News & Analysis as of

Subscription Services Consumer Protection Laws

Cozen O'Connor

FTC and Match Strike $14M Deal over Alleged Deceptive Practices

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The FTC has reached a settlement with Match Group, Inc. and Match Group, LLC (collectively, “Match”)—the owners and operators of online dating services Match.com, OkCupid, PlentyofFish, The League, and other dating sites—to...more

Hudson Cook, LLP

Online Dating Service Agrees to Pay $14 Million to Resolve FTC Lawsuit

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On August 12, 2025, the Federal Trade Commission announced that a large online dating company (the "Company") agreed to stop alleged unlawful practices related to advertising, cancellation, and billing. ...more

Kelley Drye & Warren LLP

Massachusetts Provides Clarifications on Upcoming ​“Junk Fee” and Negative Option Regulations

Last week, the Massachusetts Attorney General’s office released a webinar and business guidance to help companies comply with upcoming regulations on junk fees and negative option contracts. The webinar and guidance cover a...more

Hinch Newman LLP

Massachusetts Releases Junk Fee Business Compliance Guidance

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On July 29, 2025 the Massachusetts Attorney General released updated business guidance on the new "junk fee" rules. Business must comply by September 2, 2025. The updated guidance and webinar is designed to help businesses...more

WilmerHale

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

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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

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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

DLA Piper

FTC’s “Click-to-Cancel” Rule Voided

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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

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

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On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more

Mintz

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

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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

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

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The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Proskauer - Advertising Law

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

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

BakerHostetler

Negative Option Rule No More: How To Comply in the Wake of the Eighth Circuit’s Decision

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As promised in last week’s blog that covered the Eighth Circuit’s decision to vacate the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule), we are back with some practical insights on and...more

Benesch

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

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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

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

Bass, Berry & Sims PLC

Eighth Circuit Vacates FTC’s Click-to-Cancel Rule

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On July 8, the U.S. Court of Appeals for the Eighth Circuit issued a unanimous opinion in Custom Communications Inc. v. Federal Trade Commission that vacates the Federal Trade Commission’s (FTC) Rule Concerning Recurring...more

Kelley Drye & Warren LLP

Ad Law News and Views - June 2025

In our most recent ​“Junk Fee” Legislative Roundup, we noted that the Connecticut legislature had introduced a bill that could require companies to include mandatory fees in their prices. On June 10, 2025, Connecticut’s...more

Wilson Sonsini Goodrich & Rosati

Consumer Protection in the UK: Update on Reforms Taking Effect in 2025 and 2026

Consumer protection in digital markets has become a major public concern in recent years, and the UK is the latest jurisdiction to introduce legislation aimed at enhancing protections online. The Digital Markets, Competition,...more

Fenwick & West LLP

Eighth Circuit Vacates FTC’s Click-To-Cancel Rule

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On Tuesday, July 8, the Eighth Circuit struck down the Federal Trade Commission’s new “click-to-cancel” rule just days before the FTC planned to begin enforcement on July 14, 2025. ...more

Winstead PC

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

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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

BakerHostetler

Eighth Circuit Clicked to Cancel the FTC’s Negative Option Rule

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Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more

Hudson Cook, LLP

Eighth Circuit Vacates FTC's Negative Option Rule

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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

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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?

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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

Perkins Coie

New York and Colorado Update Auto-Renewing Subscription Requirements

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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

BakerHostetler

Automatic Renewal Law Updates - Massachusetts, New York and Connecticut

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Companies selling subscriptions have been busy navigating compliance with the Federal Trade Commission’s Negative Option Rule, which is scheduled to go into effect July 14. But when it rains, it pours....more

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