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Unfair or Deceptive Trade Practices Cancellation Rights Subscription Services

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

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

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

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

Proskauer - Advertising Law

Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - May 2025 - "The CFPB in the End of May"

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In this month's article, we share some of our top "bites" covered during the May 2025 webinar....more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Latham & Watkins LLP

FTC Delays Enforcement of Click-to-Cancel Rule Until July 14 2025

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Companies with B2C or B2B recurring payment programs that include negative option terms now have until July 14, 2025, to ensure their disclosure, consent, and cancellation practices are compliant with the Negative Option...more

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

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Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

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Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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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

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

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This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

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Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more

Fenwick & West LLP

CLE Takeaways: The Risks and Rewards of Recurring Subscriptions

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For companies offering subscription-based services, the regulatory landscape is becoming increasingly complex, with recent updates to federal and state laws creating new compliance requirements that demand careful attention...more

Venable LLP

Fast VAST Update: Federal Court Declines to Stay FTC Negative Option Rule During Challenge

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Last Friday in a 2-1 order, the Eighth Circuit Court of Appeals rejected an initial challenge to the Federal Trade Commission’s (FTC) Negative Option Rule. The challengers had asked the court to stay the Rule from taking...more

Cozen O'Connor

The State AG Report – 12.19.2024

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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

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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

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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

Morris, Manning & Martin, LLP

FTC “Click to Cancel” Rule: What to Know Now

On October 16, 2024, the Federal Trade Commission (FTC) announced its final “Click to Cancel” Rule (the Rule) as a part of its ongoing review of its 1973 Negative Option Rule. The FTC revised the Rule to provide additional...more

BakerHostetler

[Podcast] AD Nauseam: FTC Negative Option Rule

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On today’s episode of AD Nauseam Amy and Daniel talk about the new FTC Negative Option Rule....more

Sheppard Mullin Richter & Hampton LLP

Click! FTC Updates Its Negative Option Rule

The FTC updated its Negative Option Rule last month and gave it a new name to emphasize the expanded scope of programs to which it applies. It will now be the “Rule Concerning Recurring Subscriptions and Other Negative Option...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 12, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

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