For decades, the Federal Trade Commission $($FTC$)$ resolved fair trade and advertising disputes through individual adjudications. In the $1960$s$,$ the FTC began setting forth rules that defined unfair trade practices. In cases involving violations of these rules, the due process rights of participants were more limited and did not include cross$-$examination. This was because, although anyone found violating a rule would receive a full adjudication, the legitimacy of the rule itself could not be challenged in the adjudication. Any party charged with violating a rule was almost certain to lose the adjudication. Affected parties complained to a court, arguing that their rights before the FTC were unduly limited by the new rules.