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Click to Cancel: FTC Proposes New Rule Regulating Subscription Services and Negative Option Programs with Broad Implications

Last week, the Federal Trade Commission announced that its proposed rule replacing its Prenotification Negative Option Rule would result in new, expansive requirements for all forms of negative option offers, including...more

Ninth Circuit Rejects Dark Patterns Challenge to Arbitration Agreement

The Ninth Circuit has never been shy about declining to compel arbitration, and the Court has issued multiple cases outlining what constitutes sufficient notice of certain provisions in consumer-facing terms and conditions,...more

Ninth Circuit Rules That TCPA Aggregated Statutory Damages Might Be Unconstitutionally Punitive

​​​​​​​For those embroiled in Telephone Consumer Protection Act (TCPA) class action litigation, the sum of the damages may not necessarily equal the whole. In Wakefield v. ViSalus, Inc., the plaintiff and certified...more

The FTC Brings More Light to Dark Patterns in New Staff Report

​​​​​​​By a unanimous 5-0 vote, the Federal Trade Commission last week released a staff report that sheds light on the agency’s enforcement positions and priorities regarding digital “dark patterns,” which the FTC defines as...more

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