Ok, this isn't 100% on-topic, but in numerous posts on FTC settlements its argued that since companies typically get off with only a portion of the penalty, it's still in their best interests to violate. Ah, but here is an example of a company which tried to hedge their financials submitted to the FTC & the court to get the reduced settlement... Now, they have to pay the full $1.9 MILLION penalty thanks to the "avalanche clause"... http://www.ftc.gov/opa/2007/04/sunnyhealth.shtm So don't get discouraged when a company skirts paying the price because they claim insolvency. If they didn't dot their i's and cross their t's it could all come back to haunt them.