News & Analysis as of

Subscription Services Consent Enforcement Actions

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

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

Holland & Knight LLP on

In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...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

Benesch

A New Era of Auto-Renewal: A Closer Look at the New FTC and California Requirements

Benesch on

It’s time to revisit automatic renewal compliance. With California amending its Automatic Renewal Law ("ARL") on September 24, 2024, and the Federal Trade Commission (“FTC”) finalizing its “Click-to-Cancel” Rule (“FTC Final...more

Bass, Berry & Sims PLC

FTC Releases “Click to Cancel” Rule

Bass, Berry & Sims PLC on

On October 16, the Federal Trade Commission (FTC) released the final version of its Rule Concerning Recurring Subscriptions and Other Negative Option Programs (Rule), which requires sellers of products and services to receive...more

Perkins Coie

FTC Finalizes “Click To Cancel” Rule With Substantial Requirements for Recurring Subscription Programs

Perkins Coie on

The Federal Trade Commission (FTC) announced its final Negative Option Rule (the Rule)—which the FTC often refers to as the “Click to Cancel” rule—for automatically renewing subscriptions, free trials that convert to paid...more

Butler Snow LLP

How to Get Cancelled: An Overview of New Rules Affecting Businesses Offering Subscription Services to Tennessee Consumers

Butler Snow LLP on

Subscription services, initially marketed as a cheaper, more accessible option, have recently been experiencing a price surge. In 2023, top subscription apps like Apple Music, Amazon Music, YouTubeTV, Netflix, Peacock, HBO...more

Venable LLP

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

Venable LLP on

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

DarrowEverett LLP

The FTC is Turning the Lights On: Dark Patterns Aren't in the Shadows Anymore

DarrowEverett LLP on

The continued growth and dominance of e-commerce has ushered in a new frontier for businesses. In response to the progressive evolution from brick-and-mortar marketplaces to the current e-commerce dominant landscape,...more

Fenwick & West LLP

FTC Warns Companies Offering Subscription Services to Avoid Using “Dark Patterns”

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On October 28, 2021, the Federal Trade Commission issued a new Enforcement Policy Statement (the Statement) warning companies against using “dark patterns” in negative option marketing. “Dark patterns” is a broad term that...more

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