News & Analysis as of

ROSCA Cancellation Rights

Goodwin

FTC’s “Click-to-Cancel” Rule Gets New Life As FTC’s Enforcement Wave Continues to Target Negative-Option Sellers

Goodwin on

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

Hudson Cook, LLP

State Attorneys General Join FTC Suit Against Major Rideshare Company for "Cancel Anytime" Subscription Practices

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Twenty-one states and the District of Columbia have joined an FTC enforcement lawsuit against a major rideshare and food delivery company over its subscription and cancellation practices. The allegations center on the...more

Stradling Yocca Carlson & Rauth

The Subscription Cancellation Gap: Clear State Rules, Vague Federal Standards, and Growing Legal Risk

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

Loeb & Loeb LLP

FTC Scrutiny of Automatic Renewals: What Health & Wellness Companies Should Know

Loeb & Loeb LLP on

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

Goodwin

FTC Settles with Amazon Over Enrollment and Cancellation Processes for Prime Memberships

Goodwin on

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

Wiley Rein LLP

FTC Consumer Protection and Privacy Enforcement Series: Subscription Cancellation Policies Remain a Top FTC Priority

Wiley Rein LLP on

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

Holland & Knight LLP

FTC Steps Up Subscription Enforcement After "Click to Cancel" Rule Struck Down

Holland & Knight LLP on

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

Fisher Phillips

Even Without Click-to-Cancel, the FTC Forces $7.5M Settlement Based on Subscription Violations: What Your Business Should Do

Fisher Phillips on

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

Orrick, Herrington & Sutcliffe LLP

FTC makes ed. tech company pay $7.5M for unlawful cancellation practices

On September 15, the FTC announced it had filed a complaint in the U.S. District Court for the Northern District of California along with a proposed order for permanent injunction and monetary judgment against an educational...more

Kelley Drye & Warren LLP

FTC Announces $7.5 Million Settlement Over Cancellation Practices

In July, the Eighth Circuit vacated the FTC’s ​“Click to Cancel Rule.” At the time, we noted that although the FTC was unlikely to try to resurrect the Rule, they could continue to challenge cancellation practices under other...more

DLA Piper

Click-to-Cancel Lives on Under ROSCA and Section 5

DLA Piper on

The Federal Trade Commission (FTC) has filed a complaint in the Central District of California against Fitness International, LLC and Fitness & Sports Clubs, LLC (together, LA Fitness), alleging unfair and deceptive practices...more

Cozen O'Connor

FTC Sues LA Fitness to Cancel Unfair Membership Cancellation Practices

Cozen O'Connor on

The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more

Troutman Pepper Locke

FTC Orders Match Group to Pay $14M Over Alleged Deceptive Subscription Practices and Guarantee Claims

Troutman Pepper Locke on

On August 12, the Federal Trade Commission (FTC) ordered Match Group, owners and operators of online dating platforms such as Match.com, OkCupid, PlentyOfFish, The League, and others, to pay $14 million. This settlement...more

Hudson Cook, LLP

FTC Sues Large Gym Chain over Cancellation Policies

Hudson Cook, LLP on

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

WilmerHale

Eighth Circuit Vacates the FTC's Click to Cancel Rule, but Federal and State Regulators Likely to Remain Active

WilmerHale on

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

BakerHostetler

Negative Option Rule No More: How To Comply in the Wake of the Eighth Circuit’s Decision

BakerHostetler on

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

BakerHostetler

Eighth Circuit Clicked to Cancel the FTC’s Negative Option Rule

BakerHostetler on

Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

BakerHostetler on

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

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 and Illinois Attorney General Settle with Grubhub for Deceptive Practices

Venable LLP on

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

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?

Womble Bond Dickinson on

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

Kilpatrick

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

Kilpatrick on

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

Wiley Rein LLP on

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

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

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