News & Analysis as of

Penalties Federal Trade Commission (FTC)

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

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In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...more

Sheppard Mullin Richter & Hampton LLP

FTC Imposed $9.6 Million Judgement Against Debt Collector for Alleged Threats and Phantom Debt

On April 30, 2025, the FTC filed an amended complaint and final order in the U.S. District Court for the Northern District of Georgia against a debt collection company in connection with allegations that the company engaged...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

Troutman Pepper Locke

FTC Bans Debt Collector and Imposes Substantial Penalty for Allegedly Coercing Consumers into Paying Debts Not Owed

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Last year, the Federal Trade Commission (FTC) filed suit in the U.S. District Court for the Northern District of Georgia, alleging Global Circulation, Inc. (GCI) and its owner, Kenneth Redon III, violated the FTC Act, Fair...more

Wiley Rein LLP

Is Your Company Prepared for the FTC’s May 14 “Click-to-Cancel” Compliance Deadline?

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A May 14, 2025 deadline is rapidly approaching for companies to comply with several of the most significant changes to the Federal Trade Commission’s (FTC) amended negative option rule, often called the “click-to-cancel”...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

Seyfarth Shaw LLP

Federal Trade Commission Orders accessiBe to Pay $1M For Misleading Claims Relating to Automated Website Accessibility Remediation...

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The FTC issued a Decision and Order prohibiting accessibility plug-in/Widget vendor AccessiBe from making misleading claims and to pay $1 million....more

Jenner & Block

Premerger Enforcement Actions Highlight Importance of HSR Compliance

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Cases involving premerger enforcements under the Hart-Scott-Rodino (HSR) Act are relatively rare. So far in 2025, however, we have seen two such cases involving potentially record-breaking penalties. The timing is notable, as...more

Hudson Cook, LLP

FTC Proposes Largest Dealer Fine in Its History

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On December 19, 2024, the Federal Trade Commission announced a proposed $20 million settlement with Leader Automotive Group and its parent company, AutoCanada, to resolve claims brought by the FTC and the State of Illinois....more

Whiteford

Client Alert: Winter 2025 Antitrust M&A Law Developments

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The Federal Trade Commission, the agency that administers the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR Act”), has announced the annual adjustments to its coverage, filing fee, and other dollar-denominated...more

Orrick, Herrington & Sutcliffe LLP

FTC adjusts maximum civil penalty amounts for 2025

On February 11, the FTC announced adjustments to the maximum civil penalty amounts for violations of 16 provisions of laws it enforces, as mandated by the Federal Civil Penalties Inflation Adjustment Act Improvements Act. The...more

Orrick, Herrington & Sutcliffe LLP

HSR Filing Thresholds, Filing Fees, and Penalties on the Rise Again

The U.S. Federal Trade Commission (FTC) has announced revised filing thresholds as required by the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act), along with adjusted HSR filing fee tiers and...more

Mayer Brown

FTC Ups HSR Act Thresholds in Annual Update

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On January 22, 2025, the US Federal Trade Commission (FTC) published its annual update to the Hart-Scott-Rodino (HSR) Act thresholds in the Federal Register. The HSR Act governs certain deals that must be reported to the FTC...more

Bass, Berry & Sims PLC

HSR Thresholds and Filing Fees Increased for 2025

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The Hart-Scott-Rodino (HSR) Act requires parties to transactions that meet certain thresholds to notify the Department of Justice (DOJ) and Federal Trade Commission (FTC) and observe a waiting period prior to closing unless...more

A&O Shearman

2025 increases to HSR notification thresholds, filing fees, interlocking directorate thresholds, and HSR penalties

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The Federal Trade Commission (FTC) has announced increases to the notification thresholds and premerger filing fees under the Hart-Scott-Rodino (HSR) Antitrust Improvements Act, which requires premerger notification of...more

Ropes & Gray LLP

FTC Announces Revised HSR Filing Fees, Thresholds, Penalties, and Interlocking Directorate Thresholds for 2025

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The Federal Trade Commission (“FTC”) announced the new filing fees, along with the annual adjustment to jurisdictional thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR”), as amended. The filing...more

BakerHostetler

Rare FTC-DOJ Joint ‘Gun Jumping’ Action Results in Record Penalty

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On January 7, 2025, the FTC and DOJ jointly filed a complaint against XCL, Verdun, and EP concerning an alleged gun-jumping violation. The parties simultaneously filed a proposed final judgment, under which the defendants...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

Hinch Newman LLP

Did Your Company Receive an FTC Warning Letter or Notice of Penalty Offense?

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Has your company received an FTC warning letter or a penalty offense notice? If so, such correspondence should not be ignored because there is a high likelihood that the FTC is in the process of actively and quickly seeking...more

Hinch Newman LLP

Will the FTC Under President-Elect Trump Reject Novel Liability Theories?

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President-elect Donald Trump recently announced that Republican Commissioner Andrew Ferguson will chair the Federal Trade Commission during Mr. Trump’s second administration. Commissioner Ferguson is also a known critic of...more

Klein Moynihan Turco LLP

DNC Demand Letters Are a Serious Matter

As our readers are aware, companies risk substantial penalties for failure to abide by federal Do-Not-Call (“DNC”) regulations. Many DNC lawsuits, that eventually end in judgment or settlement, were preceded by DNC demand...more

Holland & Hart LLP

Open Banking Rules are Finally Here: What's Next for the Financial Services Industry

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On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued its long-anticipated Open Banking Rule (the Open Banking Rule) under Section 1033 of the Dodd-Frank Act, fundamentally reshaping the data-sharing...more

Kohrman Jackson & Krantz LLP

The FTC’s New "Click-to-Cancel" Rule: Simplifying Subscription Cancellations for Consumers

On October 16, 2024, The Federal Trade Commission (FTC) announced a significant update to its regulations governing negative option programs. This new “click to cancel” rule aims to make it easier for consumers to cancel a...more

Foley & Lardner LLP

Private Equity Investments in Oncology: Top Five Things to Know

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Although private equity (PE) sponsors have been active investors in the health care services industry for the last decade, PE-backed health care providers today constitute only 4% of the United States health market by...more

Foley & Lardner LLP

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

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The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

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