News & Analysis as of

State Attorneys General Subscription Services

Mintz

Click to Cancel: What the FTC’s Setback Means for Subscription-Based Businesses

Mintz on

I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...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

Perkins Coie

New York and Colorado Update Auto-Renewing Subscription Requirements

Perkins Coie on

Recent enforcement actions underscore the growing risks for businesses with automatically renewing subscriptions. In June 2025, New York Attorney General Letitia James announced a $600,000 settlement with fitness company...more

Cozen O'Connor

The State AG Report – 06.05.2025

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: • AGs Secure Contempt Ruling Against Robocaller for...more

Cozen O'Connor

Connecticut Enacts New Law Strengthening Consumer Protections

Cozen O'Connor on

The Connecticut legislature has passed a sweeping new consumer protection law addressing hidden fees, subscription practices, electronic privacy, price gouging, and right-to-repair requirements, among other things....more

Cozen O'Connor

NY Settles with Equinox for Allegedly Making Consumers Sweat over Negative Option Plans

Cozen O'Connor on

New York AG Letitia James entered into a settlement with Equinox Group, LLC (Equinox Group), which operates fitness services under Equinox, Equinox+, and SoulCycle, resolving allegations that its subscription and cancellation...more

Wiley Rein LLP

[Webinar] Navigating FTC Health Care Advertising and Privacy Compliance in the Trump Administration: Key Insights for Health...

Wiley Rein LLP on

Join us for a webinar on FTC advertising and privacy compliance for health service providers, including in emerging areas of FTC and state attorney general interest. Also joining as a featured panelist is Mary Engle,...more

Venable LLP

Subscription Sellers Take Note: New Tariffs Could Hit You Hard and Require You to Notify Customers

Venable LLP on

Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more

Troutman Pepper Locke

Massachusetts AG Campbell Releases “Junk” Fees and Auto-Renewal Regulations

Troutman Pepper Locke on

Massachusetts Attorney General (AG) Andrea Joy Campbell announced Massachusetts’ new consumer protection regulations prohibiting “junk fees” and providing consumers with greater transparency regarding trial and subscription...more

Cozen O'Connor

The State AG Report – 12.19.2024

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •Illinois AG’s and FTC’s Settlement Takes a $25 Million...more

Cozen O'Connor

Illinois AG’s and FTC’s Settlement Takes a $25 Million Bite Out of Grubhub

Cozen O'Connor on

Illinois AG Kwame Raoul and the FTC have settled with Grubhub Inc. and Grubhub Holdings Inc. (collectively, “Grubhub”) to resolve allegations that it engaged in deceptive business practices that harmed customers, food...more

Venable LLP

FTC and Illinois Attorney General Settle with Grubhub for Deceptive Practices

Venable LLP on

This week, the Federal Trade Commission (FTC) and the Illinois attorney general announced a settlement with Grubhub Inc. to resolve allegations that the company engaged in an array of unfair and deceptive practices that...more

Cozen O'Connor

New FTC Rule Makes Cancelling Negative Option Plans Easier

Cozen O'Connor on

The FTC has finalized a new “Click-to-Cancel” rule to protect consumers from unfair or deceptive practices when seeking to cancel their enrollment in subscription services, memberships, and other recurring-payment programs....more

Cozen O'Connor

The State AG Report – 6.20.2024

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •GOP AGs Seek to Black Out FERC’s Electrical Transmission &...more

Venable LLP

Telemarketing Trial: Defendant Sweeps All Six Claims Against the FTC and Pennsylvania AG

Venable LLP on

It’s not often we see defendants win a resounding victory against the Federal Trade Commission (FTC) and/or state attorneys general, especially after trial. But a recent opinion out of the Eastern District of Pennsylvania...more

Venable LLP

Mitigating Class Action Exposure: An Excerpt from the Advertising Law Tool Kit

Venable LLP on

When it comes to mitigating the risk of class action lawsuits, the best offense is a good defense. Companies can take many steps to reduce their exposure to class action litigation before it happens, including the tactics...more

Cozen O'Connor

The State AG Report – 1.4.2024

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: • Bipartisan AG Group Supports Google Users in Case...more

Kelley Drye & Warren LLP

NY AG Gets Serious Over Cancellation Practices

Last month, the New York AG filed a lawsuit against Sirius XM Radio, alleging that the company ​“sells subscriptions that are easy to purchase, and extremely difficult to cancel.” Consumers who want to cancel their...more

Cozen O'Connor

AG James Seeks to Cancel Onerous Consumer Cancellation Processes

Cozen O'Connor on

New York AG Letitia James settled with Cerebral, Inc. to resolve allegations that the online mental health provider required consumers to go through a lengthy, multi-step process to cancel their subscriptions; continued to...more

Venable LLP

New York Attorney General: Sirius XM Customers “Frustrated” When Trying to Cancel Subscriptions

Venable LLP on

On December 20, 2023, New York Attorney General Letitia James filed a Petition in state court alleging Sirius XM Radio’s autorenewal practices violated New York’s autorenewal law. In the lawsuit, New York alleges that Sirius...more

Cozen O'Connor

FTC Alleges Cash Advance Provider’s Tactics Were a Bridge Too Far

Cozen O'Connor on

The FTC reached a proposed settlement with Bridge It, Inc. d/b/a Brigit, to resolve allegations that the personal finance app provider violated the FTC Act and the Restore Online Shoppers’ Confidence Act through deceptive...more

Troutman Pepper Locke

Bipartisan State AGs Support FTC’s Amendments to Negative Option Rule

Troutman Pepper Locke on

The New York and Pennsylvania state attorneys general recently led a bipartisan coalition of 26 state AGs in a letter, supporting the Federal Trade Commission (FTC)’s proposed rule amending the Negative Option Rule....more

Orrick, Herrington & Sutcliffe LLP

26 state AGs support FTC’s proposal on Negative Option Rule

On June 26, a coalition of 26 state attorneys general from New York, Pennsylvania, Alabama, Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts,...more

Cozen O'Connor

AGs React Positively to FTC’s Proposed Negative Option Rule

Cozen O'Connor on

A coalition of 26 AGs filed a comment letter in support of the FTC’s proposed amendments to the Negative Option Rule, which is meant to prohibit the unfair or deceptive use of negative option marketing whereby a company takes...more

Cozen O'Connor

A Brief Investigation Gets to the Bottom of Alleged Underwear Subscription Deception

Cozen O'Connor on

A coalition of 32 AGs reached a settlement with online underwear retailer Adore Me, Inc. to resolve allegations that the company deceptively marketed its subscription membership program and made it intentionally difficult for...more

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