As a result of an action brought by the FTC, the U.S. Court of Appeals for the Second Circuit recently found LeadClick Media, LLC liable for false claims made by third party affiliate marketers, which drove traffic to LeanSpa, a maker of weight-loss supplements. As a result, LeadClick was ordered to pay $11.9 million for its part in helping to promote a deceptively marketed weight-loss supplement. This decision marks the first by a court of appeals, which holds the operator of an affiliate marketing network liable for the deception of third-party marketers.