands of dollars in finance charges in the process. These companies somehow persuaded some called parties to pay an up-front fee, at which point the companies, the FTC alleges, “do little or nothing to lower their credit card interest rates. The only thing that some companies do … is to initiate three-way calls with consumers’ credit card issuers and orally request a rate reduction, a request that consumers could make on their own and that invariably is denied.” The principal defendants do business as Treasure Your Success, Ambrosia Web Design, A+ Financial Center, The Green Savers, and Key One Solutions, LLC. In granting the TROs, the courts appointed receivers for the defendants and found that the FTC showed a substantial likelihood of success on the merits of its claims. The courts also ordered the defendants to appear on November 5, 2012, for a hearing on the FTC’s motions for preliminary injunctions that would continue to enjoin the challenged calls and related activities until each case’s conclusion. See, e.g., FTC v. The Green Savers, LLC, No. 12-cv-1588 (M.D. Fla.); FTC v. Ambrosia Web Design LLC, No. CV-12-2248 (D. Ariz.).