Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
Podcast - The FTC's Click to Cancel Proposal
The Federal Trade Commission (FTC) has filed a complaint in the Central District of California against Fitness International, LLC and Fitness & Sports Clubs, LLC (together, LA Fitness), alleging unfair and deceptive practices...more
The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more
On August 12, the Federal Trade Commission (FTC) ordered Match Group, owners and operators of online dating platforms such as Match.com, OkCupid, PlentyOfFish, The League, and others, to pay $14 million. This settlement...more
On August 20, 2025, the FTC filed a complaint in the U.S. District Court for the Central District of California, alleging that the Gym violated the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA). The FTC's...more
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....more
As promised in last week’s blog that covered the Eighth Circuit’s decision to vacate the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule), we are back with some practical insights on and...more
Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more
The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more
On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more
This week, the Federal Trade Commission (FTC) and the Illinois attorney general announced a settlement with Grubhub Inc. to resolve allegations that the company engaged in an array of unfair and deceptive practices that...more
The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more
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
For companies who offer recurring subscriptions, it is important for them to understand the Federal Trade Commission’s recently finalized rule applicable to negative option marketing that requires such companies to make the...more
On October 16, 2024, the Federal Trade Commission (FTC or Commission) announced its adoption of a final “click-to-cancel” Rule that regulates both sign-up and cancellation processes for subscriptions or other recurring...more
Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more
A federal judge in Seattle has ruled against Amazon in its bid to have a Federal Trade Commission (FTC) lawsuit dismissed that alleges the online retailer used deceptive “dark patterns” practices to enroll customers in Prime...more
The Federal Trade Commission (FTC) has made clear its focus on automatic renewal programs with high-profile lawsuits in recent weeks, alleging violations of the Restore Online Shoppers' Confidence Act (ROSCA). Below are some...more
The California legislature recently renewed its efforts to regulate automatic renewal programs with proposed amendments to its Automatic Renewal Law (ARL). This development does not follow any lack of attention to this area...more
On December 20, 2023, New York Attorney General Letitia James filed a Petition in state court alleging Sirius XM Radio’s autorenewal practices violated New York’s autorenewal law. In the lawsuit, New York alleges that Sirius...more
The recent suit filed by the Federal Trade Commission (FTC) represents the latest guidance in the rapidly evolving patchwork of federal and state laws that govern online subscription models. Any company offering subscription...more
On March 23, the Federal Trade Commission announced proposed changes to its Negative Option Rule. This latest announcement appears to be another move by the Commission in its recent flurry of activities to ramp up its...more
On March 23, 2023, the Federal Trade Commission (“FTC” or “Commission”) issued a Notice of Proposed Rule Making (“NPRM”) seeking comment on proposed amendments to the Commission’s Negative Option Rule. The proposed...more
Mornings for advertising lawyers usually start slow – coffee in one hand and phone in the other while we glance at emails. Imagine our surprise the other morning when we saw that the Federal Trade Commission (FTC) had issued...more
The Federal Trade Commission recently announced that it has stopped internet phone service provider Vonage from allegedly imposing junk fees and creating obstacles to those that try to cancel their service. According to the...more
For years, the Federal Trade Commission has aggressively enforced the Restore Online Shoppers’ Confidence Act against digital marketers that offer Internet-based automatic renewals and subscriptions. In short, ROSCA requires...more