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FTC’s Click to Cancel Rule is Vacated, But Remember It Was Not Alone

What happened and why?  On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more

FTC Defers Some Click-to-Cancel Rule Enforcement to July 14, 2025

Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more

New Click-to-Cancel Requirements… Welcome/Not Welcome?

The Federal Trade Commission (FTC) announced its long-awaited final Negative Option Rule (the “Rule”) on October 16, 2024. “Negative Options” according to the FTC are arrangements “under which the consumer’s silence or...more

You’ve Got Mail (Not the Good Kind): FTC Sends Mass Warning Regarding Deceptive Endorsements

In brief: The FTC has sent hundreds of advertisers (including high profile retailers, manufacturers, agencies, and other large businesses) across assorted industries a Notice of Penalty Offenses. The Notice warns recipients...more

CAN-SPAM Rule Stands

The Federal Trade Commission (FTC) has elected to retain its CAN-SPAM Rule in its present form without changes. The CAN-SPAM Rule implements the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM)...more

ICO Warns Prominent US Company to Change Business Model: Paid Subscription versus FREE with Ads

A European privacy regulator has spoken on a key facet in its General Data Protection Regulation (GDPR) interpretation. The UK’s enforcement office apparently believes that an EU data subject cannot give consent to a...more

FTC Takes Hard Line on Social Media Endorsements: Disclose, Disclose, Disclose... (It Matters Given Growing Reliance on Social...

The Federal Trade Commission (FTC) has unequivocally signaled this month that compliant endorsements on social media remain a high priority for this US consumer protection agency because endorsements carry weight and affect...more

#Clear and #Conspicuous Paid Partnerships: Instagram Lends Helpful Technology Hand

It is often considered difficult for endorsers to make appropriate disclosures of their paid partnership with a brand within the confines of social media. Instagram has announced it will try to help make disclosures around...more

Hey, Alexa: What’s New in Children’s Privacy?... FTC Updates COPPA Guidance

Trying to keep pace with developments in internet-connected toys and other devices for children, the Federal Trade Commission (“FTC”) announced June 21, 2017 that it has updated its guidance, a “Six-Step Compliance Plan for...more

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