News & Analysis as of

Subscription Services Goods or Services

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

UB Greensfelder LLP

FTC Implements New Rule Regulating Subscription-Based Services, Free Trial Offers, and Other Automatic Renewal Sales Systems

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The Federal Trade Commission (FTC) introduced its updated Negative Option Rule on October 16, 2024 (the “New Rule”). The New Rule targets deceptive practices associated with subscription-based services through which companies...more

DLA Piper

FTC Finalizes "Click-to-cancel" Rule: Top Points

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On October 16, 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule. The amendments to the rule, now titled the “Rule Concerning Recurring Subscriptions and Other Negative Option...more

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

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On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

BCLP

The DMCCA: Taking a Closer Look at the Impact on Subscription Contracts

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The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has recently received royal assent, following the announcement of the July General Election. We examine the key developments in our previous article. One very...more

Orrick, Herrington & Sutcliffe LLP

FTC proposes changes to Negative Option Rule

On March 23, the FTC announced a notice of proposed rulemaking (NPRM) seeking feedback on proposed amendments to the agency’s Negative Option Rule, which is used to combat unfair or deceptive practices related to...more

Akerman LLP - SALT Insights

Texas Supreme Court Rejects Texas Comptroller’s “Receipt-Producing, End-Product” Act Test for Sourcing Receipts from Services

On March 25, the Texas Supreme Court issued a highly-anticipated decision concerning the proper test to source receipts from services for purposes of Texas franchise tax. By statute, receipts from a “service performed in this...more

Harris Beach Murtha PLLC

New York Implements Automatic Renewal and Continuous Service Law for Contracts for Goods and Services

New York recently became the latest state to enact strict laws regarding the provision of automatic renewal and continuous service clauses in paid subscription or purchasing agreements with consumers (N.Y. Gen. Bus. Law §§...more

Seyfarth Shaw LLP

California DMV Finds “Care by Volvo” Subscription Service Violates State Law

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The California Department of Motor Vehicles (“DMV”) recently disclosed the results of its investigation of the “Care by Volvo” car subscription service (“CbV”) that was challenged as unlawful competition by the California New...more

Mintz - Consumer Product Safety Viewpoints

Stricter Automatic Renewal Law in California Commences July 1, 2018

On July 1, 2018, California’s revised Automatic Renewal Law (ARL), Cal. Bus. & Prof. Code § 17600 et seq., goes into effect. The updated law requires e-commerce sellers, doing business in California, to allow online...more

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