District Court, District of Columbia December 1, 2009, Civil Action 09-1636 (RBW) (American Bar Ass'n v. Federal Trade Commission)

MEMORANDUM OPINION

REGGIE B. WALTON, District Judge.

On August 27, 2009, the plaintiff, the American Bar Association, filed a three-count complaint against the Federal Trade Commission (the “Commission”), alleging that the Commission’s application of Final Rule, Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003, 72 Fed.Reg. 63,718 (Nov.