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FTC Act Subscription Services

Sheppard Mullin Richter & Hampton LLP

Lessons from the FTC: The Cleo AI Settlement

The FTC’s settlement with Cleo AI gives some indication as to what we might see from the agency in the coming months. The FTC alleged, among other things, that Cleo AI’s actions violated Section 5 of the FTC Act. 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

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

Venable LLP

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

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Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more

BakerHostetler

FTC Files Brief Fully Supporting Its Click-to-Cancel Rule

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Just prior to the Federal Trade Commission’s (FTC or Commission) publication of its Click-to-Cancel Rule (the Rule) – which we wrote about in depth here – in the Federal Register, several trade associations filed petitions...more

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

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Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more

Venable LLP

Fast VAST Update: Federal Court Declines to Stay FTC Negative Option Rule During Challenge

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Last Friday in a 2-1 order, the Eighth Circuit Court of Appeals rejected an initial challenge to the Federal Trade Commission’s (FTC) Negative Option Rule. The challengers had asked the court to stay the Rule from taking...more

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

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The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more

Troutman Pepper Locke

FTC and Illinois AG Settle Matter Against Grubhub for $140M

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On December 17, 2024, the Federal Trade Commission (FTC) and Illinois Attorney General (AG) Kwame Raoul settled their lawsuit against Grubhub for $140 million (Grubhub will only have to pay $25 million, with the balance...more

Hudson Cook, LLP

CFPB Bites of the Month - November 2024 - CFPB Take Me Home, Country Roads

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In this month's article, we share some of our top "bites" for the prior and current month covered during the November 2024 webinar....more

Venable LLP

FTC and Illinois Attorney General Settle with Grubhub for Deceptive Practices

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This week, the Federal Trade Commission (FTC) and the Illinois attorney general announced a settlement with Grubhub Inc. to resolve allegations that the company engaged in an array of unfair and deceptive practices that...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 12, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Kelley Drye & Warren LLP

Why Dissenting Statements by FTC Commissioners Matter

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Last week, the FTC, by a 3-2 vote along party lines, adopted its click-to-cancel rule, which purports to make it easier to cancel gym memberships, streaming services, and the like. [We wrote about it here.] The final rule...more

DLA Piper

FTC Finalizes "Click-to-cancel" Rule: Top Points

DLA Piper on

On October 16, 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule. The amendments to the rule, now titled the “Rule Concerning Recurring Subscriptions and Other Negative Option...more

Fox Rothschild LLP

Federal Trade Commission’s New “Click-to-Cancel” Rule Simplifies Ending Unwanted Subscriptions

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Gone are the days when subscriptions were limited to Netflix or Amazon. Today, you can find subscription services for nearly anything—from meal kits to beauty products and beyond. For companies, these subscriptions offer a...more

Orrick, Herrington & Sutcliffe LLP

FTC orders billing companies to shut down and issues $40M payout for fraud

On September 17, the FTC announced that the U.S. District Court for the Middle District of Florida approved the Commission’s order, effectively shutting down several companies named in the FTC’s June complaint and required...more

Arnall Golden Gregory LLP

The Pitch - June 2024

The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more

Alston & Bird

No Easy Way Out? Adobe and Executives’ Subscription Service Focus of FTC Action

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The Federal Trade Commission took action against Adobe and two of its executives. Our Consumer Protection/FTC Team outlines vital takeaways for companies and their executives in light of the FTC’s recent action....more

Moritt Hock & Hamroff LLP

FTC ‘Dark Patterns’ Lawsuit Against Amazon Progresses

A federal judge in Seattle has ruled against Amazon in its bid to have a Federal Trade Commission (FTC) lawsuit dismissed that alleges the online retailer used deceptive “dark patterns” practices to enroll customers in Prime...more

Cozen O'Connor

DOJ and FTC Accuse Adobe of Engaging in Acrobatics to Hide Subscription Terms

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The U.S. DOJ, upon notification and referral from the FTC, filed a lawsuit against Adobe, Inc. and two of its executives (collectively, “Adobe”), alleging that the software company violated the FTC Act and the Restore Online...more

Ballard Spahr LLP

The Iliad Flows: Federal Judge Allows FTC “Dark Patterns” Suit Against Amazon to Proceed

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In a lengthy ruling, a Seattle federal judge has allowed the Federal Trade Commission (FTC) to proceed with its groundbreaking case alleging that Amazon’s Prime online subscription marketing tactics constituted deceptive...more

Sheppard Mullin Richter & Hampton LLP

FTC Settles with Fintech for $18M over Deceptive Cash Transfers and Difficult-to-Cancel Memberships

On November 2, the FTC entered into a settlement agreement with a Manhattan-based fintech company for $18 million over alleged deceptively marketed cash advances to consumers and impeding customers’ ability to cancel...more

Cozen O'Connor

FTC Alleges Cash Advance Provider’s Tactics Were a Bridge Too Far

Cozen O'Connor on

The FTC reached a proposed settlement with Bridge It, Inc. d/b/a Brigit, to resolve allegations that the personal finance app provider violated the FTC Act and the Restore Online Shoppers’ Confidence Act through deceptive...more

Proskauer - Minding Your Business

Amazon: The Prime Target in FTC Crackdown

On October 18, 2023, Amazon filed a motion to dismiss the Federal Trade Commission’s lawsuit alleging that the company deceived millions of consumers into nonconsensual Prime membership enrollment and thwarted members’...more

WilmerHale

FTC Targets "Dark Patterns" in Actions Against Amazon and Publishers Clearing House

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The Federal Trade Commission (FTC) in recent years has made clear its intention to adopt a more aggressive enforcement posture toward so-called dark patterns. The FTC defines unlawful dark patterns to include any online...more

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