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Disclosure Requirements Unfair or Deceptive Trade Practices

Miller Canfield

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

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The Federal Trade Commission’s (“FTC”) Negative Option Rule, dubbed the “Click-to-Cancel” Rule (the “Rule”), stands to substantially change the way online businesses must interact with customers. Its fate is now in the hands...more

Kilpatrick

Influencers on the "Free Stuff" Train Require Monitoring for False Claims

Kilpatrick on

A recent National Advertising Division (NAD) decision provides a warning that sending free stuff to influencers may make you responsible for what those influencers say, even without a formal relationship between the brand and...more

Proskauer - Advertising Law

Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more

Perkins Coie

The FTC “Junk Fee” Rule Is Here… Along With a Wave of State Laws

Perkins Coie on

Key Takeaways - - The Federal Trade Commission’s Rule on Unfair or Deceptive Fees is now in effect. - The rule applies to businesses that offer or advertise live-event tickets or short-term lodging. - If including the...more

BakerHostetler

FTC’s Junk Fee Rule FAQs Give Road Map for Displaying Price

BakerHostetler on

In May the FTC’s Rule on Deceptive or Unfair Fees (the Rule) went into effect, and the FTC staff published accompanying FAQs for business. We have blogged a lot about the proposed Rule, enforcement in this space and its windy...more

Perkins Coie

The FTC “Junk Fee” Rule Is Here…Along with a Wave of State Laws

Perkins Coie on

Also referred to as the “junk fee” rule against “bait-and-switch” or “drip” pricing, the rule was adopted with bipartisan support in the waning days of the Biden presidency. Further, the Republican-led FTC under the Trump...more

IR Global

FTC Implements Rule to Eliminate Hidden Fees in Pricing

IR Global on

On May 12, 2025, the Federal Trade Commission (FTC) enacted the Rule on Unfair or Deceptive Fees (the “Rule”), mandating that businesses disclose all mandatory fees upfront in advertised prices. This initiative aims to...more

Holland & Knight LLP

Podcast - New Guidance on Complying with FTC Rule on Deceptive and Unfair Fees

Holland & Knight LLP on

In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta breaks down the Federal Trade Commission's (FTC) Rule on Unfair or Deceptive Fees, focusing on recent FAQs that clarify its application...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

Winstead PC on

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

Snell & Wilmer on

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

Venable LLP on

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

Mayer Brown on

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

Fox Rothschild LLP on

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

Fenwick & West LLP on

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

Latham & Watkins LLP on

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

Benesch on

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

Perkins Coie on

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

Hogan Lovells on

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

Alston & Bird on

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

Pierce Atwood LLP on

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

Holland & Knight LLP on

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

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