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First 100 Days of the New HSR Rules with Antitrust Partner Kara Kuritz
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The Federal Trade Commission, state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers, including automatic renewals, free-to-pay conversions, and continuity programs....more
On October 16, 2024, the Federal Trade Commission (FTC) announced its final “Click to Cancel” Rule (the Rule) as a part of its ongoing review of its 1973 Negative Option Rule. The FTC revised the Rule to provide additional...more
The FTC updated its Negative Option Rule last month and gave it a new name to emphasize the expanded scope of programs to which it applies. It will now be the “Rule Concerning Recurring Subscriptions and Other Negative Option...more
After a multi-year process that was initiated in 2019, the U.S. Federal Trade Commission (FTC) has officially brought the 1973 Negative Option Rule into the 21st century, but not without opposition. The FTC has announced a...more
On October 16, 2024, the Federal Trade Commission (FTC) announced its Final Rule revising its Negative Option Rule, now known as the Rule Concerning Recurring Subscriptions and Other Negative Option Programs (the Rule). The...more
In an era where subscriptions are just a click away, getting out of them often frustrates consumers. Responding to that frustration, the Federal Trade Commission (FTC) revised its existing Negative Option Rule, now retitled...more
Earlier this week, we discussed the Federal Trade Commission’s (FTC) final amendments to the Negative Option Rule, now retitled the Rule Concerning Recurring Subscriptions and Other Negative Option Programs. These amendments,...more
On October 16, the FTC issued its final amendments to the Negative Option Rule, which now applies to all negative option programs and includes a “click to cancel” provision intended to make it easier for consumers to cancel...more
In March 2023, we discussed the Federal Trade Commission’s (FTC) Notice of Proposed Rulemaking (NPRM) aimed at making it easier for consumers to cancel recurring subscriptions and memberships. The proposed rule was part of...more