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Kelley Drye & Warren LLP

HelloFresh to Pay $7.5 Million to Settle Automatic Renewal Suit

Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more

Fisher Phillips

Proposed New Jersey Regulations Would Require Major Privacy Compliance Shifts for Businesses

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New Jersey officials recently released proposed privacy regulations that would create several new compliance obligations for businesses above and beyond what existing state law and many other state laws require, meaning you...more

Fisher Phillips

Court Strikes Down FTC’s Click-to-Cancel Rule – But Businesses Still Face Major Risk from State Auto-Renewal Laws

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A federal appeals court just vacated the FTC’s controversial Click-to-Cancel rule on procedural grounds – but businesses shouldn’t drop their guard just yet. Many states already have their own automatic renewal laws on the...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

Troutman Pepper Locke

Virginia’s Protection of Reproductive Health Information Law – Part Two, Compliance and Implementation

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In Part Two of this FAQ series, we continue to break down Virginia’s Senate Bill 754, Consumer Protection Act; prohibited practices, etc., reproductive or sexual health information (Act), which amends the Virginia Consumer...more

Kelley Drye & Warren LLP

Fragmentation of Privacy Requirements Accelerates as Four States Amend Nascent Laws

On June 25, 2025, Connecticut Governor Ned Lamont signed into law a major amendment to the state’s comprehensive privacy law (CTDPA), just over three years after signing the CTDPA into law on May 10, 2022 and two years after...more

Orrick, Herrington & Sutcliffe LLP

Navigating Federal and California Negative Option Rules: Key Insights for Businesses

As regulatory scrutiny around automatic renewals intensifies, understanding the Federal Trade Commission’s new “Click-to-Cancel” rule and California’s recently amended Automatic Renewal Law, is essential for companies looking...more

Venable LLP

July 1 and July 14 Autorenewal and Negative Option Compliance Deadlines: A Fast VAST Alert

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On July 1, California's amended autorenewal law takes effect, and the Federal Trade Commission's (FTC) updated enforcement deadline for the primary requirements of the updated Negative Option Rule (so-called Click to Cancel...more

Nelson Mullins Riley & Scarborough LLP

Autorenewal Requirements Are Finally Coming Into Focus – What You Need to Know

As July prepares to descend upon us, the swirl regarding the impending legal requirements for properly offering and administering autorenewing subscriptions has become downright maddening – which rules will apply? How can I...more

Miller Canfield

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

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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

Klein Moynihan Turco LLP

AI Privacy

With the use of artificial intelligence (“AI”) becoming more pervasive every day, it should not surprise our readers that regulators are increasingly focused on the use of AI and its associated consumer data privacy...more

Perkins Coie

The Start of Something New? New Jersey’s Proposed Privacy Rules

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On June 2, 2025, the New Jersey Office of Consumer Protection announced proposed rules for New Jersey’s comprehensive consumer privacy law, the New Jersey Data Privacy Act (NJDPA), which went into effect on January 16, 2025....more

Davis Wright Tremaine LLP

New Jersey Releases Proposed Regulations Expanding on Obligations Under Privacy Law

On June 2, 2025, Governor Murphy announced proposed regulations (the "Regulations") implementing and expanding on the requirements of the New Jersey Data Privacy Act (the "Act")...more

Perkins Coie

Don’t Mind If I Do: Montana Says Hands Off Neural Data

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In May 2025, Montana enacted Senate Bill 163 (SB 163), amending that state’s Genetic Information Privacy Act (MGIPA) to include protections for neurotechnology data—namely, data collected from the activity of the central or...more

Bass, Berry & Sims PLC

Virginia Strengthens Privacy Protections for Reproductive and Sexual Health Information

On March 24, Virginia Governor Glenn Youngkin signed into law SB 754 (Act), which amends the Virginia Consumer Protection Act (VCPA) to prohibit entities from collecting, disclosing, selling, or disseminating reproductive or...more

Sheppard Mullin Richter & Hampton LLP

California’s “Auto Renewal Law” Takes Effect on July 1

Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more

Arnall Golden Gregory LLP

State Wave of Click-to-Cancel Rules

The end of President Biden’s administration saw the Federal Trade Commission (“FTC”) adopt the sweeping “Click-to-Cancel” rule, which stands to impose a spate of requirements for disclosure, consent, and cancellation on any...more

McDermott Will & Schulte

New Jersey Proposes Rules for the New Jersey Data Privacy Act

New Jersey’s Office of Consumer Protection has prepared proposed rules for the New Jersey Data Privacy Act (NJDPA) (Proposed Rules). While the bulk of the Proposed Rules consist of recitations of the obligations found in the...more

Davis Wright Tremaine LLP

New Requirements on the Collection and Use of Biometrics in Colorado Become Effective Soon

Last May, Colorado Governor Jared Polis signed into law amendments to the Colorado Privacy Act ("CPA") that impose new obligations governing the collection, processing, retention, and disclosure of Coloradans' biometrics. The...more

Amundsen Davis LLC

What a Tracking Technology Class Action Lawsuit Can Teach Financial Institutions

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Financial institutions that use code-based tracking technologies may soon find themselves facing increased scrutiny and legal exposure as the next wave of class action litigation begins. On December 19, 2024, a member of...more

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

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In the fall of 2024, California and the Federal Trade Commission (FTC) amended their respective auto-renewal regulations. The amendments detail new and largely parallel disclosure, consent, and cancellation requirements for...more

Benesch

Ubisoft Win Offers Defense Blueprint for VPPA Consent Challenges

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A recent decision from the Northern District of California may signal an important shift in the trend of how courts interpret “consent” under the Video Privacy Protection Act (VPPA). In Lakes v. Ubisoft, Inc., No....more

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

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Notwithstanding significant changes at the Federal Trade Commission (FTC) – including the removal of two of the five Commissioners, and the new appointment of Commissioner Mark Meador – the Commission has sent a clear message...more

BakerHostetler

COPPA Is Back in the Saddle: FTC Publishes Final Rule for Children’s Privacy

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Just as we’re getting ready to pick out our cowboy boots and bolo ties for Beyoncé’s Cowboy Carter Tour, the Federal Trade Commission (FTC or Commission) published its long-awaited finalized amendments (Final Rule) to the...more

Robinson+Cole Data Privacy + Security Insider

The VPPA: An Old Law with New Streams

Enacted in 1988, the Video Privacy Protection Act (VPPA) was intended to regulate the then-booming videotape industry by limiting how video rental and sales data is disclosed. The law was enacted in direct response to the...more

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