These impacts have not gone unnoticed by American companies and policy makers at the state and federal levels. At the federal level, unfair competition is generally addressed through the Federal Trade Commission Act (FTC Act) that allows federal officials to bring suit for "[u]nfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce."3 However, the FTC Act has a significant limitation: It does not provide for a private right of action. This means states and private companies must wait for federal officials to take action against foreign competitors--something the FTC has been reluctant to do despite the dollar value impacts to American business. In an attempt to prompt action, attorneys general from 36 states and three territories signed a letter to the FTC and head of the Unfair Competition Bureau in November 2011, asking the FTC to help address the issue and announcing their collective commitment to use their powers at the state level to increase enforcement against manufacturers that use stolen IT