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Eighth Circuit Vacates FTC Click-to-Cancel Rule Days Before Compliance Deadline

Although the entire Rule has been vacated, businesses offering negative option programs should remain aware of general unfair and deceptive advertising principles and applicable state law requirements. KEY POINTS: On July...more

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Financial Firms Beware: Dangers Lurk in the Cloud

US regulators are calling attention to financial firms’ obligations to protect against evolving cybersecurity threats. On October 2, 2019, the Financial Industry Regulatory Authority (FINRA) issued an information notice to...more

FTC Administrative Law Judge Issues Initial Decision in LabMD Matter

In a stunning victory, an administrative law judge has recommended the dismissal of a long-pending US Federal Trade Commission (FTC) complaint against LabMD, Inc. (LabMD). In a strongly worded opinion in a case that had...more

Eight Key Takeaways from FTC's Settlement with Snapchat

Yesterday, the Federal Trade Commission announced a settlement with Snapchat, the young mobile messaging company. The complaint alleges misrepresentations about functionality and related security as well as privacy...more

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