Last week the Federal Trade Commission settled a case against the adware company DirectRevenue for a variety of deceptive, deceitful and disgraceful practices that, among other things, including bundling pop-up adware with supposed anti-popup software, according to a dissent by Commissioner Jon Leibowitz. Commissioner Leibowitz dissented not because the injunctive provisions stopping future practices were inadequate, but because his 4 colleagues stopped short of forcing the principals of DirectRevenue to disgorge their ill-gotten gains:

But the $1.5 million in monetary relief that the Commission obtained as part of the consent agreement is a disappointment because it apparently leaves DirectRevenue’s owners lining their pockets with more than $20 million from a business model based on deceit.