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Mayer Brown

Click-to-Cancelled! Eighth Circuit Vacates Federal Trade Commission’s Revised Negative Option Rule

Mayer Brown on

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

Clark Hill PLC

Eighth Circuit blocks Click-to-Cancel Rule

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On July 8, the U.S. Court of Appeals for the Eighth Circuit blocked the “click-to-cancel” rule, which would have required companies to make it as easy to cancel subscriptions as it was to sign up, including obtaining consent...more

Miller Canfield

Eighth Circuit Slams the Brakes on FTC’s Click-to-Cancel Rule

Miller Canfield on

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

Ropes & Gray LLP

FTC’s “Click-to-Cancel” Rule Struck Down by Eighth Circuit

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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

Lerman Senter PLLC

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

Lerman Senter PLLC on

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

Winstead PC

8th Circuit Vacates FTC’s “Click to Cancel Rule”

Winstead PC on

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...more

Hudson Cook, LLP

Eighth Circuit Vacates FTC's Negative Option Rule

Hudson Cook, LLP on

On July 8, 2025, the Eighth Circuit issued an opinion that vacated the FTC's Negative Option Rule in its entirety. The FTC's compliance deadline for the Rule, which had been extended once, was set to go into effect on July...more

Kelley Drye & Warren LLP

Eighth Circuit Vacates FTC’s Negative Option Rule

Kelley Drye & Warren LLP on

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

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

Morrison & Foerster LLP on

The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Foley & Lardner LLP

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

Foley & Lardner LLP on

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

BakerHostetler

Keeping Up with the FTC Rulemakings - Part One

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We love two-parters. Who shot J.R.? Who shot Montgomery Burns? Well, perhaps this one won’t be quite as much fun – but checking in on FTC rulemakings also warrants the two-parter treatment. ...more

Stradling Yocca Carlson & Rauth

Beware of the FTC’s Proposed Changes to The Negative Option Rule… There is a Potential Trojan Horse

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Key Takeaways - In its current form, the Negative Option Rule covers only a narrow category of negative option marketing – prenotification negative option plans. The FTC’s proposed Rule seeks to synthesize all of the...more

Hinch Newman LLP

Roundup of FTC Consumer Protection Matters of Interest to Digital Advertisers: April 2023

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In April 2023, the Federal Trade Commission announced a number of consumer protection actions and inquiries involving an important U.S. Supreme Court Ruling regarding the ability of defendants in FTC and SEC actions to raise...more

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