News & Analysis as of

Unfair or Deceptive Trade Practices Subscription Services

DLA Piper

Click-to-Cancel Lives on Under ROSCA and Section 5

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The Federal Trade Commission (FTC) has filed a complaint in the Central District of California against Fitness International, LLC and Fitness & Sports Clubs, LLC (together, LA Fitness), alleging unfair and deceptive practices...more

Partridge Snow & Hahn LLP

New Massachusetts Fee Disclosure Rules Impose Substantial Penalties for Non-Compliance

Effective September 2, 2025, Massachusetts will begin enforcing 940 CMR 38.00, a new regulation aimed at promoting price transparency for consumers. These comprehensive rules apply to the sale or lease of goods and services...more

Kelley Drye & Warren LLP

HelloFresh to Pay $7.5 Million to Settle Automatic Renewal Suit

Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more

Cozen O'Connor

The State AG Report – 08.28.2025

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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: • FTC Sues LA Fitness to Cancel Unfair Membership...more

Troutman Pepper Locke

FTC Orders Match Group to Pay $14M Over Alleged Deceptive Subscription Practices and Guarantee Claims

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On August 12, the Federal Trade Commission (FTC) ordered Match Group, owners and operators of online dating platforms such as Match.com, OkCupid, PlentyOfFish, The League, and others, to pay $14 million. This settlement...more

Troutman Pepper Locke

Massachusetts AG Campbell Releases Business Guidance on “Junk Fee” and Auto-Renewal Regulations

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Massachusetts Attorney General (AG) Andrea Joy Campbell has issued guidelines to help businesses comply with the recently enacted consumer protection regulations, prohibiting “junk fees” and providing consumers with greater...more

Alston & Bird

FTC Enforcement of Cancellation Practices Continues After Click-to-Cancel Rule Defeated

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Our Consumer Protection/FTC Team examines how the FTC continues to actively pursue companies with allegedly complicated cancellation practices by relying on existing legal authority despite setbacks to the Click-to-Cancel...more

Loeb & Loeb LLP

Match Group’s $14 Million Lesson: Even Without “Click-to-Cancel,” Subscription Companies Can’t Play Hard to Get

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Last week, Match Group Inc., the powerhouse behind Match.com, OkCupid, Plenty of Fish and The League, agreed to shell out $14 million and revamp its cancellation policies, ending a nearly six-year showdown with the Federal...more

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

Ballard Spahr LLP

Eighth Circuit voids FTC ‘Click to Cancel’ rule

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A federal appeals court has nullified the Federal Trade Commission’s amendments to its Negative Option Rule intended to make it easier for people to cancel subscriptions....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

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

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

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