2023151 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of 

CHEGG, INC., a corporation. 

DECISION AND ORDER 

DOCKET NO. C-4782

DECISION 

The Federal Trade Commission (“Commission”) initiated an investigation of certain acts and 

practices of the Respondent named in the caption. The Commission’s Bureau of Consumer 

Protection (“BCP”) prepared and furnished to Respondent a draft Complaint. BCP proposed to 

present the draft Complaint to the Commission for its consideration. If issued by the 

Commission, the draft Complaint would charge the Respondent with violations of the Federal 

Trade Commission Act. 

Respondent and BCP thereafter executed an Agreement Containing Consent Order (“Consent 

Agreement”). The Consent Agreement includes: 1) statements by Respondent that it neither 

admits nor denies any of the allegations in the Complaint, except as specifically stated in this 

Decision and Order, and that only for purposes of this action, it admits the facts necessary to 

establish jurisdiction; and 2) waivers and other provisions as required by the Commission’s 

Rules. 

The Commission considered the matter and determined that it had reason to believe that 

Respondent has violated the Federal Trade Commission Act, and that a Complaint should issue 

stating its charges in that respect. The Commission accepted the executed Consent Agreement 

and placed it on the public record for a period of 30 days for the receipt and consideration of 

public comments. The Commission duly considered any comments received from interested 

persons pursuant to Section 2.34 of its Rules, 16 C.F.R. § 2.34. Now, in further conformity with 

the procedure prescribed in Rule 2.34, the Commission issues its Complaint, makes the 

following Findings, and issues the following Order: 

Findings 

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

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

 

 

 

 

2. The Commission has jurisdiction over the subject matter of this proceeding and over the 

Respondent, and the proceeding is in the public interest. 

ORDER 

Definitions 

For purposes of this Order, the following definitions apply: 

A. “April 2018 Breach” means the exposure of individuals’ Covered Information from 

systems of or controlled by Respondent in or about April 2018. 

B. “April 2020 Breach” means the exposure of individuals’ Covered Information from 

systems of or controlled by Respondent in or about April 2020. 

C. “Clear and Conspicuous” or “Clearly and Conspicuously” means that a required 

disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by 

ordinary consumers, including in all of the following ways: 

1. In any communication that is solely visual or solely audible, the disclosure must 

be made through the same means through which the communication is presented. 

In any communication made through both visual and audible means, such as a 

television advertisement, the disclosure must be presented simultaneously in both 

the visual and audible portions of the communication even if the representation 

requiring the disclosure (“triggering representation”) is made through only one 

means. 

2. A visual disclosure, by its size, contrast, location, the length of time it appears, 

and other characteristics, must stand out from any accompanying text or other 

visual elements so that it is easily noticed, read, and understood. 

3. An audible disclosure, including by telephone or streaming video, must be 

delivered in a volume, speed, and cadence sufficient for ordinary consumers to 

easily hear and understand it. 

4. In any communication using an interactive electronic medium, such as the 

Internet or software, the disclosure must be unavoidable. 

5. The disclosure must use diction and syntax understandable to ordinary consumers 

and must appear in each language in which the triggering representation appears. 

6. The disclosure must comply with these requirements in each medium through 

which it is received, including all electronic devices and face-to-face 

communications. 

2
 

 

 

7. The disclosure must not be contradicted or mitigated by, or inconsistent with, 

anything else in the communication. 

8. When the representation or sales practice targets a specific audience, such as 

children, the elderly, or the terminally ill, “ordinary consumers” includes 

reasonable members of that group. 

D. “Covered Incident” means any incident that results in Respondent notifying, pursuant to 

a statutory or regulatory requirement, any U.S. federal, state, or local government entity 

that information of or about an individual consumer was, or is reasonably believed to 

have been, accessed, acquired, or publicly exposed without authorization. 

E. “Covered Information” means information from or about an individual consumer, 

including: (a) a first and last name; (b) a home or physical address; (c) an email address 

or other online contact information, such as an instant messaging user identifier or a 

screen name; (d) a mobile or other telephone number; (e) a driver’s license or other 

government-issued identification number; (f) date of birth; (g) geolocation information 

sufficient to identify street name and name of a city or town; (h) credit or debit card 

information (including a partial credit or debit card number with more than 5 digits); (i) 

user ID, or other persistent identifier that can be used to recognize a user over time and 

across different devices, websites, or online services; or (j) user account credentials, such 

as a login name and password (whether plain text, encrypted, hashed, and/or salted). 

“Covered Information” does not include information that a user intends to make public 

using Respondent’s services. 

F. “Identified Breaches” includes the September 2017 Breach, April 2018 Breach, June 

2019 Breach, and April 2020 Breach. 

G. “June 2019 Breach” means the exposure of individuals’ Covered Information from 

systems of or controlled by Respondent that was discovered in or about June 2019. 

H. “Medical Information” means information relating to the health of an individual 

consumer, including but not limited to medical history information, prescription 

information, hospitalization information, clinical laboratory testing information, health 

insurance information, or physician exam notes. 

I. “Respondent” means Chegg, Inc., a Delaware corporation, and its successors and 

assigns. 

J. “September 2017 Breach” means the exposure of individuals’ Covered Information 

from systems of or controlled by Respondent in or about September 2017. 

Provisions 

I. Prohibition Against Misrepresentations 

IT IS ORDERED that Respondent, and Respondent’s officers, agents, employees, and 

attorneys, and all other persons in active concert or participation with any of them, who receive 

3
 

 

 

 

 

 

actual notice of this Order, whether acting directly or indirectly, in connection with promoting or 

offering for sale any product or service, must not misrepresent in any manner, expressly or by 

implication: 

A. The extent to which Respondent collects, maintains, uses, discloses, deletes, or permits or 

denies access to any Covered Information; and 

B. The extent to which Respondent otherwise protects the privacy, security, availability, 

confidentiality, or integrity of any Covered Information. 

II. Data Retention and Deletion 

IT IS FURTHER ORDERED that Respondent, within 60 days after issuance of this Order, 

must: 

A. Document and adhere to a retention schedule for Covered Information. Such schedule 

shall set forth: (1) the purpose or purposes for which each type of Covered Information is 

collected; (2) the specific business needs for retaining each type of Covered Information; 

and (3) a set timeframe for deletion of each type of Covered Information (absent any 

intervening deletion requests from consumers) that precludes indefinite retention of any 

Covered Information; and 

B. Provide a Clear and Conspicuous link on the homepage and initial login page of 

Respondent’s websites directing consumers to an online form through which they can 

request access to or the deletion of their Covered Information. Respondent must respond 

to and fulfill every request either in accordance with the applicable consumer data access 

and deletion rights and related procedures prescribed by applicable law in the consumer’s 

jurisdiction of residence or, if the location of the consumer’s residence is unknown to 

Respondent, or if there are no applicable laws in the consumer’s jurisdiction that provide 

for consumer rights to access or delete Covered Information, then in accordance with the 

consumer data access and deletion rights afforded by law to residents of the state in 

which Respondent’s principal executive offices are located. If there are no laws that 

provide consumers with rights to access or delete Covered Information within the state in 

which Respondent’s principal executive offices are located, then Respondent must fulfill 

any such requests within 45 days of receiving them. The time period to respond to the 

request may be extended once by an additional 45 days when reasonably necessary, 

provided the consumer is provided notice of the extension within the first 45-day period. 

Provided, however, that any Covered Information that Respondent is otherwise required 

to delete or destroy pursuant to this provision may be retained, and may be disclosed, as 

requested by a government agency or otherwise required by law, regulation, court order, 

or other legal obligation, including as required by rules applicable to the safeguarding of 

evidence in pending litigation, or pursuant to written policies Clearly and Conspicuously 

posted on Respondent’s websites relating to investigations or disciplinary actions by 

educational institutions concerning academic integrity. 

4
 

 

 

 

 

 

 

 

 

 

 

III. Multi Factor Authentication for Users 

IT IS FURTHER ORDERED that within six months after issuance of this Order, Respondent 

must provide multi-factor authentication methods as an option or as a requirement for consumer 

users. This time period may be extended for a reasonable time if such extension is approved in 

writing by a representative of the Commission. Respondent must not use, provide access to, or 

disclose any information collected for multi-factor authentication for any other purpose, unless 

such information is obtained separate and apart from enabling multi-factor authentication. 

Respondent may use equivalent, widely adopted industry authentication options that are not 

multi-factor, if the person responsible for the Information Security Program under sub-Provision 

V.C: (1) approves in writing the use of such equivalent authentication options; and (2) 

documents a written explanation of how the authentication options are widely adopted and at 

least equivalent to the security provided by multi-factor authentication. 

IV. Notice to Individuals 

IT IS FURTHER ORDERED that Respondent, within 60 days after issuance of this Order, 

must provide a notice to each individual whose unencrypted Social Security number, financial 

account information, date of birth, user account credentials, or Medical Information was exposed 

in an Identified Breach, to the extent such individual has not already previously been sent 

notification by Respondent. The notice shall be delivered by email and shall include an exact 

copy of the notice attached hereto as Attachment A (“Identified Breaches Notice”), with the 

subject line “Information about Chegg Data Breach.” Respondent must not include with the 

Identified Breaches Notice any other information, documents, or attachments. 

V. Mandated Information Security Program 

IT IS FURTHER ORDERED that Respondent and any business that Respondent controls, 

directly or indirectly, in connection with the collection, maintenance, use, or disclosure of, or 

provision of access to, Covered Information, must, within 90 days after issuance of this Order, 

establish and implement, and thereafter maintain, a comprehensive information security program 

(“Information Security Program”) that protects the security, availability, confidentiality, and 

integrity of Covered Information under Respondent’s control. To satisfy this requirement, 

Respondent must, at a minimum: 

A. Document in writing the content, implementation, and maintenance of the Information 

Security Program; 

B. Provide the written program and any evaluations thereof or material updates thereto to 

Respondent’s board of directors or governing body or, if no such board or equivalent 

governing body exists, to a senior officer of Respondent responsible for Respondent’s 

Information Security Program at least once every 12 months and promptly (not to exceed 

30 days) after a Covered Incident; 

C. Designate a qualified employee to coordinate and be responsible for the Information 

Security Program; 

5
 

 

 

 

 

 

 

 

D. Assess and document, at least once every 12 months and promptly (not to exceed 30 

days) following a Covered Incident, internal and external risks to the security, 

confidentiality, or integrity of Covered Information that could result in the 

(1) unauthorized collection, maintenance, use, or disclosure of, or provision of access to, 

Covered Information; or the (2) misuse, loss, theft, alteration, destruction, or other 

compromise of such information; 

E. Design, implement, maintain, and document safeguards that control for the internal and 

external risks Respondent identifies to the security, confidentiality, availability, or 

integrity of Covered Information identified in response to sub-Provision V.D. Each 

safeguard must take into account the volume and sensitivity of the Covered Information 

that is at risk, and the likelihood that the risk could be realized and result in the 

(1) unauthorized collection, maintenance, use, alteration, or disclosure of, or provision of 

access to, Covered Information; or the (2) misuse, loss, theft, destruction, or other 

compromise of such information. Such safeguards must also include: 

1. Training of all of Respondent’s employees, at least once every 12 months, on how 

to safeguard Covered Information; 

2. Documenting in writing the content, implementation, and maintenance of an 

incident response plan designed to ensure the identification of, investigation of, 

and response to the unauthorized access to Covered Information. Respondent 

shall revise and update this incident response plan to adapt to any changes to its 

assets or networks; 

3. Implementing technical measures to log and monitor Respondent’s networks and 

assets for anomalous activity and active threats. Such measures shall require 

Respondent to determine baseline system activity and identify and respond to 

anomalous events and unauthorized attempts to access or exfiltrate Covered 

Information; 

4. Policies and procedures to minimize data collection, storage, and retention, 

including data deletion or retention policies and procedures; 

5. Implementing data access controls for all assets (including databases) storing 

Covered Information and technical measures, policies, and procedures to 

minimize or prevent online attacks resulting from the misuse of valid credentials, 

including: (a) restricting inbound and outbound connections; (b) requiring and 

enforcing strong passwords or other credentials; (c) preventing the reuse of 

known compromised credentials to access Covered Information; (d) implementing 

automatic password resets for known compromised credentials; and (e) limiting 

employee access to what is needed to perform that employee’s job function; 

6. Requiring multi-factor authentication methods for all employees, contractors, and 

affiliates in order to access any assets (including databases) storing Covered 

Information. Such multi-factor authentication methods for all employees, 

contractors, and affiliates should not include telephone or SMS-based 

6
 

 

 

 

 

 

authentication methods and must be resistant to phishing attacks. Respondent 

may use equivalent, widely adopted industry authentication options that are not 

multi-factor, if the person responsible for the Information Security Program under 

sub-Provision V.C: (1) approves in writing the use of such equivalent 

authentication options; and (2) documents a written explanation of how the 

authentication options are widely adopted and at least equivalent to the security 

provided by multi-factor authentication; 

7. Developing and implementing configuration standards to harden system 

components against known threats and vulnerabilities. New system components 

shall not be granted access to Respondent’s network, resources, or Covered 

Information until they meet Respondent’s configuration standards; 

8. Encryption of, at a minimum, all Social Security numbers, passport numbers, 

financial account information, tax information, dates of birth associated with a 

user’s account, Medical Information associated with a user’s account, and user 

account credentials on Respondent’s computer networks, including but not limited 

to cloud storage; 

9. Policies and procedures to ensure that all information technology (“IT”) assets on 

Respondent’s network with access to Covered Information are securely installed 

and inventoried at least once every 12 months; 

10. Implementing vulnerability and patch management measures, policies, and 

procedures that require confirmation that any directives to apply patches or 

remediate vulnerabilities are received and completed and that include timelines 

for addressing vulnerabilities that account for the severity and exploitability of the 

risk implicated; and 

11. Enforcing policies and procedures to ensure the timely investigation of data 

security events and the timely remediation of critical and high-risk security 

vulnerabilities. 

F. Assess, at least once every 12 months and promptly (not to exceed 30 days) following a 

Covered Incident, the sufficiency of any safeguards in place to address the internal and 

external risks to the security, confidentiality, or integrity of Covered Information, and 

modify the Information Security Program based on the results; 

G. Assess, prior to the acquisition of any entity that maintains, processes, or transmits 

Covered Information (“Acquired Entity”), the effectiveness of that entity’s safeguards to 

protect such information. Either during the acquisition due diligence process or 

following such acquisition, Respondent must independently test the effectiveness of the 

Acquired Entity’s safeguards to protect Covered Information. Respondent shall not 

integrate any application or information system into its network(s) until (1) all material 

risks to the security, confidentiality, and integrity of Covered Information identified in 

such a test are remediated; and (2) such application or information system meets the 

requirements of this Provision. Provided, however, that Respondent shall have 90 days 

7
 

 

 

after integrating any application or information system of an acquired entity into its 

networks to implement the requirements of sub-Provision V.E.6 with respect to such 

application or system. 

H. Test and monitor the effectiveness of the safeguards at least once every 12 months and 

promptly (not to exceed 30 days) following a Covered Incident and modify the 

Information Security Program based on the results. Such testing and monitoring must 

include vulnerability testing of Respondent’s networks once every six months and 

promptly (not to exceed 30 days) after a Covered Incident, and penetration testing of 

Respondent’s networks at least once every 12 months and promptly (not to exceed 30 

days) after a Covered Incident; 

I. Select and retain service providers capable of safeguarding Covered Information they 

access through or receive from Respondent, and contractually require service providers to 

implement and maintain safeguards sufficient to address the internal and external risks to 

the security, confidentiality, or integrity of Covered Information; and 

J. Evaluate and adjust the Information Security Program in light of any changes to 

Respondent’s operations or business arrangements, a Covered Incident, new or more 

efficient technological or operational methods to control for the risks identified in subProvision V.D of this Order, or any other circumstances that Respondent knows or has 

reason to know may have an impact on the effectiveness of the Information Security 

Program or any of its individual safeguards. At a minimum, Respondent must evaluate 

the Information Security Program at least once every 12 months and modify the 

Information Security Program based on the results. 

VI. Information Security Assessments By A Third Party 

IT IS FURTHER ORDERED that, in connection with compliance with Provision V, 

Respondent shall obtain initial and biennial assessments (“Assessments”): 

A. The Assessments must be obtained from a qualified, objective, independent thirdparty professional (“Assessor”), who: (1) uses procedures and standards 

generally accepted in the profession; (2) conducts an independent review of the 

Information Security Program; (3) retains all documents relevant to each 

Assessment for 5 years after completion of such Assessment; and (4) will provide 

such documents to the Commission within ten days of receipt of a written request 

from a representative of the Commission. The Assessor may not withhold any 

documents from the Commission on the basis of a claim of confidentiality, 

proprietary or trade secrets, work product protection, attorney-client privilege, 

statutory exemption, or any similar claim. 

B. For each Assessment, Respondent must provide the Associate Director for 

Enforcement for the Bureau of Consumer Protection at the Federal Trade 

Commission with the name, affiliation, and qualifications of the proposed 

Assessor, whom the Associate Director shall have the authority to approve in her 

or his sole discretion. 

8
 

 

 

 

 

 

 

 

C. The reporting period for the Assessments must cover: (1) the first 180 days after 

the issuance date of the Order for the initial Assessment; and (2) each two-year 

period thereafter for 20 years after issuance of the Order for the biennial 

Assessments. 

D. Each Assessment must, for the entire assessment period: 

1. Determine whether Respondent has implemented and maintained the 

Information Security Program required by Provision V of this Order; 

2. Assess the effectiveness of Respondent’s implementation and maintenance of 

sub-Provisions V.A-J of this Order; 

3. Identify any gaps or weaknesses in, or instances of material noncompliance 

with, the Information Security Program; 

4. Address the status of gaps or weaknesses in, or instances of material noncompliance with, the Information Security Program that were identified in any 

prior Assessment required by this Order; and 

5. Identify specific evidence (including documents reviewed, sampling and 

testing performed, and interviews conducted) examined to make such 

determinations, assessments, and identifications, and explain why the 

evidence that the Assessor examined is: (a) appropriate for assessing an 

enterprise of Respondent’s size, complexity, and risk profile; and (b) 

sufficient to justify the Assessor’s findings. No finding of any Assessment 

shall rely primarily on assertions or attestations by Respondent’s 

management. The Assessment must be signed by the Assessor, state that the 

Assessor conducted an independent review of the Information Security 

Program and did not rely primarily on assertions or attestations by 

Respondent’s management and state the number of hours that each member of 

the assessment team worked on the Assessment. To the extent that 

Respondent revises, updates, or adds one or more safeguards required under 

Provision V of this Order during an Assessment period, the Assessment must 

assess the effectiveness of the revised, updated, or added safeguard(s) for the 

time period in which it was in effect, and provide a separate statement 

detailing the basis for each revised, updated, or additional safeguard. 

E. Each Assessment must be completed within 60 days after the end of the reporting 

period to which the Assessment applies. Unless otherwise directed by a Commission 

representative in writing, Respondent must submit an unredacted copy of the initial 

Assessment to the Commission within 10 days after the Assessment has been 

completed via email to DEbrief@ftc.gov or by overnight courier (not the U.S. Postal 

Service) to: Associate Director for Enforcement, Bureau of Consumer Protection, 

Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begin: “In re Chegg, Inc.” Respondent must retain an 

unredacted copy of each subsequent biennial Assessment as well as a proposed 

9
 

 

 

 

 

 

 

 

redacted copy of each subsequent biennial Assessment suitable for public disclosure 

and provide to the Associate Director for Enforcement within 10 days of request. The 

initial Assessment and any subsequent biennial Assessment provided to the 

Commission must be marked, in the upper right-hand corner of each page, with the 

words “DPIP Assessment” in red lettering. 

VII. Cooperation With Third-Party Information Security Assessor 

IT IS FURTHER ORDERED that Respondent, in connection with any Assessment 

required by Provision VI of this Order, shall: 

A. Provide or otherwise make available to the Assessor all information and material 

in its possession, custody, or control that is relevant to the Assessment for which 

there is no reasonable claim of privilege; 

B. Provide or otherwise make available to the Assessor information about 

Respondent’s network(s) and all of Respondent’s IT assets so that the Assessor 

can determine the scope of the Assessment, and visibility to those portions of the 

network(s) and IT assets deemed in scope; and 

C. Disclose all material facts to the Assessor, and not misrepresent in any manner, 

expressly or by implication, any fact material to the Assessor’s: (1) determination 

of whether Respondent has implemented and maintained the Information Security 

Program required by Provision V of this Order; (2) assessment of the 

effectiveness of the implementation and maintenance of sub-Provisions V.A-J of 

this Order; or (3) identification of any gaps or weaknesses in, or instances of 

material noncompliance with, the Information Security Program. 

VIII. Annual Certifications 

IT IS FURTHER ORDERED that Respondent shall: 

A. One year after the issuance date of this Order, and each year thereafter, provide 

the Commission with a certification from the a senior corporate manager, or, if no 

such senior corporate manager exists, a senior officer of Respondent responsible 

for Respondent’s Information Security Program that: (1) Respondent has 

established, implemented, and maintained the requirements of this Order; and (2) 

Respondent is not aware of any material noncompliance that has not been (a) 

corrected or (b) disclosed to the Commission. The certification must be based on 

the personal knowledge of a senior corporate manager, or, if no such senior 

corporate manager exists, a senior officer of Respondent responsible for 

Respondent’s Information Security Program, or subject matter experts upon 

whom the senior corporate manager, or, if no such senior corporate manager 

exists, a senior officer of Respondent responsible for Respondent’s Information 

Security Program reasonably relies in making the certification. 

10
 

 

 

 

 

 

B. Unless otherwise directed by a Commission representative in writing, submit all 

annual certifications to the Commission pursuant to this Order via email to 

DEbrief@ftc.gov or by overnight courier (not the U.S. Postal Service) to 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begin: “In re Chegg” 

IX. Covered Incident Reports 

IT IS FURTHER ORDERED that, within ten days of any notification to a United States 

federal, state, or local entity of a Covered Incident, Respondent shall submit a report to the 

Commission. The report must include, to the extent possible: 

A. The date, estimated date, or estimated date range when the Covered Incident 

occurred; 

B. A description of the facts relating to the Covered Incident, including the causes of 

the Covered Incident, if known; 

C. A description of each type of information that was affected by the Covered 

Incident; 

D. The number of consumers whose information was affected by the Covered 

Incident; 

E. The acts that Respondent has taken to date to remediate the Covered Incident and 

protect Covered Information from further exposure or access, and protect affected 

individuals from identity theft or other harm that may result from the Covered 

Incident; and 

F. A representative copy of each materially different notice sent by Respondent to 

consumers or to any U.S. federal, state, or local government entity. 

G. Unless otherwise directed by a Commission representative in writing, all Covered 

Incident reports to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begin: “In re Chegg, Inc.” 

11
 

 

 

 

A. 

B. 

C. 

X. Order Acknowledgements

IT IS FURTHER ORDERED that Respondent obtain acknowledgments of receipt of this 

Order: 

Respondent, within 10 days after the effective date of this Order, must submit to 

the Commission an acknowledgment of receipt of this Order sworn under penalty 

of perjury. 

For 5 years after issuance of this Order, Respondent must deliver a copy of this 

Order to: (1) all principals, officers, and directors; (2) all employees having 

managerial responsibilities for cybersecurity, privacy, and the collection, use, or 

disclosure of Covered Information and all agents and representatives who 

participate in cybersecurity, privacy, and the collection, use, or disclosure of 

Covered Information; and (3) any business entity resulting from any change in 

structure as set forth in Provision XI. Delivery must occur within 10 days of 

issuance of this Order for current personnel. For all others, delivery must occur 

before they assume their responsibilities. 

From each individual or entity to which Respondent delivered a copy of this 

Order, Respondent must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

XI. Compliance Reporting 

IT IS FURTHER ORDERED that Respondent make timely submissions to the 

Commission: 

A. One year after issuance of this Order, Respondent must submit a compliance 

report, sworn under penalty of perjury. Respondent must: (a) identify the 

primary physical, postal, and email address and telephone number, as designated 

points of contact, which representatives of the Commission may use to 

communicate with Respondent; (b) identify all of Respondent’s businesses by all 

of their names, telephone numbers, and physical, postal, email, and Internet 

addresses; (c) describe the activities of each business, including the goods and 

services offered, the means of advertising, marketing, and sales; (d) describe in 

detail whether and how Respondent is in compliance with each Provision of this 

Order; and (e) provide a copy of each Order Acknowledgment obtained pursuant 

to this Order, unless previously submitted to the Commission. 

B. For 12 years after issuance of this Order, Respondent must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the 

following: (a) any designated point of contact; or (b) the structure of any entity 

that Respondent has any ownership interest in or controls directly or indirectly 

that may affect compliance obligations arising under this Order, including: 

creation, merger, sale, or dissolution of the entity or any subsidiary, parent, or 

affiliate that engages in any acts or practices subject to this Order. 

C. Respondent must submit to the Commission notice of the filing of any bankruptcy 

12
 

 

 

 

 

 

 

 

A. 

B. 

C. 

D. 

E. 

petition, insolvency proceeding, or similar proceeding by or against Respondent 

within 14 days of its filing. 

D. Any submission to the Commission required by this Order to be sworn under 

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, 

such as by concluding: “I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. Executed on: 

_____” and supplying the date, signatory’s full name, title (if applicable), and 

signature. 

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begin: “In re Chegg, Inc.” 

XII. Recordkeeping 

IT IS FURTHER ORDERED that Respondent must create certain records for 12 years after 

issuance of the Order and retain each such record for 5 years. Specifically, Respondent must 

create and retain the following records: 

Accounting records showing the revenues from all goods or services sold; 

Personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person’s: name; addresses; telephone numbers; job 

title or position; dates of service; and (if applicable) the reason for termination; 

Records of all consumer complaints and refund requests, whether received 

directly or indirectly, such as through a third party, and any response; 

All records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and 

A copy of each widely disseminated, unique advertisement or other marketing 

material that references or otherwise relates to: (a) Respondent’s privacy and data 

security practices; or (b) Respondent’s websites or online services offered by 

Respondent that, if any, are directed at students in grades kindergarten through 

seventh grade. 

XIII. Compliance Monitoring 

IT IS FURTHER ORDERED that, for the purpose of monitoring Respondent’s compliance 

with this Order: 

13
 

 

 

A. Within 14 days of receipt of a written request from a representative of the 

Commission, Respondent must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for 

depositions; and produce documents for inspection and copying. The 

Commission is also authorized to obtain discovery, without further leave of court, 

using any of the procedures prescribed by Federal Rules of Civil Procedure 29, 30 

(including telephonic depositions), 31, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission is authorized to communicate 

directly with Respondent. Respondent must permit representatives of the 

Commission to interview any employee or other person affiliated with 

Respondent who has agreed to such an interview. The person interviewed may 

have counsel present. 

C. The Commission may use all other lawful means, including posing, through its 

representatives as consumers, suppliers, or other individuals or entities, to 

Respondent or any individual or entity affiliated with Respondent, without the 

necessity of identification or prior notice. Nothing in this Order limits the 

Commission’s lawful use of compulsory process, pursuant to Sections 9 and 20 of 

the FTC Act, 15 U.S.C. §§ 49, 57b-1. 

XIV. Order Effective Dates 

IT IS FURTHER ORDERED that this Order is final and effective upon the date of its 

publication on the Commission’s website (ftc.gov) as a final order. This Order will terminate 20 

years from the date of its issuance (which date may be stated at the end of this Order, near the 

Commission’s seal), or 20 years from the most recent date that the United States or the 

Commission files a complaint (with or without an accompanying settlement) in federal court 

alleging any violation of this Order, whichever comes later; provided, however, that the filing of 

such a complaint will not affect the duration of: 

A. Any Provision in this Order that terminates in less than 20 years; 

B. This Order’s application to any Respondent that is not named as a defendant in such 

complaint; and 

C. This Order if such complaint is filed after the Order has terminated pursuant to this 

Provision. 

Provided, further, that if such complaint is dismissed or a federal court rules that the Respondent 

did not violate any provision of the Order, and the dismissal or ruling is either not appealed or 

upheld on appeal, then the Order will terminate according to this Provision as though the 

complaint had never been filed, except that the Order will not terminate between the date such 

14
complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date 

such dismissal or ruling is upheld on appeal. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

ISSUED: January 25, 2023

15