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Disclosure Requirements Unfair or Deceptive Trade Practices

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

Snell & Wilmer

FTC Click-to-Cancel Rule Enforcement Delayed 60 Days to Enable Business Compliance

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Enforcement of the Federal Trade Commission (FTC) Click-to-Cancel Rule (Rule) has now been deferred to July 14, 2025. The FTC noted that enforcement of the Rule did not adequately consider the compliance burdens...more

Arnall Golden Gregory LLP

Unhidden Fees: FTC Mandates Upfront Disclosure of All Mandatory Fees in Live-Event Ticketing

The live entertainment industry should take note that the Federal Trade Commission (“FTC”) has finalized its Rule on Unfair or Deceptive Fees aimed at eliminating deceptive pricing practices in the live-event ticketing...more

Venable LLP

FTC Staff Issues Guidance Ahead of New Rule Targeting Deceptive Fees

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Last week, the Federal Trade Commission (FTC) published a set of Frequently Asked Questions (FAQ) aimed at helping businesses and consumers understand the agency’s Rule on Unfair or Deceptive Fees, which takes effect on May...more

Mayer Brown

(A)Identify Yourself: State Bills Would Require Notification When Interacting with AI

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As the communication capabilities of artificial intelligence (“AI”)-powered chatbots and automated voice assistants (“callbots”) improve, it is becoming increasingly difficult to tell human from machine. At the same time,...more

Fox Rothschild LLP

FTC’s Unfair/Deceptive Fees Rule Takes Effect

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The Federal Trade Commission’s (FTC) Rule on Unfair or Deceptive Fees, 16 C.F.R. Part 464, is effective as of May 12, 2025. According to the FTC’s recent press release, the Rule “prohibits bait-and-switch pricing and other...more

Fenwick & West LLP

The FTC Rule on Unfair or Deceptive Fees: FAQs and Guidance

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On May 12, 2025, the Federal Trade Commission’s Rule on Unfair or Deceptive Fees will take effect. Under the rule, certain businesses must disclose all mandatory fees and the total price up front to limit bait-and-switch...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

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Notwithstanding significant changes at the Federal Trade Commission (FTC) – including the removal of two of the five Commissioners, and the new appointment of Commissioner Mark Meador – the Commission has sent a clear message...more

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

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Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Kelley Drye & Warren LLP

FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week

The FTC issued FAQs to answer common questions about its Rule on Unfair or Deceptive Fees and to provide a small entity compliance guide in connection with the Rule. The issuance of the FAQs affirms that the current FTC, led...more

Hogan Lovells

Deceptive sweepstakes prompt FTC action and consumer payouts

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Last week, the Federal Trade Commission sent more than $18 million in refunds to U.S. consumers who entered a Publishers Clearing House (PCH) sweepstakes in recent years. The refund represents a significant remedy to...more

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

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Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Pierce Atwood LLP

Revolve Faces $50M Class Action Alleging Undisclosed Influencer Relationships

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Social media influencing is an estimated $30 billion annual global industry, with brands increasingly electing to partner with influencers over traditional marketing channels. But, while social media and influencer...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...more

Kelley Drye & Warren LLP

Multiple Bites at the Apple over AI Claims

When Apple announced the iPhone 16 last year, it advertised that it would be ​“the first iPhone built for Apple Intelligence.” Apple touted several AI features and advertised that Apple Intelligence is ​“Available Now.” In...more

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Orrick, Herrington & Sutcliffe LLP

Iowa enacts provisions regarding prescreened mortgage solicitation practices

On April 18, Iowa enacted HF 857 (the “Act”), prohibiting financial institutions from using unfair or deceptive practices when they use prescreened mortgage trigger lead information to solicit consumers who have applied for...more

Kohrman Jackson & Krantz LLP

Avoiding Legal Pitfalls: Understanding Ohio’s Home Solicitation Sales Act

Are you a contractor who sells services directly to customers at their homes or outside your ordinary place of business? If so, do you know about Ohio’s Home Solicitation Sales Act? Understanding this law is crucial, and if...more

Fenwick & West LLP

Blurred Lines, Big Lawsuits: The Cost of Missing Disclosures

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Revolve is facing a $50 million putative class action over allegedly failing to enforce disclosure rules in its influencer campaigns. The suit claims that influencers received payments and free products but failed to clearly...more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

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This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more

Buchalter

#Ad – Annoyance or Necessary? The Rising Risk of Undisclosed Influencer Deals

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On April 11, 2025, a class-action lawsuit was filed accusing online fashion retailer Revolve Group Inc. of violating the Florida Deceptive and Unfair Trade Practices Act, the Consumers Legal Remedies Act, the Unfair...more

Benesch

Fee-Fallin’: Why “Tariff Fees” Are Not A Quick Fix to Offset New Costs

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In the wake of the Trump administration’s newly-imposed tariffs, many retailers are facing significant unanticipated cost increases across their supply chains, from raw materials, to manufacturing, to transporting goods...more

Orrick, Herrington & Sutcliffe LLP

Tennessee expands consumer protection against deceptive practices

On April 11, Tennessee enacted HB 911 (the “Act”), amending certain consumer protection measures. The Act introduces changes focusing on deceptive and unfair practices, motor vehicle-related misrepresentations, and regulatory...more

Kelley Drye & Warren LLP

Shein Faces Class Action Over Influencer Posts

A recent class action asks how it’s possible that a Chinese company, with allegedly ​“no fashion designers or background, selling flea-market quality clothes, became a giant in the fast-fashion industry in the US?” The...more

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