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Rulemaking Process Enforcement Consumer Protection Laws

Arnall Golden Gregory LLP

Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

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, resolving the challenges to the rule filed on the heels of its adoption in...more

Morgan Lewis

FTC’s Click-to-Cancel Rule Vacated Ahead of Planned July 14 Effective Date

Morgan Lewis on

On July 8, 2025, a three-judge panel of the US Court of Appeals for the Eighth Circuit issued a per curiam opinion vacating the US Federal Trade Commission’s (FTC’s) Negative Option Rule (Click-to-Cancel) on Administrative...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

Perkins Coie

Eighth Circuit Vacates FTC Negative Option Rule, What’s Next?

Perkins Coie on

Key Takeaways - - The Eighth Circuit vacated the FTC’s Negative Option Rule due to the agency’s failure to issue a required preliminary regulatory analysis during the rulemaking process. The ruling comes just days before the...more

Kelley Drye & Warren LLP

Eighth Circuit Vacates FTC’s Negative Option Rule

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

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

Wiley Rein LLP

‘An Avalanche of Rulemakings’ – The FTC Gears Up for an Active 2022

Wiley Rein LLP on

Privacy In Focus®- On December 10, 2021, the Federal Trade Commission (FTC) published its Annual Regulatory Plan for 2022 – the first under FTC Chair Lina Khan – noting that it “will consider developing both...more

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