The market for teeth whitening began in the 1990s. North Carolina dentists grew a market for the application of concentrations of peroxide to teeth to create a chemical reaction that results in whiter teeth. In about 2003, non-dentists also started offering teeth-whitening ser-vices, often at a significantly lower price than dentists. Day spas, chain whitening franchis-es, and other businesses offered the service. Shortly thereafter, dentists began complaining to the North Carolina State Board of Dental Examiners and sought to have the non-dentist whitening services shut down because allowing such services to be performed by non-dentists created public health, safety, and welfare concerns. After receiving complaints from dentists, the Board opened an investigation into teeth-whitening services performed by non-dentists. As a result of the investigations, the Board issued 47 cease-and-desist letters to 29 non-dentist teeth-whitening pro-viders. The letters were issued on official let-terhead and noted that the companies were subject to misdemeanor charges for the unauthorized practice of dentistry if they did not cease and desist their operations. The result was that non-dentist teeth whiteners were eliminated from North Carolina. The FTC filed a complaint against the board charging it with unfair competition. The Board moved to dismiss the complaint. Who is correct in this situation? [North Carolina State Bd. of Dental Examiners v F.T.C., 574 U.S. 494 (2015)]