Whether Section 13(b)'s second proviso providing that the FTC 'may seek' a permanent injunction is an independent grant of authority to 'file suit' seeking implied consumer redress remedies circumventing the elaborate enforcement scheme set by Congress?

QUESTION PRESENTED Section 13(b) of the FTCA expressly authorizes the commission to “file suit” to enjoin allegedly false, misleading or deceptive trade practices with a temporary restraining order, preliminary injunction “pending the issuance of an administrative complaint” when an individual or corporation is “violating, or about to violate” the FTCA. If an administrative complaint is not filed within twenty days of issuance of temporary or preliminary injunctive relief, the injunction must be dissolved. Section 19 provides an elaborate enforcement scheme that authorizes the FTC to file direct enforcement actions in the district court for relief including but not limited to consumer redress, refunds, restitution and an unqualified grant of full equitable “relief as the court deems necessary.” The question presented is: Whether Section 13(b)’s second proviso providing that the FTC “may seek” a permanent injunction is an independent grant of authority to “file suit” seeking implied consumer redress remedies circumventing the elaborate enforcement scheme set by Congress?