3. The Complaint states a claim upon which relief may be granted against Defendant under Sections 5(a), 5(1), 13(b), and 16(a)(1) of the FTC Act, 15 U.S.C. $8 45(a), 45(1), 52, 53(b), and 56(a)(1), including for violations of Parts I and IV of the Commission's Decision and Order in In re Facebook, Inc. , C-4365, 2012 FTC LEXIS 135 (F.T.C. July 27, 2012)