Disclosure Requirements, Appeals, Negative Option Rule

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

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

Wiley Rein LLP on 7/16/2025

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

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

Rule Interrupted: “Click-to-Cancel” is “Click-to-Gone”

Dickinson Wright on 7/11/2025

The Federal Trade Commission’s (FTC) negative option rule, better known as the “Click-to-Cancel” rule, which was set to go into effect July 14, 2025, has been vacated in its entirely by the Eighth Circuit in Custom...more

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

Miller Canfield on 6/18/2025

The Federal Trade Commission’s (“FTC”) Negative Option Rule, dubbed the “Click-to-Cancel” Rule (the “Rule”), stands to substantially change the way online businesses must interact with customers. Its fate is now in the hands...more