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Unfair or Deceptive Trade Practices Consumer Protection Laws Subscription Services

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

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

Venable LLP

FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

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In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more

Miller Canfield

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

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The Federal Trade Commission’s (“FTC”) Negative Option Rule, dubbed the “Click-to-Cancel” Rule (the “Rule”), stands to substantially change the way online businesses must interact with customers. Its fate is now in the hands...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

Cozen O'Connor

The State AG Report – 06.05.2025

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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: • AGs Secure Contempt Ruling Against Robocaller for...more

BakerHostetler

[Podcast] AD Nauseam: I Want to Break Free – Free Claims!!

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In this episode of AD Nauseam, Amy Mudge and Daniel Kaufman explore the complexities of advertising “free” offers, emphasizing the importance of transparency and compliance with FTC guidelines. They discuss how the term...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

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

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

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

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

Robinson+Cole Data Privacy + Security Insider

Cleo AI Agrees to $17 Million Settlement with FTC

Sometimes, deals are too good to be true. That was the case for Cleo AI, an online cash advance company that promised consumers fast, up-front cash payments. According to the Federal Trade Commission (FTC), Cleo AI offered...more

Baker Botts L.L.P.

New CMA consumer protection regime in force next week

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A new UK consumer protection regime comes into force on 6 April 2025 through the implementation of the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 2) Regulations 2025 (SI 2025/272) (“the...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

Venable LLP

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

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Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more

BakerHostetler

FTC Files Brief Fully Supporting Its Click-to-Cancel Rule

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Just prior to the Federal Trade Commission’s (FTC or Commission) publication of its Click-to-Cancel Rule (the Rule) – which we wrote about in depth here – in the Federal Register, several trade associations filed petitions...more

BakerHostetler

Massachusetts Finalizes Junk Fee Regulation

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Earlier this month, Massachusetts issued regulations on two of the hottest areas for consumer protection: junk fees and subscriptions. In this blog post, we address the junk fee requirements....more

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