> This decision is the result of a biased and broken system where the Commission serves as accuser, judge, jury, and then appellate judge all in the same case

Interesting argument, but also a distraction from "we lied in advertising."

> It could also clearly disclose the percentage of customers that actually do qualify for the free service, somewhere close to the “free” claim advertised, the commission said.

They ran an ad during the 49ers game this weekend, centered around it being free for the character in the ad. I'm guessing that's how they'll work around this.