On August 16th, the Ninth Circuit affirmed the entry of summary judgment finding appellants civilly liable for making material misrepresentations and engaging in deceptive business practices in violation of the Federal Trade Commission Act and the FTC's Franchise Rule in their sale of internet kiosk business opportunities. The Court also affirmed the imposition of equitable monetary relief upon the companies and a constructive trust over a portion of fees paid to appellants' attorneys. FTC v. Network Services Depot, Inc.