SUMMARY: Consumer Reports, Public Knowledge, and Upturn refute Facebook’s claim that because its users don’t pay Facebook directly for access to its social network, they don’t have a merchant-consumer relationship, and Facebook and its trade practices are thus not subject to the District of Columbia’s Consumer Protection Procedures Act, or CPPA. The consumer groups note that a contrary, incorrect ruling could cause ripple effects in DC and elsewhere, encouraging other companies that offer “free” goods and services online to assert immunity from consumer protection law.