Disclosure Requirements, Automatic Renewals, Enforcement Actions

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

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

Miller Canfield on 7/14/2025

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

New York and Colorado Update Auto-Renewing Subscription Requirements

Perkins Coie on 7/2/2025

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

FTC Delays Enforcement of Amended Negative Option Rule

Cooley LLP on 5/14/2025

On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

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

Kelley Drye & Warren LLP on 5/12/2025

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

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

Latham & Watkins LLP on 5/9/2025

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

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

Alston & Bird on 5/2/2025

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

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

Wilson Sonsini Goodrich & Rosati on 4/28/2025

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

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

Venable LLP on 4/25/2025

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

Disclosure Requirements › Automatic Renewals › Enforcement Actions