us, moreover, the agency publication is alleged not only to be defamatory but also to be a knowing misrepresentation. Despite its obvious relevance, we nonetheless have reason to question the continued validity of the Hearst Radio decision, particularly in a case such as this one in which there is a specific statutory authorization for dissemination of information. The Hearst Radio doctrine has not been reconsidered carefully since 1948. During the thirty-five years since the issuance of the decision in Hearst Radio, the Supreme Court and lower courts have developed a more expansive interpretation of the term “agency action” than the one suggested by Hearst Radio. See, e.g., FTC v. Standard Oil Co. of California, 449 U.S. 232, 238 n. 7, 101 S.Ct. 488, 492 n. 7, 66 L.Ed.2d 416 (1980) (<HOLDING>) (quoting broad language of APA legislative
holding fda seizure action did not constitute final agency action holding that ftc issuance of a complaint meets the apa definition of order and therefore is agency action even if not final agency action holding that the designation of the rod as final agency action under the apa is generally recognized holding issuance of administrative complaint to initiate proceedings not final agency action holding that apa  702s waiver of sovereign immunity applies regardless of whether the challenged agency action constitutes final agency action 