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Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click-to-Cancel Rule, resolving the challenges to the rule filed on the heels of its adoption in...more

State Wave of Click-to-Cancel Rules

The end of President Biden’s administration saw the Federal Trade Commission (“FTC”) adopt the sweeping “Click-to-Cancel” rule, which stands to impose a spate of requirements for disclosure, consent, and cancellation on any...more

Eighth Circuit Refuses to Stay Click-to-Cancel Rule

On January 17, 2025, the United States Court of Appeals for the Eighth Circuit denied a petition to administratively stay the effective date of the Federal Trade Commission’s controversial “Click-to-Cancel” Rule. A divided...more

Minnesota Jumps on the Pricing Transparency Bandwagon

Minnesota is the latest state to join the roster of those that have recently adopted pricing transparency laws. As background, on February 11, 2024, New York amended General Business Law 518 to provide that consumers could...more

FTC Bans Non-Compete Agreements

On April 23, 2024, the Federal Trade Commission (“FTC”) issued a final rule effectively banning non-compete agreements in the employment context. This final rule follows a proposed rule published by the FTC on January 5,...more

The FTC Proposes a New Rule on “Junk Fees”

On October 11, 2023, the Federal Trade Commission (“FTC”) published its Notice of Proposed Rulemaking for a new “Rule on Unfair and Deceptive Fees” — popularly referred to as the “junk fee” rule. The new rule, which will be...more

The FTC Blacklists Dark Patterns

It’s happened to all of us. You’re browsing online and a pop-up appears, blocking the entire screen and urging you to enter your email in exchange for 10% off. You look for the “X” to close the window, but there isn’t one....more

Government Investigations Team Insights - December 2021

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics.  In this edition, we discuss recent criticism of the Justice Department’s use of “taint teams” to review...more

The FTC and CFPB Target Big Tech, While the Chamber of Commerce Pushes Back

The first full year of the Biden Administration has seen an overhaul of the leadership of executive agencies, coupled with an intense focus on how big business affects the United States economy. ...more

The Tail Must Stop Wagging the Dog: Unanimous Supreme Court Reins in FTC Section 13b Authority

As we previously wrote, one of the biggest FTC decisions in decades was recently argued before the United States Supreme Court. And on Thursday, April 22, 2021, the Supreme Court unanimously ruled against the Federal Trade...more

Break It Up: FTC Files Antitrust Action Against Big Pharma Companies

On January 25, 2021, just weeks after Congress directed the Federal Trade Commission (FTC) to scrutinize the healthcare industry for anti-competitive activity, the FTC filed a meticulously detailed complaint against Endo...more

Supreme Court Hears Oral Argument over FTC’s Section 13(b) Authority

On January 13, 2021, the United States Supreme Court heard an oral argument in a pivotal challenge to the Federal Trade Commission’s (FTC) historic practice of obtaining monetary damages under a statutory provision that, on...more

New Frontiers for the FTC in Healthcare Following the Consolidated Appropriations Act

On December 27, 2020, the Consolidated Appropriations Act (CAA) became law, garnering attention nationwide for the economic stimulus components necessitated by the ongoing pandemic. Less publicized, however, were the...more

Legal Issues Business Leaders Need to Know in 2017

Expanding wage and hour obligations will continue to be a top concern for employers in 2017. As most employers are aware, in May 2016, the United States Department of Labor issued its long-awaited final rule regarding the...more

Reserve Funds and Restitution: Government Litigation in the Payments Space

Beginning in earnest in 2013, the Federal Trade Commission (“FTC”) began to exert pressure on the payments industry—including payment card processors and independent sales organizations (“ISOs”)—to stamp out businesses...more

AGG Litigation Insights Newsletter - Summer 2016

Even for companies accustomed to civil lawsuits, when the government is on the other side of the “v,” the prospect of litigation can be intimidating and unfamiliar. In this issue of the Litigation Newsletter, we explore how...more

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