The FTC has rule making authority but it will certainly be litigated. My expectation is a case will quickly be brought in the Northern District of Texas, they'

The FTC has rule making authority but it will certainly be litigated. My expectation is a case will quickly be brought in the Northern District of Texas, they'll rule it unlawful (following Commissioner Holyoak's lead), then it'll get bumped up to the 5th Circuit on appeal and they'll issue a stay. I don't expect to see this rule take affect anytime soon, if ever.