News & Analysis as of

Consumer Protection Laws › Automatic Renewals › FTC Act

WilmerHale

Eighth Circuit Vacates the FTC's Click to Cancel Rule, but Federal and State Regulators Likely to Remain Active

WilmerHale on

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

Lerman Senter PLLC

"Click to Cancel" Rule Vacated Ahead of July 14th Deadline

Lerman Senter PLLC on

Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more

Winstead PC

8th Circuit Vacates FTC’s “Click to Cancel Rule”

Winstead PC on

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...more

Kelley Drye & Warren LLP

Eighth Circuit Vacates FTC’s Negative Option Rule

Kelley Drye & Warren LLP on

On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more

Nelson Mullins Riley & Scarborough LLP

Autorenewal Requirements Are Finally Coming Into Focus – What You Need to Know

Nelson Mullins Riley & Scarborough LLP on

As July prepares to descend upon us, the swirl regarding the impending legal requirements for properly offering and administering autorenewing subscriptions has become downright maddening – which rules will apply? How can I...more

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

Paul Hastings LLP on

In the fall of 2024, California and the Federal Trade Commission (FTC) amended their respective auto-renewal regulations. The amendments detail new and largely parallel disclosure, consent, and cancellation requirements for...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Latham & Watkins LLP on

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

Venable LLP on

This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more

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