News & Analysis as of

ROSCA Negative Option Rule

Venable LLP

[Webinar] How Subscription Offers Have Become One of the Hottest Areas of Challenge in 2026 - February 26th, 2:00 pm - 3:00 pm ET

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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

Goodwin

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

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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

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

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

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

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

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

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

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

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

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

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

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

Fisher Phillips

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

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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

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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

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