Disclosure Requirements, Appeals, Cancellation Rights

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

Mayer Brown on 7/21/2025

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

Eighth Circuit Cancels FTC’s “Click-to-Cancel” Rule

Benesch on 7/15/2025

On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more

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

Arnall Golden Gregory LLP on 7/14/2025

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

FTC’s “Click-to-Cancel” Rule Struck Down by Eighth Circuit

Ropes & Gray LLP on 7/14/2025

On Tuesday July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) “Negative Option” Rule, also called the “Click-to-Cancel” Rule, which expanded regulations on...more

FTC’s Click-to-Cancel Rule Vacated by Appeals Court

Alston & Bird on 7/11/2025

Due to go into effect on July 14, the Negative Option Rule has been struck down by the Eighth Circuit. Our Consumer Protection/FTC Group examines the Federal Trade Commission’s options going forward....more

FTC "Click-To-Cancel" Rule Coming Soon

Lowenstein Sandler LLP on 3/31/2025

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