News & Analysis as of

Rulemaking Process › Consumer Protection Laws › Subscription Services

WilmerHale

Eighth Circuit Vacates the FTC's Click to Cancel Rule, but Federal and State Regulators Likely to Remain Active

WilmerHale on

On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) “Click to Cancel” Rule....more

Clark Hill PLC

Eighth Circuit blocks Click-to-Cancel Rule

Clark Hill PLC on

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

DLA Piper

FTC’s “Click-to-Cancel” Rule Voided

DLA Piper on

A unanimous three-judge panel of the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) final rule of amendments to the Negative Option Rule days before the rule’s scheduled July 14, 2025 effective date. The...more

Proskauer - Advertising Law

Canceled Before It Clicked: Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

Proskauer - Advertising Law on

Just days before it was set to take effect, the U.S. Court of Appeals for the Eighth Circuit struck down the Federal Trade Commission’s (FTC) much anticipated “Click-to-Cancel Rule” (the “Rule”), delivering regulatory...more

Benesch

Eighth Circuit Cancels FTC’s “Click-to-Cancel” Rule

Benesch on

On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more

Eversheds Sutherland (US) LLP

Eighth Circuit vacates FTC’s “Click-to-Cancel” Rule in Custom Communications v. FTC

Eversheds Sutherland (US) LLP on

Just days before it was scheduled to take effect, the Federal Trade Commission’s (FTC) amended Negative Option Rule, commonly known as the “Click-to-Cancel” Rule (Rule), was vacated by the US Court of Appeals for the Eighth...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

Womble Bond Dickinson

FTC’s Click to Cancel Rule is Vacated, But Remember It Was Not Alone

Womble Bond Dickinson on

What happened and why?  On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more

Venable LLP

Eighth Circuit Cancels FTC Negative Option Rule: What Does It Mean?

Venable LLP on

The U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Rule Concerning Subscriptions and Other Negative Option Plans (often referred to as the “Click-to-Cancel” rule) on July 8, just days...more

Venable LLP

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

Venable LLP on

Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...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

Sheppard Mullin Richter & Hampton LLP

FTC Finalizes ‘Click to Cancel’ Rule

Sheppard Mullin Richter & Hampton LLP on

On October 16, the FTC announced that it has finalized its “click to cancel” rule, that will require sellers to make it much easier for consumers to cancel subscriptions. The final rule is part of the FTC’s ongoing review of...more

Hinch Newman LLP

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

Hinch Newman LLP on

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

Sheppard Mullin Richter & Hampton LLP

CFPB: Negative Option Marketing Practices May Violate CFPA

Sheppard Mullin Richter & Hampton LLP on

On January 19, the CFPB issued Circular 2023-01 to affirm that companies offering “negative option” subscription services are required to comply with federal consumer financial protection laws. According to the Circular,...more

15 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide