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Jehan Patterson

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.

Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.

Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices.

In August, the Federal Trade Commission (“FTC”) announced a $14 million settlement with Match Group, Inc. and Match Group, LLC (collectively, “Match”), the parent companies of online dating platforms Match.com, OkCupid, PlentyOfFish, and other dating sites. In addition to monetary relief, the settlement includes significant injunctive provisions aimed at addressing alleged deceptive marketing and unfair billing practices. This resolution marks a significant development in the FTC’s ongoing efforts to monitor and regulate subscription-based services in the digital space.

Continue Reading FTC Secures $14 Million Settlement with Match Group Over Deceptive Subscription Practices

On August 7, 2025, the Federal Trade Commission (“FTC”) announced a $45 million settlement with online lead generator MediaAlpha, Inc. and its subsidiary QuoteLab, LLC (collectively, “MediaAlpha”), resolving allegations that the companies misled consumers seeking health insurance products. According to the FTC, MediaAlpha tricked consumers into sharing sensitive personal information under the guise of offering health insurance options through their lead generation sites. MediaAlpha allegedly then used that data for abusive telemarketing, including calling numbers on the National Do Not Call Registry. The FTC also alleged that MediaAlpha auctioned off consumers’ information to third-party lead generators and telemarketers, who similarly used that data to make illegal telemarketing calls.

Continue Reading FTC Takes Aim at Online Lead Generator

With the Trump administration’s renewed focus on American manufacturing, FTC Chairman Andrew N. Ferguson’s recent declaration that July 2025 is “Made in the USA” Month appears to signal a renewed emphasis on Made in USA enforcement.  The FTC has a long history of scrutinizing these claims and the more recently-issued Made in USA Rule sets strict compliance standards with the threat of significant monetary penalties for non-compliance.  And while Chairman Ferguson’s statement nods to the importance of preventing deception in this area, it emphasizes that advertisers should be making Made in USA claims whenever they are appropriate.

Continue Reading FTC Declares July as “Made in the USA” Month

On July 8, 2025, the Eighth Circuit issued a per curiam decision that vacated the FTC’s revised Negative Option Rule in its entirety.  The opinion will become effective when the court issues its mandate, which should happen within seven weeks unless the FTC seeks further review.

Continue Reading Eighth Circuit Vacates FTC Negative Option Rule

On October 16, the Federal Trade Commission (“FTC”) announced a final “click-to-cancel” rule that amends the previous Negative Option Rule to “make it as easy for consumers to cancel their enrollment as it was to sign up.” The Rule also imposes extensive requirements regarding misrepresentations, disclosures, and consent, among others. Most of the provisions will go into effect 180 days after publication in the Federal Register. As of today, the final rule has not yet been published. This final rule is the culmination of a five-year proceeding including the FTC’s issuance of a notice of proposed rulemaking (“NPRM”) in March 2023 and an advanced notice of proposed rulemaking in October 2019. We previously analyzed the proposed rule presented in the NPRM.

Continue Reading FTC Issues Final “Click-to-Cancel” Rule