MEMORANDUM OPINION
RICHARD W. ROBERTS, District Judge.
Plaintiff POM Wonderful LLC ("POM"), the largest processor and distributor of pomegranate products in the United States, brings an action against the Federal Trade Commission ("FTC") under the Declaratory Judgment Act, 28 U.S.C. § 2201, seeking a declaratory judgment that the FTC's allegedly new rule governing disease claims in food advertising exceeds the FTC's statutory authority, violates...
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