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Corporate Counsel › Cancellation Rights › Subscription Services

BakerHostetler

Negative Option Rule No More: How To Comply in the Wake of the Eighth Circuit’s Decision

BakerHostetler on

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

Proskauer - Advertising Law

Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

Proskauer - Advertising Law on

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more

Lowenstein Sandler LLP

FTC "Click-To-Cancel" Rule Coming Soon

Lowenstein Sandler LLP on

The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more

Fisher Phillips

FTC’s New Click-to-Cancel Rule Means Your Business Needs to Simplify the Cancellation Process: 5 Steps to Stay Compliant

Fisher Phillips on

The federal government just fundamentally changed how businesses need to handle recurring subscriptions by unveiling its new “Click-to-Cancel” rule and making it mandatory to simplify cancellation processes. Designed to...more

Venable LLP

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

Venable LLP on

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

Venable LLP

Your 2024 Outlook: California’s Enforcement Trends and New State Laws Governing Automatic Renewal Programs

Venable LLP on

It’s that time of year again. Regardless of what you call them—subscriptions, negative option programs, automatic renewals, or continuous service offers—states are continuing to enact and enforce new laws with increasingly...more

Venable LLP

Click to Cancel: FTC Proposes New Rule Regulating Subscription Services and Negative Option Programs with Broad Implications

Venable LLP on

Last week, the Federal Trade Commission announced that its proposed rule replacing its Prenotification Negative Option Rule would result in new, expansive requirements for all forms of negative option offers, including...more

Sheppard Mullin Richter & Hampton LLP

CFPB: Negative Option Marketing Practices May Violate CFPA

Sheppard Mullin Richter & Hampton LLP on

On January 19, the CFPB issued Circular 2023-01 to affirm that companies offering “negative option” subscription services are required to comply with federal consumer financial protection laws. According to the Circular,...more

Hinch Newman LLP

eCommerce Attorney Tips Regarding Recent Automatic Renewal Law Developments

Hinch Newman LLP on

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

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