News & Analysis as of

ROSCA

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

Goodwin

FTC Files Suit Against Online Cash Advance Provider for Allegedly Deceptive and Misleading Conduct

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On November 5, 2024, the FTC announced​ that it had filed suit against a California-based online cash advance provider for allegedly deceptive and misleading advertisements and representations, in violation of the FTC Act, 15...more

BCLP

Are You Preparing to Comply with the FTC “Click-to-Cancel” Rule?

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The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more

Womble Bond Dickinson

New Click-to-Cancel Requirements… Welcome/Not Welcome?

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The Federal Trade Commission (FTC) announced its long-awaited final Negative Option Rule (the “Rule”) on October 16, 2024. “Negative Options” according to the FTC are arrangements “under which the consumer’s silence or...more

Sheppard Mullin Richter & Hampton LLP

FTC Takes Aim at Mobile Banking App for Deceptive Advertising Practices

On November 5, the Federal Trade Commission (“FTC”) filed a complaint against a company in connection with its mobile banking app, alleging violations of Section 5(a) of the FTC Act and Section 4 of the Restore Online...more

Kilpatrick

The FTC Expands its Negative Option Rule to Reach Autorenewal and Other Programs

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For companies who offer recurring subscriptions, it is important for them to understand the Federal Trade Commission’s recently finalized rule applicable to negative option marketing that requires such companies to make the...more

Wiley Rein LLP

FTC Adopts Final “Click-to-Cancel” Rule with Requirements for Recurring Subscriptions

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On October 16, 2024, the Federal Trade Commission (FTC or Commission) announced its adoption of a final “click-to-cancel” Rule that regulates both sign-up and cancellation processes for subscriptions or other recurring...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

Venable LLP

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

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Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more

Orrick, Herrington & Sutcliffe LLP

FTC takes action against an online care services platform with an $8.5M fine

On August 26, the FTC released its complaint and stipulated order against an online platform offering child and senior care services, alleging violations of the FTC Act and the Restore Online Shoppers’ Confidence Act. The FTC...more

Perkins Coie

FTC Order Bans Anonymous Messaging App from Serving Minors

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The Federal Trade Commission (FTC) and the Los Angeles County District Attorney on July 9, 2024, announced a complaint and proposed stipulated order against NGL Labs, LLC, and two NGL co-founders concerning the “NGL: ask me...more

Clark Hill PLC

Children’s Data Update: From FTC and State Agency Enforcement to KOSA Advancing the Senate

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On July 7, the FTC and the Los Angeles District Attorney’s Office filed a complaint in the United States District Court for the Central District of California against the developer of an anonymous messaging app (NGL Labs,...more

Dechert LLP

Dechert Cyber Bits - Issue 59

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U.S. Court Axes Most of SEC's SolarWinds Data Breach Suit - The U.S. District Court for the Southern District of New York recently dismissed much of the U.S. Securities and Exchange Commission’s (“SEC”) suit against...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 16, 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

Cooley LLP

FTC Continues Aggressive ROSCA Enforcement Agenda Against Negative Option Sellers

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In June 2024, the US Federal Trade Commission (FTC) and the Department of Justice jointly filed a complaint under the Restore Online Shoppers’ Confidence Act (ROSCA) in the US District Court for the Northern District of...more

Moritt Hock & Hamroff LLP

FTC Accuses Adobe Of Manipulating Customers Into Costly Subscriptions

Customers worldwide use Acrobat, Photoshop, Illustrator and other Adobe software to create content and manipulate images. Now, the Federal Trade Commission (FTC) is accusing Adobe of manipulating customers into subscription...more

Venable LLP

The Loper Bright Impact: Agency Action Likely to Face More Scrutiny in Light of the Supreme Court’s Disposal of Chevron Deference

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These days, it seems like there are three guarantees in life—death, taxes, and monumental Supreme Court administrative law opinions in the summer. As you’ve probably heard by now, the trend continues this year, including...more

BakerHostetler

FTC Concerns over Marketing to Kids - It’s Not Just About COPPA Anymore

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The Federal Trade Commission (FTC or Commission) has signaled for some time that while the Children’s Online Privacy Protection Act (COPPA) is limited to children under the age of 13, it also has concerns about the...more

BakerHostetler

The Chevron Decision Will Create Some Challenges for FTC Law Enforcement and Rulemaking

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It was certainly a memorable final week for the Supreme Court this term. There has been quite a lot to digest, and the impact and implications are broad and significant. But for now, let’s look through a narrow lens and focus...more

Orrick, Herrington & Sutcliffe LLP

FTC refers ROSCA case against software company and executives to DOJ

On June 17, the FTC announced an enforcement action against a software company and two of its executives for its practices related to its subscription model. According to the redacted complaint filed by the DOJ (upon referral...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

BakerHostetler

[Podcast] AD Nauseam: Movie Pass – I Am Big. It’s the Pictures that Got Small.

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On today’s episode of Ad Nauseam Amy and Daniel talk about the FTC’s case against MoviePass and a recent HBO documentary called MoviePass Movie Crash....more

Venable LLP

The Federal Trade Commission's Enforcement Trends under the Restore Online Shoppers' Confidence Act: A Fast VAST Update

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The Federal Trade Commission (FTC) has made clear its focus on automatic renewal programs with high-profile lawsuits in recent weeks, alleging violations of the Restore Online Shoppers' Confidence Act (ROSCA). Below are some...more

Hinch Newman LLP

Whoa! U.S. Lawsuit Against Telehealth Providers and Executives Should Turn Heads

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On June 10, 2024, the U.S. Justice Department announced that together with the Federal Trade Commission, it filed an amended complaint against telehealth company Cerebral Inc., Cerebral’s founder and former Chief Executive...more

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