News & Analysis as of

ROSCA FTC Act

BakerHostetler

FTC Signals Restart on Negative Option Rulemaking

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In July 2025, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule, which was set to go into effect that month. You can find more details in our blog post on that decision, but, in short, the...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

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

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

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

Morrison & Foerster LLP - Social Media

Social Links: Darkness on the Edge of Town

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

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

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

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

Goodwin

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

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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

Hudson Cook, LLP

FTC Announced $2.5 Billion Settlement Against Large Online Retailer over Deceptive Subscription and Cancellation Practices

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On September 25, 2025, the FTC announced a settlement with a large online retailer, requiring the company to pay a $1 billion civil penalty and provide $1.5 billion in consumer restitution. ...more

Wiley Rein LLP

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

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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

Nelson Mullins Riley & Scarborough LLP

Click-to-Cancel is (Mostly*) Dead, But Amazon Settlement Proves Enforcement Lives On

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

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

Hinch Newman LLP

FTC Announces Historic $2.5 Billion Settlement With Amazon

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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

Hogan Lovells

FTC orders Chegg to pay $7.5 million over subscription cancellation practices

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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

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

DLA Piper

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

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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

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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

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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

Alston & Bird

FTC Enforcement of Cancellation Practices Continues After Click-to-Cancel Rule Defeated

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Our Consumer Protection/FTC Team examines how the FTC continues to actively pursue companies with allegedly complicated cancellation practices by relying on existing legal authority despite setbacks to the Click-to-Cancel...more

Hudson Cook, LLP

FTC Sues Large Gym Chain over Cancellation Policies

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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

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