Publishing.com, LLC, Christian Mikkelsen, and Rasmus Mikkelsen; Analysis of Proposed Consent Order To Aid Public Comment
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Abstract
The consent agreement in this matter settles alleged violations of Federal law prohibiting unfair or deceptive acts or practices. The attached Analysis of Proposed Consent Order to Aid Public Comment describes both the allegations in the complaint and the terms of the consent order--embodied in the consent agreement--that would settle these allegations.
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<title>Federal Register, Volume 91 Issue 73 (Thursday, April 16, 2026)</title>
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[Federal Register Volume 91, Number 73 (Thursday, April 16, 2026)]
[Notices]
[Pages 20456-20458]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-07420]
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FEDERAL TRADE COMMISSION
[File No. 242 3055]
<a href="http://Publishing.com">Publishing.com</a>, LLC, Christian Mikkelsen, and Rasmus Mikkelsen;
Analysis of Proposed Consent Order To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement; request for comment.
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SUMMARY: The consent agreement in this matter settles alleged
violations of Federal law prohibiting unfair or deceptive acts or
practices. The attached Analysis of Proposed Consent Order to Aid
Public Comment describes both the allegations in the complaint and the
terms of the consent order--embodied in the consent agreement--that
would settle these allegations.
DATES: Comments must be received on or before May 18, 2026.
ADDRESSES: Interested parties may file comments online or on paper by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Please write ``<a href="http://Publishing.com">Publishing.com</a>;
File No. 242 3055'' on your comment and file your comment online at
<a href="https://www.regulations.gov">https://www.regulations.gov</a> by following the instructions on the web-
based form. If you prefer to file your comment on paper, please mail
your comment to: Federal Trade Commission, Office of the Secretary, 600
Pennsylvania Ave. NW, Mail Stop H-144 (Annex P), Washington, DC 20580.
[[Page 20457]]
FOR FURTHER INFORMATION CONTACT: Emily Cope Burton (phone: 415-848-
5111), Assistant Regional Director, Western Region, Federal Trade
Commission, 90 7th St., Suite 14-300, San Francisco, CA 94103.
SUPPLEMENTARY INFORMATION: Pursuant to section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing a consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of 30 days. The following
Analysis to Aid Public Comment describes the terms of the consent
agreement and the allegations in the complaint. An electronic copy of
the full text of the consent agreement package can be obtained at
<a href="https://www.ftc.gov/news-events/commission-actions">https://www.ftc.gov/news-events/commission-actions</a>.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before May 18, 2026.
Write ``<a href="http://Publishing.com">Publishing.com</a>; File No. 242 3055'' on your comment. Your
comment--including your name and your State--will be placed on the
public record of this proceeding, including, to the extent practicable,
on the <a href="https://www.regulations.gov">https://www.regulations.gov</a> website.
We encourage you to submit comments through the <a href="https://www.regulations.gov">https://www.regulations.gov</a> website. Postal mail addressed to the Commission
will be subject to delay because of heightened security screening. If
you prefer to file your comment on paper, write ``<a href="http://Publishing.com">Publishing.com</a>; File
No. 242 3055'' on your comment and on the envelope, and send it via
overnight service to: Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue NW, Mail Stop H-144 (Annex P),
Washington, DC 20580.
Because your comment will be placed on the publicly accessible
website at <a href="https://www.regulations.gov">https://www.regulations.gov</a>, you are solely responsible for
making sure your comment does not include any sensitive or confidential
information. In particular, your comment should not include sensitive
personal information, such as your or anyone else's Social Security
number; date of birth; driver's license number or other State
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure your comment does not include
sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2),
16 CFR 4.10(a)(2)--including competitively sensitive information such
as costs, sales statistics, inventories, formulas, patterns, devices,
manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule 4.9(c). In particular,
the written request for confidential treatment that accompanies the
comment must include the factual and legal basis for the request and
must identify the specific portions of the comment to be withheld from
the public record. See FTC Rule 4.9(c). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted on the <a href="https://www.regulations.gov">https://www.regulations.gov</a> website--as legally
required by FTC Rule 4.9(b)--we cannot redact or remove your comment
from that website, unless you submit a confidentiality request that
meets the requirements for such treatment under FTC Rule 4.9(c), and
the General Counsel grants that request.
Visit the FTC website at <a href="https://www.ftc.gov">https://www.ftc.gov</a> to read this document
and the news release describing the proposed settlement. The FTC Act
and other laws the Commission administers permit the collection of
public comments to consider and use in this proceeding, as appropriate.
The Commission will consider all timely and responsive public comments
it receives on or before May 18, 2026. For information on the
Commission's privacy policy, including routine uses permitted by the
Privacy Act, see <a href="https://www.ftc.gov/site-information/privacy-policy">https://www.ftc.gov/site-information/privacy-policy</a>.
Analysis of Proposed Consent Order To Aid Public Comment
The Federal Trade Commission (``Commission'') has accepted, subject
to final approval, an Agreement Containing Consent Order (``Consent
Agreement'') with <a href="http://Publishing.com">Publishing.com</a>, LLC, Christian Mikkelsen, and Rasmus
Mikkelsen (collectively, ``Respondents''). The proposed Decision and
Order (``Order''), included in the Consent Agreement and subject to
final Commission approval, is designed to remedy Respondents' deceptive
practices in connection with marketing their self-publishing programs.
The proposed Order has been placed on the public record for 30 days
to receive comments from interested persons. Comments received during
this period will become part of the public record. After 30 days, the
Commission will again review the Consent Agreement, and the comments
received, and will decide whether it should withdraw from the Consent
Agreement and take appropriate action or make the proposed Order final.
The complaint alleges that Respondents violated section 5 of the
FTC Act, 15 U.S.C. 45, by making false or unsubstantiated earnings
claims about their self-publishing programs. The complaint further
alleges that Respondents violated section 5 of the FTC Act by
misrepresenting its refund policy as a simple money-back guarantee for
12 months. Finally, the complaint alleges that Respondents falsely
represented that consumer reviews and testimonials for their programs
represented the actual, genuine experiences and opinions of ordinary
and impartial purchasers.
The proposed Order contains provisions designed to prevent
Respondents from engaging in these and similar acts and practices in
the future. Provision I of the proposed Order permanently restrains and
enjoins Respondents from making earnings claims or assisting others in
making earnings claims unless those claims are non-misleading and
Respondents have a reasonable basis for them. Provision II prohibits
Respondents from making the specific misrepresentations alleged in the
complaint and misrepresentations concerning any other material fact in
the sale of any product or service. Provision III prohibits Respondents
from misrepresenting or failing to disclose material terms and
conditions of any cancellation or refund policy or failing to promptly
honor a consumer's cancellation or refund request in compliance with
company policies in effect at the time of the consumer's purchase.
Provision IV prohibits Respondents from making certain
misrepresentations regarding testimonials and endorsements.
Provision V requires Respondents to disclose any unexpected
material connections with endorsers or reviewers and any payments or
incentives for posting reviews. Provision VI requires Respondents to
pay $1.5 million in monetary relief and Provision VII details
additional monetary provisions necessary to ensure receipt of the
monetary relief. Provision VIII requires
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Respondents to provide the Commission with sufficient information about
its customers so that the Commission can efficiently administer
redress, if possible.
Provisions IX through XIII relate to notice and compliance.
Provision IX requires Respondents to acknowledge receipt of the Order;
distribute the Order to principals, officers, and certain employees and
agents; and obtain signed acknowledgements from them. Provision X
requires Respondents to submit compliance reports to the Commission one
year after the Order's issuance and when certain events occur.
Provision XI requires Respondents to create certain records for 15
years and retain them for five years thereafter. Provision XII requires
Respondents to provide information or documents necessary to monitor
compliance with the Order during the period of the Order's effective
dates. Provision XIII provides the effective dates of the Order,
including that, with exceptions, the Order will terminate in 20 years.
The purpose of this analysis is to facilitate public comment on the
Consent Agreement and proposed Order to aid the Commission in
determining whether it should make the proposed Order final. This
analysis is not an official interpretation of the proposed Order and
does not modify its terms in any way.
By direction of the Commission.
April J. Tabor,
Secretary.
[FR Doc. 2026-07420 Filed 4-15-26; 8:45 am]
BILLING CODE 6750-01-P
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