"We also respectfully suggest that a hearing might assist the Court in deciding whether to enter the proposed consent decree," the motion adds.

The proposed settlement imposes a US$22.5 million fine on Google, which is the largest civil penalty ever secured by the FTC for a violation of one of its orders, although it is a tiny fraction of Google's almost $38 billion in 2011 revenue.

However, despite the historic fine, the proposed settlement also states that Google "denies any violation of the FTC Order, any and all liability for the claims set forth in the Complaint, and all material allegations of the Complaint save for those regarding jurisdiction and venue.

In its , the FTC alleged that Google falsely told Safari users that it wouldn't place tracking cookies on their devices or serve them targeted ads.

The FTC said that with this misrepresentation, Google violated an existing privacy settlement it had reached with the agency related to alleged privacy breaches in the Google Buzz social network.