News & Analysis as of

Consumer Protection Laws › Enforcement Actions › Automatic Renewals

Hudson Cook, LLP

FTC Sues Large Gym Chain over Cancellation Policies

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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

Hudson Cook, LLP

Online Dating Service Agrees to Pay $14 Million to Resolve FTC Lawsuit

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On August 12, 2025, the Federal Trade Commission announced that a large online dating company (the "Company") agreed to stop alleged unlawful practices related to advertising, cancellation, and billing. ...more

Mayer Brown

Click-to-Cancelled! Eighth Circuit Vacates Federal Trade Commission’s Revised Negative Option Rule

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INTRODUCTION - On July 8, 2025, the Eighth Circuit issued its decision in Custom Communications, Inc. v. Federal Trade Commission, vacating on procedural grounds the FTC’s planned “Click-to-Cancel” rule (the “Rule”), which...more

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

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The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Miller Canfield

Eighth Circuit Slams the Brakes on FTC’s Click-to-Cancel Rule

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In a dramatic turn of events, the United States Court of Appeals for the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) Click-to-Cancel Rule, which was set to take effect on July 14, 2025. ...more

Perkins Coie

New York and Colorado Update Auto-Renewing Subscription Requirements

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Recent enforcement actions underscore the growing risks for businesses with automatically renewing subscriptions. In June 2025, New York Attorney General Letitia James announced a $600,000 settlement with fitness company...more

DLA Piper

FTC Pauses “Click-to-Cancel” Rule Until July 14

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The Federal Trade Commission (FTC) announced on May 9, 2025 that it will delay full implementation of the amended Negative Option Rule and begin enforcing it on July 14, 2025....more

Kelley Drye & Warren LLP

FTC Extends Compliance Deadline for Negative Option or ​“Click to Cancel” Rule, but Indicates Intent to Enforce as Written in July

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Late Friday, the FTC announced that the Commission had voted 3-0 to extend the compliance deadline for the to-be-effective provisions of the Negative Option Rule, formerly known as the ​“Click to Cancel Rule.” While the...more

Latham & Watkins LLP

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

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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

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

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Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Venable LLP

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

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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

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

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The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Ballard Spahr LLP

A Closer Look at Automatic Renewal Laws

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Over the past several years, state legislatures have become more aggressive in passing laws to protect consumers’ digital rights. The promulgation of state data security and privacy laws, such as the California Consumer...more

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