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Federal Trade Commission (FTC) Consent

Fox Rothschild LLP

FTC Restricts Omnicom-IPG Merger to Prevent Viewpoint-Based Ad Bias

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The Federal Trade Commission approved Omnicom Group Inc.’s approximately $13.5 billion acquisition of The Interpublic Group of Companies, Inc. (IPG) but with strict conditions designed to prevent anticompetitive coordination...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

Perkins Coie

Another Take on the TAKE IT DOWN Act

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The TAKE IT DOWN Act (the Act), enacted on May 19, 2025, is a powerful (and controversial) new tool designed to stop people from sharing “nonconsensual intimate imagery,” or NCII, online. The Act does two main things: it...more

Epstein Becker & Green

FTC Challenges Merger Based on Potential Coordinated Effects Theory, Accepts Conduct Remedy

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A recent enforcement action by the Federal Trade Commission (FTC) is particularly noteworthy because of the theory of potential harm and the accepted remedy....more

Tarter Krinsky & Drogin LLP

Waves of Lawsuits Hit Businesses Over Website Tracking Pixels

Websites are ubiquitous, and so are cookies and tracking pixels (a/k/a web beacons). A web browser uses cookies to store login details and preferences; the cookies also track and profile user behavior. When visiting a...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

Nelson Mullins Riley & Scarborough LLP

The TAKE IT DOWN Act Targets AI-Generated and Authentic Nonconsensual Intimate Images

The Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks Act, the TAKE IT DOWN Act, a federal bipartisan effort to require covered platforms to remove nonconsensual intimate...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

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

Morgan Lewis

TAKE IT DOWN Act Targets Deepfakes: Are Online Platforms Caught in the Crosshairs?

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The TAKE IT DOWN Act, recently signed into federal law, criminalizes the distribution of nonconsensual intimate imagery and requires covered online platforms to implement a notice-and-removal process by May 19, 2026....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

Parker Poe Adams & Bernstein LLP

New FTC Consent Order Against Health Care-Focused Private Equity Firm Has Antitrust Implications

Last week, the Federal Trade Commission (FTC) approved a final consent order with a private equity firm focused on health care and technology to resolve allegations of anticompetitive practices in two anesthesiology markets...more

Cozen O'Connor

Covered Platforms Face Strict Deadlines Under the Take It Down Act

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A new federal law criminalizes nonconsensual intimate imagery and gives covered websites, mobile applications, and other online platforms merely 48 hours to comply with requests to take down such materials. On May 19, 2025,...more

Orrick, Herrington & Sutcliffe LLP

TAKE IT DOWN Act Becomes Law, Introducing Landmark Federal Protections to Combat Online Exploitation and Deepfakes

On May 19, President Donald Trump signed into law the bipartisan-supported TAKE IT DOWN Act (S.146). While almost forty U.S. states have enacted some form of legislation targeting online abuse, the TAKE IT DOWN Act is the...more

Venable LLP

President Trump Signs Take It Down Act into Law

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On May 19, 2025, President Trump signed into law the Take It Down Act. The new law imposes strict takedown obligations and creates new civil and criminal liabilities for individuals and platforms that distribute nonconsensual...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

Fisher Phillips

FTC’s Click-to-Cancel Rule Delayed Amid Legal Challenges: What Businesses Need to Know

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Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more

Wilson Sonsini Goodrich & Rosati

The “TAKE IT DOWN Act” Goes Up to President Trump’s Desk for Signature

On April 28, 2025, Congress passed the “TAKE IT DOWN Act.” In addition to criminalizing intentional publication of non-consensual intimate imagery, including computer-generated intimate imagery (collectively, NCII), the bill...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

Bradley Arant Boult Cummings LLP

PART 1: “Staying in Our Lane”: Andrew Ferguson’s FTC Philosophy on Privacy Enforcement

Since Andrew Ferguson assumed the role of FTC chair in January 2025, following his year-long tenure as a commissioner, businesses have been watching closely for signals of how the agency might redirect its focus on privacy...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...more

Hudson Cook, LLP

FTC Takes Action against AI Company over Deceptive Accuracy Claims about AI Content Detection

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On April 24, 2025, the Federal Trade Commission (FTC) finalized a Decision and Order against an Artificial Intelligence (AI) Company (the "Company"), alleging that it made false and unsubstantiated claims about its AI Content...more

Lowenstein Sandler LLP

FTC "Click-To-Cancel" Rule Coming Soon

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The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more

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