The goal is prevention rather than punishment, reflecting the difference between civil and criminal law. A typical remedy is ordering an advertiser to stop its illegal acts, or to include disclosure of additional information which eliminates potentially-deceptive material. Corrective advertising may be mandated, but no fines or prison time is imposed except for the rare instances where an advertiser refuses to stop despite an order to do so. In 1905, Samuel Hopkins Adams released a series of articles detailing misleading claims by the patent medicine industry. The public outcry resulting from the articles led to the creation of the Food and Drug Administration the following year. In 1941, the Supreme Court reviewed Federal Trade Commission v. Bunte Bros, Inc. under Section 5 of the Federal Trade Commission Act of 1914 with regard to "unfair or deceptive acts or practices". The court reviewed three false-advertising cases in 2013 and 2014: Static Control v. Lexmark (concerning who may sue under the Lanham Act), ONY, Inc. v. Cornerstone Therapeutics, Inc. and POM Wonderful LLC v. Coca-Cola Co. State governments have a number of unfair-competition laws which regulate false advertising, trademarks, and related issues. Many are similar to those of the FTC, and may be copied so closely that they are known as "little FTC acts." According to the National Consumer Law Center, the lawsknown as "unfair, deceptive, or abusive acts and practices laws" (UDAAP or UDAP laws)vary widely in the protection they offer consumers. In California, one such statute is the Unfair Competition Law (UCL). The UCL "borrows heavily from section 5 of the Federal Trade Commission Act", and has developed a body of case law. Civil penalties may range from thousands to millions of dollars, and advertisers are sometimes ordered to provide all customers who purchased the product with a partial (or full) refund. Corrective advertising, disclosures, and other informational remedies may also be ordered. Advertisers may have to warn buyers of false statements in advertisements, make clear disclosures in future advertisements, or provide customers with other information to correct misinformation in an original ad. United Kingdom Advertising in the UK is regulated under the Consumer Protection from Unfair Trading Regulations 2008 (CPR), the de facto successor of the Trade Descriptions Act 1968. It is designed to implement the Unfair Commercial Practices Directive, part of a common set of European minimum standards for consumer protection which legally bind advertisers in England, Scotland,