Payments Year in Review 2025: Federal and State Developments – Part 1 — Payments Pros – The Payments Law Podcast
12 Days of Regulatory Insights: Day 10 – State AGs on Pricing and Renewals — Regulatory Oversight Podcast
Paddle's Payment Predicament: Unpacking FTC's Compliance Crackdown — Payments Pros – The Payments Law Podcast
No company wants a lawsuit or civil investigative demand over their autorenewal practices. And settling a case for millions or billions of dollars is even worse. In 2025, negative options and subscription offers became one of...more
The Federal Trade Commission (FTC) is increasingly directing both its enforcement and rulemaking efforts toward auto-renewal programs, with a particular focus on burdensome or opaque cancellation procedures. ...more
Two weeks into the new year, the Federal Trade Commission (“FTC”) sued JustAnswer LLC and its CEO (together, “JustAnswer”), alleging they deceived consumers into enrolling in monthly recurring subscriptions without obtaining...more
The Federal Trade Commission (FTC) has sued JustAnswer LLC and its founder and CEO, Andrew Kurtzig, alleging that the online Q&A platform deceives consumers into costly recurring subscriptions without their informed consent,...more
In this article, we share a timeline of monthly "bites" for 2025 applicable to automatic renewal, click to cancel, lease to own, and subscription transactions. The CFPB spent 2025 walking back much of the guidance and actions...more
Automatic renewals, more commonly referred to as subscription services, have become a household topic (or maybe just in ours?) of advertising law enforcement. Subscription services – from streaming platforms to meal kits –...more
In 2025, we’ve seen new and updated automatic renewal laws (ARLs) and regulations in many states, including Arkansas, California, Colorado, Connecticut, Maryland, Massachusetts, Minnesota, and Utah. These laws regulate...more
The Federal Trade Commission (FTC) has made clear that youth-focused social apps are a priority. On September 27, the FTC filed a complaint in the Central District of California against Iconic Hearts Holdings, the company...more
Anyone who’s tried to cancel a gym membership, a digital subscription, or an auto-renewing trial knows the feeling: buried links, print-and-mail forms, long hold times. Some apps simply won’t let go....more
Earlier this summer, the Federal Trade Commission’s (FTC’s) “click-to-cancel” rule was overturned by the U.S. Court of Appeals for the Eighth Circuit, just days before the new rule was set to go into effect. According to the...more
On September 25, 2025, the Federal Trade Commission announced it had reached a settlement with Amazon.com, Inc. and two company executives, resolving allegations that the company’s enrollment and cancellation processes for...more
When the FTC’s “Click to Cancel” Rule (otherwise known as the revised Negative Option Rule), was in litigation in July 2025, we predicted the FTC was likely to instead focus on enforcing the Restore Online Shoppers Confidence...more
The Federal Trade Commission yesterday announced a bombshell $2.5 billion settlement in its lawsuit with Amazon regarding what the FTC alleged were unfair practices relating to Amazon’s Prime subscription product; this...more
Despite the demise of the Federal Trade Commission's (FTC) "Click to Cancel" Rule in July 2025, the FTC continues to actively define new standards for lawful subscription practices. The FTC's recent lawsuits and settlements...more
On September 25, 2025, the Federal Trade Commission announced that it has secured “a historic order” with Amazon.com, Inc., as well as a Senior Vice President and Vice President, settling allegations that Amazon enrolled...more
The Federal Trade Commission (FTC) has entered into a settlement with Chegg, Inc., requiring the ed-tech provider to pay $7.5 million to resolve claims that it violated both the FTC Act and the Restore Online Shoppers'...more
A recent surge in lawsuits — and two separate $7.5 million settlements — highlights increased enforcement of automatic renewal laws, with both private plaintiffs and government agencies bringing actions for alleged violations...more
The FTC just announced a $7.5 million settlement with an educational technology company over its unlawful cancellation practices, sending a warning to all businesses that offer subscription-based offerings. Even though a...more
On August 20, 2025, the FTC filed a complaint in the U.S. District Court for the Central District of California, alleging that the Gym violated the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA). The FTC's...more
On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) “Click to Cancel” Rule....more
The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more
As promised in last week’s blog that covered the Eighth Circuit’s decision to vacate the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule), we are back with some practical insights on and...more
The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more
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
In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more