 Similarly, in an earlier report investigating accusations of price gouging by oil companies after Hurricane Katrina, Leibowitz wrote separately to note that a handful of refiners studied displayed "troubling" conduct.Leibowitz advocated for a re-invigorated enforcement of the FTC Act as a way to stop anticompetitive behavior that can no longer be reached under prevailing judicial interpretation of the antitrust laws.Leibowitz argued that in founding the FTC, "Congress intended to create an agency with authority that extended beyond the limits of the Sherman Antitrust Act."