On Feb. 21, the Pennsylvania Supreme Court issued a 4-3 decision in Gregg v. Amerprise Financial, ___ A.3d ___ (Pa. Feb. 17, 2021), holding for the first time that a business' state of mind is irrelevant for a consumer to sustain a private cause of action under the "catch-all" provision of the Unfair Trade Practices and Consumer Protection Law, 73 P.S. Sections 201-1 to 201-9.3 (the UTPCPL or Consumer Protection Law). Now, any deceptive conduct that creates a likelihood of confusion or misunderstanding for a consumer is actionable under the provision, regardless of whether such conduct is committed intentionally (as in a fraudulent misrepresentation), carelessly (as in a negligent misrepresentation), or with the utmost care (as in strict liability).