ng Improprieties at DBZ 8 F. DBZ's Discovery of Accounting Improprieties and Response 8 G. DBZ's Disclosures to FTC in Fall 2006 11 H. FTC's Liquidation Demand 12 I. FTC's February 2007 and February 2008 Notices of Withdrawal 15 J. The 2009 Agreement 18 Argument 18 I. The Zwirn Respondents Cannot