RJLF Turns Back FTC’s Effort to Shut Down Doxo and Bar Its Founders

Reichman Jorgensen Lehman & Feldberg LLP (RJLF) has resolved the Federal Trade Commission’s two-year enforcement action against bill payment platform Doxo, Inc. and its co-founders. The Commission sought approximately $130 million, sought to shut the company down, and sought monetary liability and industry bans against both founders. It settled for $2.1 million, about 1.6% of what it demanded. Doxo’s business continues without monetary liability or industry bans for the individuals.

The FTC filed suit in April 2024, alleging violations of the FTC Act, the Gramm-Leach-Bliley Act, and the Restore Online Shoppers’ Confidence Act. The case was hard fought for two years.

In May 2026, the court denied the Commission summary judgment on its core deception claims under Section 5 of the FTC Act and deferred ruling on the Gramm-Leach-Bliley claim, including whether that statute permits monetary relief at all. It sent both founders’ personal liability to trial. The only liability established was on a discrete set of subscription disclosure practices that Doxo had already corrected voluntarily, with damages reserved.

RJLF Partner David King led the defense. He argued the Commission could not recover under the Gramm-Leach-Bliley Act what the Supreme Court had barred it from recovering under Section 13(b) of the FTC Act, and that Doxo was entitled to a jury, which no defendant had ever obtained in an FTC case. The court set a hearing on the monetary and jury questions, but the case settled before either question was answered.  The scope of the FTC’s ability to obtain monetary relief and defendants’ entitlement to a jury trial remain unsettled. 

“We are happy for Doxo. The FTC plays a vital role in protecting consumers from fraud and abuse. That is not what this case was about,” said King.

The FTC dismissed its remaining claims as part of the settlement. Defendants neither admitted nor denied the allegations. The stipulated order was filed with the court on August 17, 2026, and is subject to entry. It imposes no changes to the services its consumers expect.

The Commission has expanded consumer protection enforcement across the payments and subscription economy. RJLF is among a small group of firms that has taken one of these cases through summary judgment and to the door of a jury trial.

The RJLF team included David King, Courtland Reichman, Jeremiah Collins, Taylor Mauze, Letitia Chai, Estizer Smith, Sara Edelstein, and Laura Carwile. The case is Federal Trade Commission v. Doxo, Inc., et al., No. 2:24-cv-00569-TSZ (W.D. Wash.).

About Reichman Jorgensen Lehman & Feldberg LLP

Reichman Jorgensen Lehman & Feldberg LLP (RJLF) is a national trial firm that handles high-stakes commercial, intellectual property, and white collar disputes. The firm is reinventing the practice of law without the billable hour in favor of fee arrangements that align client interests. RJLF’s attorneys are diverse, exceptionally credentialed, and passionate about trial advocacy. From offices in Silicon Valley, New York, Washington, D.C., Austin, and Atlanta, the firm tries cases and argues appeals throughout the country. Visit reichmanjorgensen.com to learn more.

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