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ROSCA Enforcement Actions

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

Clark Hill PLC

Right To Know - January 2026, Vol. 37

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Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed....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

Wilson Sonsini Goodrich & Rosati

2026 Year in Preview: Regulatory Consumer Protection Trends for Companies to Watch Out For

As we ring in the new year, we want to make you aware of key issues affecting consumers that we expect lawmakers and regulators to focus on over the next 12 months. Below are the top transatlantic consumer protection issues...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Automatic Renewals, Click-to-Cancel, and Subscriptions

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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

Wiley Rein LLP

Wiley Consumer Protection Download (January 6, 2026)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Federal Trade Commission (FTC), the Consumer Financial Protection Bureau (CFPB), and the state level. Check out our new State...more

BakerHostetler

[Podcast] AD Nauseam: From AI to ROSCA – Dissecting 2025’s Biggest FTC Actions

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On today’s episode of AD Nauseam, Amy and Daniel close out 2025 with a fast‑paced look at the FTC’s most pivotal shifts—from major leadership changes to rulemaking shakeups and the year’s most consequential enforcement...more

Venable LLP

Industry Groups Urge FTC to Revive Click-to-Cancel Rulemaking on Subscription and Negative Option Plans

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Last month, two association groups, the Consumer Federation of America (CFA) and the American Economic Liberties Project (AELP), submitted a Petition for Renewed Click to Cancel Rulemaking attempting to restart the Federal...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

Wiley Rein LLP

Wiley Consumer Protection Download (December 16, 2025)

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Bipartisan Group of 42 AGs Send Letter to Technology Companies Regarding AI Chatbot Features. On December 9, the National Association for Attorneys General (NAAG) sent a letter, signed by 42 Attorneys General (AGs), to...more

Troutman Pepper Locke

12 Days of Regulatory Insights: Day 10 – State AGs on Pricing and Renewals — Regulatory Oversight Podcast

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In this episode of our special 12 Days of Regulatory Insights podcast series, RISE attorney Nam Kang welcomes Partners Clay Friedman and Mike Yaghi for a practical look at 2025 regulatory enforcement trends in advertising and...more

Kelley Drye & Warren LLP

FTC Quietly Reopens Click to Cancel Rulemaking in Response to Petition

In July, the Eighth Circuit vacated the FTC’s “Click to Cancel Rule.” Since then, the FTC has continued to challenge cancellation practices under other authority....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

Orrick, Herrington & Sutcliffe LLP

Amazon Ruling Marks New Era of Personal Liability for Execs

A Sept. 17 summary judgment decision in Federal Trade Commission v. Amazon.com Inc. from the U.S. District Court for the Western District of Washington, in finding that two Amazon executives could be personally liable for...more

Hudson Cook, LLP

FTC's Consumer Finance Pivot Brings Industry Pros And Cons

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The first nine months of the new Trump administration have dramatically affected the regulation and oversight of the consumer financial industry. The Consumer Financial Protection Bureau's new leadership moved swiftly to...more

DLA Piper

DOJ Announces Creation of Enforcement & Affirmative Litigation Branch

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The United States Department of Justice (DOJ) recently announced the creation of the Enforcement & Affirmative Litigation Branch within the Department’s Civil Division....more

Perkins Coie

Lessons From the FTC’s First Privacy Enforcement Actions During Trump 2.0

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The Federal Trade Commission (FTC) recently announced its first privacy enforcement actions of the second Trump administration with a flurry of activity in September....more

Wiley Rein LLP

Wiley Consumer Protection Download (October 7, 2025)

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FTC Seeks Comment on Proposed Strategic Plan. On September 26, the FTC announced that it is seeking public comment on the agency’s Draft Strategic Plan for Fiscal Years 2026-2030. The FTC’s strategic plan is updated every...more

Alston & Bird

FTC Reaches Record $2.5 Billion Settlement with Amazon over Prime Subscription Practices

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The Federal Trade Commission (FTC) reached a $2.5 billion settlement with Amazon over its Prime membership subscription and cancellation practices. Our Consumer Protection/FTC Team highlights what companies should know about...more

Alston & Bird

FTC Cracks Down on Messaging App Operator on Child Data Exploitation

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Sendit is an anonymous messaging app integrated with platforms like Snapchat, Instagram, and X (formerly Twitter), and is widely used by children and teens. According to the complaint, the app unlawfully collected personal...more

Katten Muchin Rosenman LLP

FTC’s Landmark $2.5 Billion Amazon Settlement Highlights Ongoing Focus on “Dark Patterns”

Updated 9/30/2025 - Three days into trial, Amazon agreed to pay $2.5 billion to settle a Federal Trade Commission lawsuit alleging that the company misled millions of consumers into subscribing to Amazon Prime and then...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

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