In their strongest form, UDAPs allow consumers to bring claims
many state UDAPs, California's Unfair Competition Law (UCL)
By and large, the utility of other states' UDAPs is even more
state UDAPs, it is insufficient to allege that a company violated a law.
constitute per se violations of their UDAPs, additional rules can limit
private right of action itself, thereby making the UDAP at least
347, 356-57 (1992) (discussing the rise of the FTC in the 1960s and enactment of state UDAPS).
1991); Franke & Ballam, supra note 131, at 358-60 & nn.71-77 (categorizing general models of state UDAPS).
(135.) State UDAPS, while powerful tools for regulating deception, are not the sole state law mechanism for policing deception.
1999) (finding claim that seeks injunctive relief under state UDAP statute to be inarbitrable).