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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

Cross-Device Tracking: Time to Reevaluate Privacy Policies

U.S companies are expected to explain how consumers are being tracked across devices, so that the company knows a consumer accessing its website from smartphone, tablet, television, laptop or other devices. Until now, U.S....more

FTC Files to Protect Consumers’ Security in the Internet of Things

As more consumer devices connect to the Internet, regulators take a more aggressive stance requiring security promises be met. On January 5, 2017, the FTC filed a complaint against computer networking equipment...more

FTC Provides Nonbinding Materials to Help Businesses Defend Against and Respond to Data Breaches

On October 25, 2016, the Federal Trade Commission (FTC) released its nonbinding “Data Breach Response” guide with an accompanying blog post and video, all directed to help businesses prepare a data breach response plan. The...more

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