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“I’m Not Dead Yet”: Is the Demise of the FTC’s Click-to-Cancel Exaggerated?

The Federal Trade Commission’s 2024 amendments to the Negative Option Rule (commonly called “Click-to-Cancel”) may have been vacated by the Eighth Circuit for failing to comply with required rulemaking procedures, but the FTC...more

FTC Chairman Issues Warning Letters Relating to Diversity Initiatives to Law Firms Which Have Implications to Corporate Employers...

On Friday, January 30, 2026, Andrew Ferguson, the Chairman of the Federal Trade Commission (FTC), sent warning letters to over 40 law firms about their purported involvement in the Mansfield Certification program, a diversity...more

Early Reviews Are In: FTC Flags Potential Violations of Consumer Reviews Rule

Companies would be wise to start the new year by reviewing their policies for compliance with the FTC Rule on Consumer Reviews & Testimonials, as warning letters sent by the Federal Trade Commission signal that this may be an...more

Blocking Their Own Shot: FTC’s Recent Arguments Could Impact If and How FTC Investigations Are Conducted

In Media Matters v. Federal Trade Commission, the Federal Trade Commission (FTC) suggested that issues surrounding the scope, validity, and enforceability of a civil investigative demand (CID) should be addressed during an...more

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