The California Dental Association (CDA) is a voluntary nonprofit association of local dental societies to which about three-fourths of the dentists belong. The CDA lobbies and litigates in its members' interests and conducts marketing and public relations campaigns for their benefit. The dentists who belong to the CDA through the local associations agree to abide by a Code of Ethics (Code) that prohibits false and misleading advertising. The local associations enforce the code by denying membership to new dentists who refuse to withdraw or revise objectionable advertisements and by subjecting current members who violate the Code to censure, suspension, or expulsion from the CDA.
The FTC brought a complaint against the CDA, alleging that it applied its guidelines so as to restrict truthful, non-deceptive advertising, and so violated Section 5 of the FTC Act. In particular, the FTC alleged that the CDA had unreasonably restricted price advertising, particularly about discounted fees, and advertising relating to the quality of dental services. Has the CDA violated the FTC Act? Why, or why not?