UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

In the Matter of 

CHEGG, INC., a corporation. 

FILE NO. 2023151 

AGREEMENT CONTAINING 

CONSENT ORDER 

The Federal Trade Commission (“Commission”) has conducted an investigation of certain 

acts and practices of Chegg, Inc. (“Proposed Respondent”). The Commission’s Bureau of 

Consumer Protection (“BCP”) has prepared a draft of an administrative Complaint (“draft 

Complaint”). BCP and Proposed Respondent enter into this Agreement Containing Consent 

Order (“Consent Agreement”) to resolve the allegations in the attached draft Complaint through 

a proposed Decision and Order to present to the Commission, which is also attached and made a 

part of this Consent Agreement. 

IT IS HEREBY AGREED by and between Proposed Respondent and BCP, that: 

1. Proposed Respondent is Chegg, Inc., a Delaware corporation with its principal office or place 

of business at 3990 Freedom Circle, Santa Clara, CA 95054. 

2. Proposed Respondent neither admits nor denies any of the allegations in the Complaint, 

except as specifically stated in the Decision and Order. Only for purposes of this action, 

Proposed Respondent admits the facts necessary to establish jurisdiction. 

3. Proposed Respondent waives: 

a. Any further procedural steps; 

b. The requirement that the Commission’s Decision contain a statement of findings of fact 

and conclusions of law; and 

c. All rights to seek judicial review or otherwise to challenge or contest the validity of the 

Decision and Order issued pursuant to this Consent Agreement. 

4. This Consent Agreement will not become part of the public record of the proceeding unless 

and until it is accepted by the Commission. If the Commission accepts this Consent Agreement, 

it, together with the draft Complaint, will be placed on the public record for 30 days and 

information about them publicly released. Acceptance does not constitute final approval, but it 

serves as the basis for further actions leading to final disposition of the matter. Thereafter, the 

Commission may either withdraw its acceptance of this Consent Agreement and so notify 

Proposed Respondent, in which event the Commission will take such action as it may consider 

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appropriate, or issue and serve its Complaint (in such form as the circumstances may require) 

and decision in disposition of the proceeding, which may include an Order. See Section 2.34 of 

the Commission’s Rules, 16 C.F.R. § 2.34 (“Rule 2.34”). 

5. If this agreement is accepted by the Commission, and if such acceptance is not subsequently 

withdrawn by the Commission pursuant to Rule 2.34, the Commission may, without further 

notice to Proposed Respondent: (1) issue its Complaint corresponding in form and substance 

with the attached draft Complaint and its Decision and Order; and (2) make information about 

them public. Proposed Respondent agrees that service of the Order may be effected by its 

publication on the Commission’s website (ftc.gov), at which time the Order will become final. 

See Rule 2.32(d). Proposed Respondent waives any rights they may have to any other manner of 

service. See Rule 4.4. 

6. When final, the Decision and Order will have the same force and effect and may be altered, 

modified, or set aside in the same manner and within the same time provided by statute for other 

Commission orders. 

7. The Complaint may be used in construing the terms of the Decision and Order. No 

agreement, understanding, representation, or interpretation not contained in the Decision and 

Order or in this Consent Agreement may be used to vary or contradict the terms of the Decision 

and Order. 

8. Proposed Respondent agrees to comply with the terms of the proposed Decision and Order. 

Proposed Respondent understands that it may be liable for civil penalties and other relief for 

each violation of the Decision and Order after it becomes final. 

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CHEGG, INC. 

By: ________________________ 

Woodie Dixon, Jr. 

General Counsel 

Date: ________________________ 

By: ________________________ 

Andrew Geoffrey Berg 

Darren Abernethy 

Greenberg Traurig 

Attorneys for Proposed Respondent 

Date: ________________________ 

By: __________________________ 

Travis LeBlanc 

Scott Dailard 

Charlie Wood 

Cooley LLP 

Attorneys for Proposed Respondent 

Date: ________________________ 

FEDERAL TRADE COMMISSION 

By: ________________________ 

Brian Shull 

Miles Plant 

Genevieve Bonan 

Attorneys 

Bureau of Consumer Protection 

APPROVED: 

By: ________________________ 

Kristin Cohen 

Acting Associate Director 

Division of Privacy and Identity Protection 

By: ________________________ 

Samuel Levine 

Director 

Bureau of Consumer Protection 

Date: ________________________ 

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