News & Analysis as of

Federal Trade Commission (FTC) Compliance

Redgrave LLP

Maintaining Information Preservation and Management Vigilance in an Age of Apparent Reduced Law Enforcement

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Corporate legal departments are busy. They face new privacy regulations, ever-shifting trade policies, developments in artificial intelligence, and an unending stream of breaking news. It is difficult to keep up, and lately,...more

DLA Piper

Accentuate the Positive, Don’t Eliminate the Negative: What a New FTC Case Says About Managing Your Customer Reviews

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The Federal Trade Commission (FTC) recently announced a new action and proposed settlement with the telemedicine firm NextMed. The action, which may seem familiar to those who followed FTC advertising cases of years past,...more

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

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On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more

Mintz

Click to Cancel: What the FTC’s Setback Means for Subscription-Based Businesses

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I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 15, 2025)

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FTC Sends Warning Letters Regarding Potential Noncompliance With “Made in USA” Requirements. On July 8, the FTC sent letters to a flagpole retailer, footwear maker, football equipment company, and personal care products...more

Latham & Watkins LLP

Eighth Circuit Vacates FTC Click-to-Cancel Rule Days Before Compliance Deadline

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Although the entire Rule has been vacated, businesses offering negative option programs should remain aware of general unfair and deceptive advertising principles and applicable state law requirements. KEY POINTS: On July...more

Alston & Bird

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

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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

Nelson Mullins Riley & Scarborough LLP

Do NOT Cancel Your Click-to-Cancel Compliance Efforts!

As has been widely reported, the Eighth Circuit issued a decision this week vacating the Federal Trade Commission’s Click-to-Cancel Rule, which had been scheduled to spring into effect on July 14. In the grand scheme of...more

Dickinson Wright

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

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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

Lerman Senter PLLC

"Click to Cancel" Rule Vacated Ahead of July 14th Deadline

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Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more

Fox Rothschild LLP

Franchisors, Take Notes: New Developments and Compliance Process for the 2025 SBA Franchise Director

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The SBA Franchise Directory is officially back online from June 1, 2025, and with it comes a series of critical updates for franchisors and franchisees discussed in the virtual briefing led by Stephen Olear, Senior Franchise...more

Vinson & Elkins LLP

Navigating Antitrust Compliance: A Q&A with Vinson & Elkins’ Antitrust and Enforcement Leaders

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At a recent Practising Law Institute (PLI) webinar on antitrust, over 250 legal professionals joined to hear from three antitrust leaders: Nicole Castle, Zach Terwilliger, and Craig Seebald. In this Q&A, they explore what’s...more

Holland & Knight LLP

Compliance Needs are Alive and Well: FTC's Recent Enforcement Activity

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In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta provides an early analysis of the Federal Trade Commission's (FTC) direction under Chair Andrew Ferguson, emphasizing that the agency is...more

Wiley Rein LLP

FTC Sends Warning Letters to 37 Eyeglass and Contact Lens Prescribers Over Possible Rule Violations

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On June 3, 2025, the Federal Trade Commission (FTC) announced its staff had sent warning letters to 37 contact lens prescribers that, according to the FTC, were the subject of consumer complaints concerning possible...more

Greenbaum, Rowe, Smith & Davis LLP

Legal Risks and Challenges for Private Equity in Healthcare Acquisitions

Private Equity (PE) firms continue to be significant players in U.S. healthcare, acquiring assets across various sectors such as physician practices, home health, behavioral health, and urgent care. However, recent legal...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Latham & Watkins LLP

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

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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

Foley & Lardner LLP

Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

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On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...more

Wiley Rein LLP

Is Your Company Prepared for the FTC’s May 14 “Click-to-Cancel” Compliance Deadline?

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A May 14, 2025 deadline is rapidly approaching for companies to comply with several of the most significant changes to the Federal Trade Commission’s (FTC) amended negative option rule, often called the “click-to-cancel”...more

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 51 – The Compliance Week at 20 Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Sheppard Mullin Richter & Hampton LLP

FTC Signals Strong Stance on Civil Investigation Demands

In a March 10 blog post, the new Director of the FTC’s Bureau of Consumer Protection (BCP) reaffirmed the agency’s commitment to enforcing consumer protection laws through Civil Investigation Demands (CIDs)....more

Wiley Rein LLP

What to Expect from New FTC Leadership on Digital Health Care

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Digital health care companies have navigated a wave of new developments at the Federal Trade Commission (FTC) over the past few years. With new leadership in the Trump Administration, the FTC may be poised to change some of...more

Baker Botts L.L.P.

Ninth Circuit Upholds Conviction of Former Uber Security Chief Joseph Sullivan in Connection with 2016 Uber Data Security Breach

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On March 13, 2025, a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit unanimously upheld the conviction of former Uber Chief Security Officer Joseph Sullivan. The ruling affirms Sullivan’s 2022 conviction...more

Ankura

Generative AI Risks: Legal and Compliance Insights - Part 1

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Generative artificial intelligence (AI) is transforming how businesses operate, from content creation to decision-making and even legal and compliance analysis. The use of machines to perform core deliberative and inventive...more

DLA Piper

Be Global: Employment Law in 5 - February 2025

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The US employment landscape continues to shift rapidly. On 21 February 2025, a federal district court enjoined the federal government from enforcing certain provisions of President Trump’s DEI Executive Orders (appeal...more

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