News & Analysis as of

Cancellation Rights California

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

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Kelley Drye & Warren LLP

California AG Issues Alert on California’s Automatic Renewal Law

Last week, we reported that HelloFresh had agreed to settle an investigation by the California Automatic Renewal Task Force. As part of the settlement, the company is required to pay $7.5 million and make various changes to...more

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

Lowenstein Sandler LLP on

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

Nelson Mullins Riley & Scarborough LLP

Do NOT Cancel Your Click-to-Cancel Compliance Efforts!

As has been widely reported, the Eighth Circuit issued a decision this week vacating the Federal Trade Commission’s Click-to-Cancel Rule, which had been scheduled to spring into effect on July 14. In the grand scheme of...more

Sheppard

California’s “Auto Renewal Law” Takes Effect on July 1

Sheppard on

Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more

Arnall Golden Gregory LLP

State Wave of Click-to-Cancel Rules

The end of President Biden’s administration saw the Federal Trade Commission (“FTC”) adopt the sweeping “Click-to-Cancel” rule, which stands to impose a spate of requirements for disclosure, consent, and cancellation on any...more

Snell & Wilmer

FTC Click to Cancel Rule

Snell & Wilmer on

In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...more

DLA Piper

Preparing for (More) Updates to California’s Automatic Renewal Law

DLA Piper on

California has passed additional amendments to its Automatic Renewal Law (ARL), which will further strengthen that law’s already stringent requirements and likely present increased class action risk....more

Hinch Newman LLP

California Expands “Dark Pattern” Automatic Renewal Legislation

Hinch Newman LLP on

On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more

Carlton Fields

California District Court Finds Defendants’ Conduct Was Not Arbitrary and Capricious Under Administrative Procedure Act

Carlton Fields on

Citing the Administrative Procedure Act (APA), and recognizing the role of the district court in reviewing a final agency determination under the act, the U.S. District Court for the Northern District of California granted...more

Pillsbury Winthrop Shaw Pittman LLP

Key Changes to California’s Automatic Renewal Law Are Now in Effect

Businesses offering subscription services or other automatically renewing agreements to California consumers must adhere to new notice and cancellation requirements or face the risk of significant liability. Businesses...more

Polsinelli

Subscription Service Businesses Take Notice: Amendments to California’s Automatic Renewal Law Are Here

Polsinelli on

Subscription service providers should be aware of the various changes coming to California's automatic renewal law. California’s already stringent laws governing recurring subscription programs are about to become even more...more

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