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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of: 

Docket No. 9408 Intuit Inc., a corporation. 

INTUIT INC.’S MOTION IN LIMINE TO EXCLUDE NON-FINAL OR INCOMPLETE 

ADVERTISEMENTS 

Intuit moves to preclude Complaint Counsel from introducing into evidence exhibits (or 

portions of exhibits) that contain non-final or incomplete advertisements, which if allowed into 

evidence would create a misleading impression of the challenged ads. The exhibits (or portions) 

sought to be excluded comprise draft scripts for television ads (portions of GX293, 651); 

cropped screenshots of Intuit’s website and web ads (GX163, 164, 166, 183, 201, 459); cropped 

screenshots of marketing emails (GX171, 172, 181, 182, 375, 377-382, 386-390, 480); 

screenshots of still-frames from video ads (GX185, 186, 203, 205, 209, 308, 310, and portions of 

GX662); screenshots of third-party websites that host video ads not included in the exhibits 

(GX162, 320, 322, 384, 385, 478, 479, 499); screenshots of social-media ads that incorporate 

videos not included in the exhibits (GX174-176, 187-188); and excerpts from search-engine 

results (GX167-170, 177-180, 190-195, 496, 497).1

 When confronted with these incomplete ads 

during a deposition, the designee for the Bureau of Consumer Protection, William Maxson, 

1

 The complete list of the exhibits (or portions) sought to be excluded by this motion is: GX162-

164, 166-172, 174-183, 185-188, 190-195, 201, 203, 205, 209, 293 (pages CC-00006250, CC00006251, CC-00006253, CC-00006254, CC-00006256, CC-00006257, CC-00006259, CC00006260, and CC-00006263 to CC-00006271 only), 308, 310, 320, 322, 375, 377-382, 384-

390, 459, 478-480, 496, 497, 499, 651 (page CC-00013983 only), and 662 (pages CC-00014475 

to CC-00014478 only). 

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invited Intuit “to bring [the issue of incomplete ads] to the trier of fact and to the judge in this 

case” if Intuit “believes that [Complaint Counsel were] not presenting all of the information.” 

GX161 at 149:13-14, 150:11-12; see also id. at 151:3-15. In filing this motion, Intuit is doing 

just that. 

This motion should be granted because courts have consistently “emphasized that in 

reviewing FTC actions prohibiting unfair advertising practices under the Federal Trade 

Commission Act a court must consider the advertisement in its entirety and not ... engage in 

disputatious dissection.” S.C. Johnson & Son, Inc. v. Clorox Co., 241 F.3d 232, 238 (2d Cir. 

2001) (quotation marks omitted; emphasis added); see also id. (“The entire mosaic should be 

viewed rather than each tile separately.”). Put simply, “[t]he tendency of the advertising to 

deceive must be judged by viewing it as a whole,” FTC v. Cyberspace.Com LLC, 453 F.3d 1196, 

1200 (9th Cir. 2006), and “in full context,” Time Warner Cable, Inc. v. DIRECTV, Inc., 497 F.3d 

144, 158 (2d Cir. 2007). Courts have specifically applied this tenet in the context of the 

Commission, with one court of appeals invoking “the principle that the Commission looks to the 

impression made by the advertisements as a whole.” Am. Home Prod. Corp. v. FTC, 695 F.2d 

681, 688 (3d Cir. 1982). 

That principle is simply an application of the more general—and fundamental—rule of 

evidence that factfinders ought not be presented with incomplete evidence. Specifically, under 

the rule of completeness, the “omitted portion of a statement must be placed in evidence if 

necessary to ... place the admitted portion in context, ... or to ensure fair and impartial 

understanding of the admitted portion.” United States v. Thiam, 934 F.3d 89, 96 (2d Cir. 2019); 

see also Fed. R. Evid. 106. In cases about advertising, this rule is interpreted to mean that an 

incomplete portion of marketing material should not be admitted unless it “conveys the 

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substance and context of the [advertisement] as a whole.” Laurel Rd. Bank v. CommonBond, 

Inc., 2019 WL 1034188, at *1 n.3 (S.D.N.Y. Mar. 5, 2019). 

Applying these principles in a misleading-advertising case, one district court excluded 

testimony about a survey “ostensibly relating to” two advertisements because the survey used 

“cropped and out of context snippets taken from” the advertisements, rather than the full 

advertisements that were disseminated to an audience. Bracco Diagnostics, Inc. v. Amersham 

Health, Inc., 627 F.Supp.2d 384, 452 (D.N.J. 2009). Because “the survey withheld ... essential 

visual, contextual and informational portions,” the court held that the survey had “no probative 

value as to whether there was false or misleading advertising or the effect of any advertising on a 

customer.” Id. at 452-453. 

In contravention of these principles, Complaint Counsel seek to introduce numerous 

exhibits that contain ads in draft, excerpted, cropped, or otherwise incomplete form, usually 

leaving out important contextual information that consumers saw, but Complaint Counsel would 

like the Court not to see. Consumers never saw these ads in those forms, and thus could not 

possibly have been deceived by them. As in Bracco, then, the exhibits have “no probative value 

as to whether there was false or misleading advertising,” or as to “the effect of any advertising on 

a customer.” 627 F.Supp.2d at 453 (emphasis added). The exhibits are therefore “[i]rrelevant” 

and “immaterial” and so “shall be excluded.” 16 C.F.R. §3.43(b). 

Even if they were not completely irrelevant, the exhibits at issue “would be misleading,” 

16 C.F.R. §3.43(b). They thus would still warrant exclusion to the extent they omit relevant 

information and might be mistaken for or confused with complete ads that consumers actually 

might have seen. 

Consider a few examples pertaining to Intuit’s social media and web advertising: GX187 

depicts a screenshot of a social media video ad without providing the accompanying video. 

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Moreover, the screenshot omits the text from that video ad stating, “Simple tax returns only.” 

See GX342 ¶159. GX459—a screenshot of a web ad—is cropped to exclude the bottom half of 

the ad’s disclosure. Compare GX334 (showing same ad with full disclosure). GX163—a 

screenshot from the website—is similarly cropped to exclude a dropdown field lower down on 

the webpage that provided “Important offer details and disclosures,” including a disclosure of the 

qualifications for Intuit’s Free Edition product. See, e.g., RX6, 7. The same exhibit also depicts 

text inviting consumers to “See why it’s free,” but the exhibit does not show that clicking on that 

text would have directed consumers to a pop-up with detailed information about the tax 

situations covered by Free Edition. See, e.g., RX23. Likewise, GX166 depicts a web ad 

including the words “simple tax returns,” but the exhibit does not show that clicking on those 

words would have caused a pop-up to appear stating “You can file with TurboTax Free Edition if 

you have a simple tax return” and detailing what is (and is not) a “simple tax return.” See, e.g., 

RX3, 25. Similarly, GX201—another screenshot from Intuit’s website—is cropped to omit 

“Important offer details and disclosures.” And as with GX163 and 166, GX201 depicts text 

without revealing that that text included multiple hyperlinks leading to detailed descriptions of 

Free Edition’s eligibility limitations. See, e.g., RX9. 

Complaint Counsel’s proffered exhibits would be misleading as to Intuit’s video ads as 

well. For instance, pages CC-00014475 to CC-00014477 of GX662 depict still-frames from 

draft video ads before text disclosures were added. None of these ads was ever disseminated to 

consumers without those disclosures. 

Equally misleading are Complaint Counsel’s proffered exhibits (GX167-170, 177-180, 

190-195, 496, 497) that depict excerpts from search-engine results containing the word “free.” 

As the Federal Circuit has explained, “[s]earch-engine results ... provide little context to discern 

how a term is actually used on the webpage that can be accessed through the search result link” 

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and thus are “insufficient to determine the nature of the use of a term.” In re Bayer 

Aktiengesellschaft, 488 F.3d 960, 967 (Fed. Cir. 2007). 

Finally, the incomplete ads this motion seeks to exclude would be cumulative and thus a 

waste of time to consider, as Complaint Counsel can and will rely on numerous exhibits 

comprising advertisements that consumers actually saw, in their full and complete form. Indeed, 

the evidence in this case will include the complete versions of several of the ads Complaint 

Counsel seek to introduce in incomplete form. For example, the ad excerpted in GX459 is 

offered in its complete form in GX334; the ad excerpted in GX203 is offered in its complete 

form as GX202; and the ad excerpted in GX209 is offered in its complete form as GX208. The 

exhibits sought to be excluded would add nothing to the complete advertisements. Their 

introduction at trial would thus be “cumulative” and therefore “needless,” providing an 

independent reason to exclude them. 16 C.F.R. §3.43(b). 

CONCLUSION 

The exhibits (or portions thereof) listed in footnote 1 of this motion should be excluded 

from evidence at trial. 

Dated: February 10, 2023 Respectfully submitted, 

By:/s/ David Z. Gringer 

DAVID Z. GRINGER 

Wilmer Cutler Pickering 

 Hale and Dorr LLP 

7 World Trade Center 

250 Greenwich Street 

New York, NY 10007 

Telephone: (212) 230-8800 

David.Gringer@wilmerhale.com 

JONATHAN E. PAIKIN 

JENNIFER MILICI 

DEREK A. WOODMAN 

JOSEPH MEYER 

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Wilmer Cutler Pickering 

 Hale and Dorr LLP 

2100 Pennsylvania Avenue NW 

Washington, DC 20037 

Telephone: (202) 663-6000 

Jonathan.Paikin@wilmerhale.com 

Jennifer.Milici@wilmerhale.com 

Derek.Woodman@wilmerhale.com 

Attorneys for Intuit Inc. 

6 
 

 

 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of: 

Docket No. 9408 Intuit Inc., a corporation. 

STATEMENT PURSUANT TO 

ADDITIONAL PROVISION 4 OF THE SCHEDULING ORDER 

Pursuant to Additional Provision No. 4 of the April 27, 2022 Scheduling Order, as 

adopted in the September 12, 2022 First Revised Scheduling Order, Respondent Intuit Inc. 

respectfully submits this Statement representing that Counsel for Respondent has conferred with 

Complaint Counsel in a good faith effort to resolve the issues raised by this motion. The parties 

corresponded by email on February 8 and 9, 2023, concerning this motion but were unable to 

reach an agreement. 

Dated: February 10, 2023 Respectfully submitted, 

WILMER CUTLER PICKERING HALE 

AND DORR LLP 

David Z. Gringer 

/s/ Derek A. Woodman 

Jonathan E. Paikin 

7 World Trade Center Jennifer Milici 

250 Greenwich St. Derek A. Woodman 

New York, NY 10007 2100 Pennsylvania Ave NW 

Telephone: (212) 230-8800 Washington, DC 20037 

Facsimile: (212) 230-8888 Telephone: (202) 663-6000 

David.Gringer@wilmerhale.com Facsimile: (202) 663-6363 

Jonathan.Paikin@wilmerhale.com 

Jennifer.Milici@wilmerhale.com 

Derek.Woodman@wilmerhale.com 

Attorneys for Respondent Intuit Inc. 
 

 

 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of: 

Docket No. 9408 Intuit Inc., a corporation. 

[PROPOSED] ORDER GRANTING INTUIT INC.’S MOTION IN LIMINE TO 

EXCLUDE NON-FINAL OR INCOMPLETE ADVERTISEMENTS 

Upon consideration of Respondent Intuit Inc.’s February 10, 2023 Motion in Limine to 

Exclude Non-Final or Incomplete Advertisements, 

IT IS ORDERED that the motion is GRANTED. 

IT IS FURTHER ORDERED that the following exhibits or portions of exhibits are 

excluded from evidence in this proceeding : GX 162-164, 166-172, 174-183, 185-188, 190-195, 

201, 203, 205, 209, 293 (pages CC-00006250, CC-00006251, CC-00006253, CC-00006254, CC00006256, CC-00006257, CC-00006259, CC-00006260, and CC-00006263 to CC-00006271 

only), 308, 310, 320, 322, 375, 377-382, 384-390, 459, 478-480, 496, 497, 499, 651 (page CC00013983 only), and 662 (pages CC-00014475 to CC-00014478 only). 

Date: _________________ ____________________________ 

D. Michael Chappell 

Chief Administrative Law Judge 
 

 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of: 

Docket No. 9408 Intuit Inc., a corporation. 

DECLARATION OF DEREK A. WOODMAN IN SUPPORT OF INTUIT INC.’S 

MOTION IN LIMINE TO EXCLUDE NON-FINAL OR INCOMPLETE 

ADVERTISEMENTS 

I, Derek A. Woodman, declare as follows: 

1. I am an attorney at Wilmer Cutler Pickering Hale and Dorr LLP. I represent 

Respondent Intuit Inc. in the above-captioned proceeding. 

2. I submit this declaration in support of Intuit’s Motion in Limine to Exclude NonFinal or Incomplete Advertisements. 

I. EVIDENCE CITED IN SUPPORT OF THE MOTION 

3. True and correct copies of pages CC-00005358 and CC-00005505 to CC00005508 of Complaint Counsel’s GX161 are attached. 

4. Provided with the motion are true and correct copies of Complaint Counsel’s 

GX202 and 208. 

5. A true and correct copy of Complaint Counsel’s GX334 is attached. 

6. True and correct copies of pages CC-00006905, CC-00006979, and CC-00006980 

of Complaint Counsel’s GX342 are attached. 

7. True and correct copies of Intuit’s RX3, 6, 7, 9, 23, and 25 are attached. 

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II. EVIDENCE SOUGHT TO BE EXCLUDED 

A. Draft Scripts for Television Ads 

8. Provided with the motion are true and correct courtesy copies of pages CC00006250, CC-00006251, CC-00006253, CC-00006254, CC-00006256, CC-00006257, CC00006259, CC-00006260, and CC-00006263 to CC-00006271 of Complaint Counsel’s GX293, 

and page CC-00013983 of Complaint Counsel’s GX651. 

B. Cropped Screenshots of Intuit’s Website and Web Ads 

9. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX163, 164, 166. 183, 201, and 459. 

C. Cropped Screenshots of Marketing Emails 

10. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX171, 172, 181, 182, 375, 377-382, 386-390, and 480. 

D. Screenshots of Still-Frames from Video Ads 

11. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX185, 186, 203, 205, 209, 308, 310, and pages CC-00014475 to CC-00014478 of 

Complaint Counsel’s GX662. 

E. Screenshots of Third-Party Websites That Host Video Ads Not Included in 

the Exhibits 

12. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX162, 320, 322, 384, 385, 478, 479, and 499. 

F. Screenshots of Social-Media Ads That Incorporate Videos Not Included in 

the Exhibits 

13. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX174-176, 187-188. 

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G. Excerpts from Search-Engine Results 

14. Provided with the motion are true and correct courtesy copies of Complaint 

Counsel’s GX167-170, 177-180, 190-195, 496, and 497. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on this 10th day of February, 2023, in Washington, D.C. 

By: /s/ Derek A. Woodman 

 Derek A. Woodman 

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1 UNITED STATES OF AMERICA 

2 BEFORE THE FEDERAL TRADE COMMISSION 

3 

4 _________________________ 

5 In The Matter of: ) 

) Docket No. 9408 

6 Intuit Inc., ) 

a corporation, ) 

7 ) 

Respondent. ) 

8 _________________________ 

9 

10 

11 

12 - C O N F I D E N T I A L -

13 

14 

15 Videotaped Deposition of William T. Maxson 

16 December 8, 2022 

17 9:23 a.m. 

18 

19 

20 

21 Reported by: Bonnie L. Russo 

22 Job No. 5570324 

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1 distract consumers' attention from the 12:28:14 

2 disclosure." 12:28:17 

3 Do you see that? 12:28:17 

4 A. I see that text. 12:28:17 

5 Q. Why is it important to review the 12:28:18 

6 entire ad to assess whether a disclosure is 12:28:20 

7 effective? 12:28:24 

8 A. I'm not aware of additional context 12:28:25 

9 beyond what is in the dot-com disclosure guide 12:28:53 

10 itself. Based on my own personal knowledge, I 12:28:56 

11 would say that when you're reviewing an ad, you 12:29:00 

12 generally want to know what is the entire 12:29:03 

13 universe of that ad campaign to make sure that 12:29:06 

14 you know all the facts that are relevant and -- 12:29:09 

15 and that you're not missing anything. 12:29:11 

16 Q. Can I ask why -- you've referred 12:29:12 

17 many, many times to the evidence in complaint 12:29:15 

18 counsel's motion for summary decision. Why 12:29:19 

19 over and over and over again they rely on only 12:29:20 

20 snippets of ads and not the full ad? 12:29:24 

21 MR. ANGUIZOLA: Objection. 12:29:27 

22 Mischaracterizes the -- the evidence and 12:29:28 

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1 misstates prior testimony and argumentative. 12:29:30 

2 THE WITNESS: I think the -- the 12:29:39 

3 complaint, the motion for summary decision, 12:29:39 

4 related briefing, the -- the oral arguments on 12:29:41 

5 the motion for summary decision, and the other 12:29:44 

6 evidence produced in discovery include the 12:29:48 

7 ads -- the advertising campaigns that are at 12:29:52 

8 issue in this case, and I think those ads speak 12:29:56 

9 for themselves. 12:29:58 

10 If Intuit believes that there is 12:30:00 

11 further context to provide with respect to 12:30:03 

12 advertisements, I mean, obviously, they have 12:30:06 

13 the ability to -- to bring that to the trier of 12:30:08 

14 fact and to the judge in this case. 12:30:12 

15 BY MR. GRINGER: 12:30:13 

16 Q. You don't think it's misleading to 12:30:13 

17 present only snippets of advertisements to the 12:30:15 

18 court and the commissioners? 12:30:18 

19 MR. ANGUIZOLA: Objection. 12:30:19 

20 Argumentative and misstates the record. 12:30:21 

21 THE WITNESS: I don't believe 12:30:27 

22 anything in the complaint or the motion for 12:30:29 

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1 summary decision or the related oral arguments 12:30:31 

2 misstated or were misleading in any way. 12:30:35 

3 Obviously, Intuit has the ability to 12:30:40 

4 counter any claims that we make as part of the 12:30:43 

5 proceeding. No. I think going out of our way 12:30:46 

6 in this complaint and the motion for summary 12:30:51 

7 decision and the related briefing in this case 12:30:54 

8 to prevent -- to present to the trier of fact 12:30:57 

9 what our claims are about these ads -- Intuit 12:31:01 

10 has its own ads obviously, and if Intuit has a 12:31:05 

11 different interpretation or believes that we're 12:31:09 

12 not presenting all of the information or the 12:31:11 

13 advertising that the administrative law judge 12:31:15 

14 should see, then obviously Intuit has the 12:31:19 

15 ability to do that. 12:31:21 

16 BY MR. GRINGER: 12:31:22 

17 Q. Right. But my question is: Don't 12:31:22 

18 you think it's misleading, regardless of 12:31:24 

19 whether we have the ads or not, to present only 12:31:26 

20 portions of certain advertisements? 12:31:30 

21 MR. ANGUIZOLA: Objection. Asked 12:31:32 

22 and answered. Misleads -- misstates the prior 12:31:33 

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1 testimony and is a misleading question and 12:31:38 

2 assumes facts not in evidence. 12:31:44 

3 THE WITNESS: As I said, I think the 12:31:46 

4 complaint, motion for summary decision, related 12:31:49 

5 briefing, the oral argument in this case, and 12:31:53 

6 the related presentation to the commission on 12:31:58 

7 the motion for summary decision accurately, 12:31:59 

8 fairly, and clearly set forth the terms of 12:32:02 

9 Intuit's claim to consumers. 12:32:06 

10 And if Intuit disagrees with any of 12:32:09 

11 the facts therein or believes that there is 12:32:13 

12 further evidence that might help provide more 12:32:15 

13 context, then, obviously, Intuit has the 12:32:18 

14 ability to bring that information forward to 12:32:20 

15 the trier of fact. 12:32:22 

16 BY MR. GRINGER: 12:32:23 

17 Q. We'll go back to that in one moment. 12:32:23 

18 But I just -- you're allowed to have 12:32:27 

19 the views you have. I just want to be clear. 12:32:28 

20 Your view is no problem presenting only 12:32:31 

21 snippets of advertisements, correct? 12:32:34 

22 MR. ANGUIZOLA: Objection. 12:32:37 

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202

Government Exhibit 

202 

Auctioneer Commercial (Kantar) Video 

(Electronic filename: 25438069_TVAd_FreeEdition 

166) 

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208

Government Exhibit 

208 

Workout Commercial (Kantar) Video 

(Electronic filename: 25364805_TVAd_No Title 

Assigned - #25364805) 

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DECLARATION OF DIANA F. SHILLER 

Pursuant to 28 U.S.C. § 1746 342

I, Diana F. Shiller, have personal knowledge of the facts and matters set forth 

below. If called as a witness, I could and would testify as follows: 

1. I am an Investigator with the Federal Trade Commission (“FTC”). 

2. At the FTC, I investigate unfair or deceptive acts or practices in violation 

of Section 5(a) of the FTC Act, and other laws or rules enforced by the FTC. As part of 

my work, I gather information and review documents, financial records, and other 

evidence in connection with FTC investigations. 

3. In the course of my employment, I participated in the FTC’s consumer 

protection investigation of Intuit Inc. (“Intuit”) and its advertising, marketing, 

distribution, and selling of TurboTax, a commonly used tax preparation software that 

enables users to prepare and file their income tax returns online. 

4. In connection with the FTC’s investigation, I reviewed public records and 

other publicly available information regarding Intuit. I also used an advertising 

monitoring service to review and monitor Intuit’s advertising of TurboTax. 

Additionally, I reviewed documents received in response to Civil Investigative 

Demands (“CIDs”) issued by the FTC to Intuit and third parties. 

5. During the course of the investigation, I visited Intuit’s TurboTax website, 

social media profiles, and YouTube channel on multiple occasions. 

6. Copies of all the exhibits referenced in this declaration are contained in the 

volumes comprising the FTC’s Exhibits. Those exhibits and the images in this 

Declaration have been redacted to protect personally identifiable information, including 

the undercover identities I used to log in to the TurboTax product. 

1 

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157. Depicted below is a copy of a screen displayed to consumers during 

commercials currently airing as part of the “Free, Free, Free, Free” campaign, which 

includes a similar fine print disclaimer: 

158. While the above screen is shown to consumers during commercials, an 

announcer says in the commercial: “That’s right, TurboTax Free Edition is free. See 

details at turbotax.com.” The announcer does not read the fine print disclaimer stating: 

“TurboTax Free Edition is for simple U.S. returns only. See if you qualify at 

turbotax.com.” 

F. Social Media TY 2021 Ads 

1. Facebook TY 2021 Ads 

159. On March 27, 2022, I visited Facebook’s Ad Library, 

(https://www.facebook.com/ads/library), searched for TurboTax ads, and saw a TurboTax 

ad active on that date that said, “America’s #1 Free Tax Prep Provider,” with a 10-

second video. The ad prominently displays the phrase “FREE $0 $0 $0.” Below are two 

partial captures of the ad. 

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160. On April 18, 2022, I visited Facebook’s Ad Library, searched for TurboTax 

ads, and saw that the TurboTax ad mentioned in paragraph 159, “America’s #1 Free Tax 

Prep Provider,” with a 10-second video was still active. 

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CERTIFICATE OF SERVICE 

I hereby certify that on February 10, 2023, I caused the foregoing document to be filed 

electronically using the FTC’s E-Filing system, which will send notification of such filing to: 

April Tabor 

Office of the Secretary 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Suite CC-5610 

Washington, DC 20580 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

I further certify that on February 10, 2023, I caused the foregoing document to be served 

via email to: 

Roberto Anguizola 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

Email: ranguizola@ftc.gov 

Tel: (202) 326-3284 

James Evans 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

Email: jevans1@ftc.gov 

Tel: (202) 326-2026 

Counsel Supporting the Complaint 

April Tabor 

Office of the Secretary 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Suite CC-5610 

Washington, DC 20580 

ElectronicFilings@ftc.gov 

Dated: February 10, 2023 

Rebecca Plett 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

Email: rplett@ftc.gov 

Tel: (202) 326-3664 

Sara Tonnesen 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

Email: stonnesen@ftc.gov 

Tel: (202) 326-2879 

The Honorable D. Michael Chappell 

Administrative Law Judge 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

Respectfully submitted, 

/s/ Derek Woodman 

DEREK WOODMAN 

Counsel for Intuit Inc