News & Analysis as of

Cancellation Rights

Goodwin

FTC’s “Click-to-Cancel” Rule Gets New Life As FTC’s Enforcement Wave Continues to Target Negative-Option Sellers

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The Federal Trade Commission (FTC) is increasingly directing both its enforcement and rulemaking efforts toward auto-renewal programs, with a particular focus on burdensome or opaque cancellation procedures. ...more

Hinch Newman LLP

FTC Submits Notice of Proposed Rulemaking to Resuscitate Click-to-Cancel Rule

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Late last month, the Federal Trade Commission announced that it has submitted a draft Advance Notice of Proposed Rulemaking (“ANPRM”) concerning the FTC’s Rule Concerning the Use of Prenotification Negative Option Plans,...more

Holland & Knight LLP

About California's Auto-Renewal Law and Implications for Alcohol Subscription Services

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As California continues to strengthen its consumer protection framework around subscription services, businesses operating in the state – particularly those offering subscription goods, such as wine clubs – must remain...more

Arnall Golden Gregory LLP

Murder Most Foul: The Kennedy Center, Artist Cancellations, and Performance Contracts

Key Takeaways - Reputational controversy alone rarely justifies cancellation. The Kennedy Center cancellations illustrate that absent a well-drafted morals or brand-protection clause, artists who cancel in response to...more

Fox Rothschild LLP

When “Too Good To Be True” Really Is Too Good To Be True: FTC Settles With NextMed Regarding Deceptive Advertising Practices.

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The Federal Trade Commission (“FTC”) has reached a settlement with NextMed (also known as Southern Health Solutions, Inc.), resolving allegations that the telehealth company misled consumers through deceptive advertising,...more

Morgan Lewis - Tech & Sourcing

Key Santa Clauses: Unwrapping Performer Contracts

The holiday season often brings an increase in events featuring Santa Claus, themed characters, or other performer—but have you ever thought about the contractual clauses Santa agrees to in connection with his appearances at...more

Hudson Cook, LLP

State Attorneys General Join FTC Suit Against Major Rideshare Company for "Cancel Anytime" Subscription Practices

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Twenty-one states and the District of Columbia have joined an FTC enforcement lawsuit against a major rideshare and food delivery company over its subscription and cancellation practices. The allegations center on the...more

Alston & Bird

FTC Finalizes Deceptive Advertising, Cancellation, and Review Practices Settlement with Telehealth Company

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The Federal Trade Commission (FTC) continues to focus on companies’ subscription and cancellation practices. Our Consumer Protection/FTC Team reviews the latest consent order accusing a company of deceiving consumers about...more

Stikeman Elliott LLP

Québec’s Bill 10: Protecting Consumers Against Abusive Practices in Ticket Resales and Online Subscription Renewals

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In keeping with its recent renewed interest in establishing robust protections for consumers within the province, the government of Québec tabled a new bill on December 2, 2025 amending the Québec Consumer Protection Act...more

Hudson Cook, LLP

California Enacts the Combating Auto Retail Scams (CARS) Act

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On October 6, California Governor Gavin Newsom signed Senate Bill 766—the California Combating Auto Retail Scams (CARS) Act—which purports to help make the car-buying process more transparent and strengthen consumer...more

Kelley Drye & Warren LLP

34 State AGs Settle UDAP Autorenewal Allegations Against ​“JustFab” Subscriptions

Last month, a group of 34 state attorneys general—led by D.C, Maryland, Pennsylvania, and Texas—settled with TFG Holdings, a company known for brands such as JustFab and Shoedazzle, concerning its subscription practices. The...more

Holland & Knight LLP

Podcast - The Digital Marketplace: The FTC's Focus on Fair Online Transactions

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In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta provides an update on Federal Trade Commission (FTC) actions in the digital commerce space. Mr. DiResta discusses the FTC's core concerns...more

Holland & Knight LLP

All State Laws Aren't Local: Are You Ready for New Massachusetts Junk Fee and Subscription Law?

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Massachusetts recently implemented significant regulations targeting "junk fees" that have nationwide implications. Businesses across a broad array of industries now face stricter standards for price transparency, disclosures...more

Hudson Cook, LLP

Keeping Your Eye on the Ball: Federal Cancellation Policy Settlements and New York Updates to Auto Renewal Law

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While much focus has recently been paid to the Massachusetts Attorney General's "junk fee" regulation, which includes newly effective negative option requirements, focus on automatic renewal cancellation policies remains a...more

Stradling Yocca Carlson & Rauth

The Subscription Cancellation Gap: Clear State Rules, Vague Federal Standards, and Growing Legal Risk

Anyone who’s tried to cancel a gym membership, a digital subscription, or an auto-renewing trial knows the feeling: buried links, print-and-mail forms, long hold times. Some apps simply won’t let go....more

Loeb & Loeb LLP

FTC Scrutiny of Automatic Renewals: What Health & Wellness Companies Should Know

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Earlier this summer, the Federal Trade Commission’s (FTC’s) “click-to-cancel” rule was overturned by the U.S. Court of Appeals for the Eighth Circuit, just days before the new rule was set to go into effect. According to the...more

Goodwin

FTC Settles with Amazon Over Enrollment and Cancellation Processes for Prime Memberships

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On September 25, 2025, the Federal Trade Commission announced it had reached a settlement with Amazon.com, Inc. and two company executives, resolving allegations that the company’s enrollment and cancellation processes for...more

Wiley Rein LLP

FTC Consumer Protection and Privacy Enforcement Series: Subscription Cancellation Policies Remain a Top FTC Priority

Wiley Rein LLP on

When the FTC’s “Click to Cancel” Rule (otherwise known as the revised Negative Option Rule), was in litigation in July 2025, we predicted the FTC was likely to instead focus on enforcing the Restore Online Shoppers Confidence...more

Holland & Knight LLP

FTC Steps Up Subscription Enforcement After "Click to Cancel" Rule Struck Down

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Despite the demise of the Federal Trade Commission's (FTC) "Click to Cancel" Rule in July 2025, the FTC continues to actively define new standards for lawful subscription practices. The FTC's recent lawsuits and settlements...more

Fisher Phillips

Even Without Click-to-Cancel, the FTC Forces $7.5M Settlement Based on Subscription Violations: What Your Business Should Do

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The FTC just announced a $7.5 million settlement with an educational technology company over its unlawful cancellation practices, sending a warning to all businesses that offer subscription-based offerings. Even though a...more

Cozen O'Connor

FTC Teaches Ed Tech Firm a $7.5M Lesson on Cancellation Practices

Cozen O'Connor on

The FTC announced a settlement with Chegg Inc., resolving allegations that the education technology company used unlawful tactics to make it extremely difficult—and, in some cases, virtually impossible—for consumers to cancel...more

Orrick, Herrington & Sutcliffe LLP

FTC makes ed. tech company pay $7.5M for unlawful cancellation practices

On September 15, the FTC announced it had filed a complaint in the U.S. District Court for the Northern District of California along with a proposed order for permanent injunction and monetary judgment against an educational...more

Kelley Drye & Warren LLP

FTC Announces $7.5 Million Settlement Over Cancellation Practices

In July, the Eighth Circuit vacated the FTC’s ​“Click to Cancel Rule.” At the time, we noted that although the FTC was unlikely to try to resurrect the Rule, they could continue to challenge cancellation practices under other...more

Troutman Pepper Locke

Driving New Standards With California's CARS Rule — Moving the Metal: The Auto Finance Podcast

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In this episode of Moving the Metal: The Auto Finance Podcast, Brooke Conkle and Chris Capurso discuss California SB 766, known as the California CARS Rule. They explore the bill's amendments, including changes to...more

Foster Garvey PC

FTC Escalates Enforcement Against Cancellation Policies Utilized with Subscription Product Orders

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The Federal Trade Commission (“FTC”) has increased its campaign against businesses that impose unreasonable barriers to consumer cancellation of memberships and subscriptions. Recent actions demonstrate the agency’s intent to...more

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