that is consistent with the structure and purposes of [the FTC Act].”). After all, the IAPA presupposes a number of significant differences between rule-makings and contested cases. For example, the IAPA specifically prohibits ex parte communications in contested cases. Iowa Code § 17A.17(1)(a). Yet, the rule is silent on ex parte contacts in informal rulemakings. See id. This suggests the legislature was not as concerned with ex parte contacts in informal rulemakings. This conclusion is consistent with the approach taken by federal courts when determining whether ex parte agency contacts during informal rulemakings violate the Federal Administrative Procedure Act. See Ass’n of Nat’l Advertisers, 627 F.2d at 1169 n. 39; see also Hercules, Inc. v. EPA, 598 F.2d 91, 124-25 (D.C.Cir.1978) (<HOLDING>); Home Box Office, 567 F.2d at 57 (“[W]e
holding that judicial review of final agency action under the administrative procedure act  provides the proper procedure to challenge the sufficiency of an eis holding that dismissal pursuant to federal rule of civil procedure 56 did not violate the seventh amendment holding that judicial review of decisions of military correction boards is review of the administrative record conducted under the administrative procedure act holding that when an agency fails to follow the proper procedure under the illinois administrative procedure act for the adoption of rules the rule is invalid holding intraagency contacts during an informal rulemaking do not violate the federal administrative procedure act