News & Analysis as of

ROSCA Disclosure Requirements

Hinshaw & Culbertson - Consumer Crossroads

Ask and You Shall Receive a Recurring Subscription: FTC Sues a Web Q&A Service for Deceptive Negative Option

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

Troutman Pepper Locke

FTC Sues JustAnswer Over Allegedly Deceptive Subscription Practices

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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

Venable LLP

FTC Lawsuit Targets JustAnswer for Alleged ROSCA and Subscription Disclosure Violations

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Last week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against JustAnswer LLC and its CEO, arising from the company’s subscription program. According to the complaint, JustAnswer operates an online...more

BakerHostetler

Wondering if the FTC Is Moving Away from ROSCA Enforcement? We Have Our (Just)Answer.

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Although many New Year’s resolutions lose momentum by February (guilty!), the FTC’s commitment to Restore Online Shoppers’ Confidence Act (ROSCA) enforcement shows no signs of slowing....more

Kelley Drye & Warren LLP

Ad Law News and Views - December 2025

Partner Gonzalo Mon wrote ​“A Look At The Wave Of 2025 Email Marketing Suits in Wash.” published by Law360. The article details a 2025 decision by the Washington State Supreme Court that focused on the scope of Washington’s...more

BakerHostetler

Staying Ahead of Enforcement: Practical Compliance with Automatic Renewal Laws

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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

Wiley Rein LLP

Automatic Renewals and Risks: State Negative Option Laws and Enforcement Are Trending

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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

Loeb & Loeb LLP

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

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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

Holland & Knight LLP

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

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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

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

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

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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

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

Benesch on

Notwithstanding significant changes at the Federal Trade Commission (FTC) – including the removal of two of the five Commissioners, and the new appointment of Commissioner Mark Meador – the Commission has sent a clear message...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

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

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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

Venable LLP

Do You Know Who You’re Paying? FTC Lawsuit Against an Online Bill Pay Platform to Proceed

Venable LLP on

On March 21, a federal judge in Washington state denied Doxo Inc.’s motion to dismiss a complaint brought by the Federal Trade Commission (FTC) regarding Doxo’s alleged deceptive advertising practices. ...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

Venable LLP

Is Your New Year’s Resolution to Comply with Automatic Renewal Laws? If So, Look No Further

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The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more

BakerHostetler

The Latest FTC Policy Statement Sets Its Sights on Negative Option Marketing

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Policy statements are neither rules nor notices of penalty offenses, but when the FTC issues a policy statement discussing an area that has been the subject of a lot of enforcement activity, it warrants serious attention,...more

Kelley Drye & Warren LLP

FTC to Increase Enforcement on Subscription Services

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Earlier today, the FTC issued a policy statement warning marketers against using “dark patterns” to trick or trap consumers into subscription services. The statement is primarily intended to assist marketers by providing...more

Fox Rothschild LLP

FTC Finalizes Sending Refund Checks To Consumers Allegedly Deceived By Subscription Snack Service

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The Federal Trade Commission (“FTC”) recently sent out settlement checks to consumers who were allegedly deceived by UrthBox, Inc. While the settlement, $100,000, and the amount refunded, around $84,000, were not very high,...more

Perkins Coie

Hot Ad Law Topics for the New Year

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Don’t let the new year be ruined by U.S. class actions, regulatory enforcement actions, or competitor claims. Here are five ad law takeaways for brand and legal teams to consider as 2019 approaches....more

BCLP

Subscription-Based Business Models: An Overview of Auto-Renewal Regulations

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The demand for subscription-based and recurring revenue business models is growing faster than ever. According to a 2014 report by The Economist Intelligence Unit, 80 percent of customers are demanding new consumption models...more

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