Consumer Reports thanks the Federal Trade Commission (“FTC”) for the opportunity to comment on the proposed consent agreement with Sunday Riley Skincare for false advertising. We strongly urge the FTC to revise this settlement as it establishes a weak precedent for companies that engage in astroturfing. By settling this case with no disgorgement of revenues or other meaningful consequences, future wrongdoers are unlikely to be deterred and will feel empowered to pollute the marketplace of information with fraudulent testimonials.