Hopkins Dodge, Inc. and other automobile dealers (car dealers) (defendants) violated the Truth in Lending Act. The Federal Trade Commission (FTC) (plaintiff) filed a suit against the car dealers and obtained a permanent injunction against further violations. The FTC also sought a civil penalty under the Truth in Lending Act. As a basis for the civil penalty, the FTC provided four FTC decisions meant to show that the car dealers were on notice of the illegality of their conduct. Only one of the decisions related to an unfair or deceptive act, and that decision involved a “bait and switch” arrangement in the meat industry. The district court denied the FTC’s motion for a civil penalty. The district court held that the FTC’s furnished decisions failed to meet the statutory prerequisites for a civil penalty. The district court granted summary judgment in the car dealers’ favor, and the FTC appealed.