Disclosure Requirements, Negative Option Rule, Rulemaking Process

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

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

Eighth Circuit Vacates FTC’s Negative Option Rule

Kelley Drye & Warren LLP on 7/9/2025

On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

Venable LLP on 3/21/2025

Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more

FTC Finalizes Click to Cancel and Negative Option Rule

Dorsey & Whitney LLP on 1/13/2025

On October 16, 2024, the Federal Trade Commission (FTC) announced a revision to its negative option rule. The rule, formally entitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs,” is a...more

Disclosure Requirements › Negative Option Rule › Rulemaking Process