Considering whether trademark owners can enter into settlement agreements that restrict the parties’ search advertising without violating U.S. antitrust laws, in 1‑800 Contacts, Inc. v. FTC, the Second Circuit held the restrictions permissible. In doing so, the Second Circuit overturned the Federal Trade Commission’s conclusion that when 1-800 Contacts, Inc., settled multiple trademark infringement suits through agreements preventing its competitors from purchasing search advertising keywords containing 1-800 Contacts’ trademarks, it violated section 5 of the FTC Act, 15 U.S.C. § 45(a)(1).