(FTC), replacing Mozelle W. Thompson. Leibowitz was sworn in to the position on September 3, 2004, and on March 2, 2009 was chosen to serve as FTC Chair by President Barack Obama. In 2012, U.S. Senate confirmed Leibowitz's appointment for a second term. Leibowitz resigned as both chair and as a member of the FTC on February 15, 2013. Consumer protection During Leibowitz's tenure as chair, the FTC filed more than 40 law enforcement actions to stop scams that prey on consumers suffering from the economic downturn, such as foreclosure "rescue" and mortgage modification schemes, phony debt-reduction and credit-repair services, bogus government grant opportunities, job scams, and get-rich quick frauds. In one of the largest judgments imposed in an FTC case—and one of the few major judgments against companies responsible for the Great Recession—Countrywide settled for $108 million with the FTC in June 2010 for collecting excessive fees from borrowers who were struggling to keep their homes. In 2011, the FTC mailed 450,177 refund checks to homeowners who were allegedly overcharged by Countrywide. Healthcare Leibowitz was active in preserving competition in the health care and pharmaceutical sectors. He criticized of "pay-for-delay" settlements in the pharmaceutical industry. The Commission aggressively worked at stopping pay-for-delay patent settlements in the pharmaceutical industry. These are deals in which a brand-name drug firm pays its potential generic drug rival to prevent price competition in the market. As Leibowitz explained, the practice results not only in windfalls for both companies—sometimes of more than a billion dollars—but also in higher drug prices for consumers. Leibowitz has published articles on this issue and advocates bringing cases against firms that engage in these practices. An FTC study released in October 2011 revealed that some pharmaceutical companies continued to engage in pay-for-delay deals in FY 2011. The findings prompted Leibowitz to ask Congress' "Super Committee" to restrict these deals, stating that it could help reduce the deficit and lower the nation's healthcare costs. Internet, telecommunications and technology During Leibowitz's tenure, the agency focused on promoting consumer protection, competition and innovation in technology sectors, through both policy initiatives and law enforcement. As FTC Chair, Leibowitz brought a number of high-profile privacy cases against Google, Facebook and other high profile technology companies for violating consumer privacy as well as major antitrust cases against multiple pharmaceutical companies for engaging in sweetheart "pay-for-delay" deals in which brand pharma companies paid generic competitors to stay