Drizly, LLC operated a website through which consumers could place orders for the delivery of alcoholic beverages from local liquor stores. The stores delivered the liquor using their own employees or through third party delivery services. The Drizly platform encouraged customers to add a tip for the driver, but did not disclose there was no assurance the tip would actually reach the driver.  Rather, the tips were disbursed to the stores, which might or might not pass them on to the driver.  The New York Attorney General's Labor Bureau commenced an investigation and contended that the Drizly platform defrauded consumers into adding tips to their orders by misleading them into believing that the drivers would receive them.

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