by late 2009, the federal trade commission (ftc) initiated an investigation to scrutinise willms’ businesses. the impetus for the investigation was the fact that willms’ companies had, at the time, triggered more complaints from consumers than almost all internet businesses. according to the ftc investigation, the majority of willms’ profit came from negative option billing, "a practice in which the seller interprets consumers' silence or inaction as permission to charge them". in effect, this meant that consumers signing up for "free trials" of a product were charged with extra fees hidden in the fine print of the terms and conditions. often consumers first became aware of this after their credit cards had been charged. also, several different company names appeared on their statements of account, each with a charge of an uneven dollar amount. the ftc claimed that these charges made up the majority of willms' profits because consumers believed they were legitimate.