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>$193K seems like a pittance compared to the money they're making off of this.

I don't have any special knowledge of this specific case, but it's important to note as a general principle that often the point of these fines is as the start of a process. It creates a formal legal record of actual damages and judgement, but the government doesn't see massive harm done yet nor think the business should be dead entirely. They want a modification of certain practices going forward, and the expectation is that the company will immediately comply and that's the end of it.

If instead the business simply paid the fine and flagrantly blew it off and did the exact same thing without so much as a fig leaf, round 2 would see the book thrown at them. Defiance of process and lawful orders is much easier to prove and has little to no wiggle room, regardless of the complexity that began an action originally. Same as an individual investigated for a crime who ends up with a section 1001 charge or other obstruction of justice and ends up in more trouble for that than the underlying cause of investigation.

So yes, not necessarily a huge fine. But if there weren't huge actual damages that seems appropriate too, so long as the behavior doesn't repeat (and everyone else in the industry is on notice now too).






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