On January 17, Washington Attorney General Nick Brown announced that his office had reached a resolution in its nearly two-year lawsuit against Puppyland, a local pet store that sells and provides financing for (you guessed it) puppies, for claims of unfair and deceptive practices in sales and marketing in violation of the state Consumer Protection Act (CPA). The AG’s Office and Puppyland have entered into a consent decree under which the company will pay $3.75 million by the end of June 2026 and will be subject to new requirements in how it markets and sells puppies in Washington.

In April 2023, former AG Bob Ferguson sued Puppyland in King County Superior Court. The lawsuit came after several customers reported, as described in the complaint, financially and emotionally devastating health issues with puppies purchased from Puppyland and exorbitant monthly payments for loans entered into with the company on the puppies themselves. The complaint highlights the state’s alleged violations of the CPA in depth, including:

  • Refusing to disclose prices until customers came into stores and formed emotional bonds with the puppies;
  • Subsequently rushing customers through the purchasing process and encouraging them to agree to predatory financing at exorbitant interest rates labeled as puppy payments”;
  • Falsely marketing supplier’s breeding standards as the Best of the Best” and misleadingly promising customers You Are Always Covered” under the company’s health guarantees; and
  • Requiring non-disparagement provisions in sales contracts that void all health guarantees if a customer publishes a negative review on social media or business review websites.

Pursuant to the consent decree, Puppyland must implement a series of sales and marketing reforms plus pay out millions of dollars to the AG’s Office (in addition to following state laws enacted since the lawsuit, including one banning pet sale financing and requiring USDA licensed breeders/brokers). Among several other terms, the consent decree enjoins Puppyland from limiting a customer’s ability to publish honest online reviews, refusing to provide customers an opportunity to understand and negotiate price terms for puppy sales, and falsely advertising breeding standards held by the company’s puppy suppliers. Puppyland must post a copy of its written health guarantee on the company’s website and clearly state in stores the price of puppies and the availability of a puppy’s health and breeding information. We should note this enforcement action is certainly not the first of its kind against puppy sellers and financers (see some more recent examples).

Even if you don’t sell puppies, here are few things to consider so you don’t give regulators or law enforcement officials too much paws:

  • Disclose price terms for products online and in stores and afford customers a full opportunity to review and understand the terms of a sales contract or loan agreement. Rushing consumers through a transaction and distracting them from reviewing the full terms will definitely raise questions from enforcers.
  • Ensure marketing campaigns and advertisements avoid unsubstantiated, exaggerated, and misleading claims about product guarantees.
  • Non-disparagement agreements that limit a customer’s ability to express honest reviews of a business or its products likely have legal consequences under federal and state law, drawing the ire of Washington in a prior matter. While this suit didn’t specifically allege federal Consumer Review Fairness Act violations, it could have (as state AGs are empowered to enforce). Washington released such claims through its settlement.

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