FTC cease-and-desist order too vague to be enforced, since an identical order from a court would be unenforceable on its terms, and the order therefore does not abate a specific act or practice that violates the statute.
http://media.ca11.uscourts.gov/opinions/pub/files/201616270.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.