News & Analysis as of

ROSCA Subscription Services Enforcement Actions

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

Wiley Rein LLP on

The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Venable LLP

FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

Venable LLP on

In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

Benesch on

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

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Venable LLP

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

Venable LLP on

In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more

Sheppard Mullin Richter & Hampton LLP

FTC Orders Fintech Company to Pay $17 Million for Allegedly Deceptive Subscription Practices

On March 27, the FTC announced that a fintech company offering cash advances through a mobile app has agreed to pay $17 million to resolve allegations that it violated the FTC Act and the Restore Online Shoppers’ Confidence...more

Hudson Cook, LLP

CFPB Bites of the Month - November 2024 - CFPB Take Me Home, Country Roads

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In this month's article, we share some of our top "bites" for the prior and current month covered during the November 2024 webinar....more

Orrick, Herrington & Sutcliffe LLP

FTC orders billing companies to shut down and issues $40M payout for fraud

On September 17, the FTC announced that the U.S. District Court for the Middle District of Florida approved the Commission’s order, effectively shutting down several companies named in the FTC’s June complaint and required...more

Venable LLP

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

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Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more

Cooley LLP

FTC Continues Aggressive ROSCA Enforcement Agenda Against Negative Option Sellers

Cooley LLP on

In June 2024, the US Federal Trade Commission (FTC) and the Department of Justice jointly filed a complaint under the Restore Online Shoppers’ Confidence Act (ROSCA) in the US District Court for the Northern District of...more

Orrick, Herrington & Sutcliffe LLP

FTC refers ROSCA case against software company and executives to DOJ

On June 17, the FTC announced an enforcement action against a software company and two of its executives for its practices related to its subscription model. According to the redacted complaint filed by the DOJ (upon referral...more

Sheppard Mullin Richter & Hampton LLP

FTC Settles with Fintech for $18M over Deceptive Cash Transfers and Difficult-to-Cancel Memberships

On November 2, the FTC entered into a settlement agreement with a Manhattan-based fintech company for $18 million over alleged deceptively marketed cash advances to consumers and impeding customers’ ability to cancel...more

Venable LLP

Is Your New Year’s Resolution to Comply with Automatic Renewal Laws? If So, Look No Further

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The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more

Venable LLP

[Webinar] New Laws and Requirements for Automatic Renewal Programs: What Businesses Need to Know in 2022 - February 23rd, 2:00 pm...

Venable LLP on

The laws and rules governing automatic renewal programs continue to change on a regular basis. Over the past year, the Federal Trade Commission has announced a number of settlements and lawsuits enforcing the federal Restore...more

Orrick, Herrington & Sutcliffe LLP

Putting Individuals In The (Urth)Box: FTC Goes After Individual Executives For Unfair And Deceptive Practices

In an increasing trend, the Federal Trade Commission (FTC) joined other federal regulators seeking to hold individuals – not just companies – liable in enforcement proceedings. The most recent target was San Francisco-based...more

Perkins Coie

Hot Ad Law Topics for the New Year

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Don’t let the new year be ruined by U.S. class actions, regulatory enforcement actions, or competitor claims. Here are five ad law takeaways for brand and legal teams to consider as 2019 approaches....more

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