News & Analysis as of

Consumer Contracts Automatic Renewals Compliance

Venable LLP

Are Hyperlinked Disclosures "Clear and Conspicuous"? Yes, in some cases, according to the FTC's Final Negative Option Rule - A...

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The Federal Trade Commission's Final Negative Option Rule ("Click to Cancel Rule") contains stringent new requirements for negative option programs, making it even more difficult to run compliant negative option offers....more

Lathrop GPM

New Click-To-Cancel FTC Rule Carries New Rules, Hefty Penalties for Violations

Lathrop GPM on

Attention, any companies that sell direct to consumers: the FTC has announced a new final rule requiring businesses to make it easier for consumers to opt-out and cancel subscriptions. Businesses will have 180 days to comply...more

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

Latham & Watkins LLP

In California, New Automatic Renewal and Continuous Service Requirements Signed Into Law

Latham & Watkins LLP on

Companies offering automatic renewal or continuous service terms to consumers subject to California law should review their consent, notice, and cancellation practices. On September 24, 2024, California Governor Gavin...more

Fenwick & West LLP

California Tightens Requirements for Automatically Renewing Subscriptions

Fenwick & West LLP on

On September 24, 2024, Governor Gavin Newsom signed into law Assembly Bill No. 2863, which will further amend California’s Automatic Renewal Law (ARL)....more

Venable LLP

California Amends Autorenewal Law, with Stricter Consent Requirements and a “One Save” Rule: Fast VAST Update

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This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more

Venable LLP

State Automatic Renewal Laws Are Starting to Look Like a Patchwork Quilt as the FTC Expands Enforcement of ROSCA

Venable LLP on

With several new state laws effective in 2022, it is becoming increasingly difficult for businesses to develop baseline compliance protocols across federal and state automatic renewal laws. Against this backdrop, federal...more

Fenwick & West LLP

Changes to California’s Automatic Renewal Law May Require Updates for Subscription Service Providers

Fenwick & West LLP on

Subscription services face increased scrutiny from regulators, lawmakers and the plaintiffs’ bar. As we highlighted in a recent client alert, the FTC warned companies against using “dark patterns” in connection with paid...more

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