News & Analysis as of

ROSCA Unfair or Deceptive Trade Practices Consumer Protection Laws

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

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

Troutman Pepper Locke on

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

Venable LLP on

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.

BakerHostetler on

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

Hudson Cook, LLP

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

Hudson Cook, LLP on

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)

Wiley Rein LLP on

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

Hudson Cook, LLP on

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)

Wiley Rein LLP on

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

Venable LLP

FTC’s Melissa Holyoak Outlines Consumer Protection Focus at ANA Advertising Law Conference

Venable LLP on

In her remarks at this year’s ANA Masters of Advertising Law Conference, Commissioner Melissa Holyoak of the Federal Trade Commission (FTC) emphasized three areas where the agency is focusing its consumer protection...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

Hudson Cook, LLP

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

Hudson Cook, LLP on

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

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

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

Hinch Newman LLP

FTC Announces Historic $2.5 Billion Settlement With Amazon

Hinch Newman LLP on

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

Benesch

A Dozen New Lawsuits and Two $7.5M Settlements Signal a New Era for Automatic Renewal Compliance

Benesch on

A recent surge in lawsuits — and two separate $7.5 million settlements — highlights increased enforcement of automatic renewal laws, with both private plaintiffs and government agencies bringing actions for alleged violations...more

Hudson Cook, LLP

FTC Announces Settlement with Education Technology Provider Over Subscription Cancellation Practices

Hudson Cook, LLP on

The Federal Trade Commission announced a settlement with an education technology provider alleged to have violated the Restore Online Shoppers' Confidence Act (ROSCA) by failing to provide consumers with a simple mechanism to...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

Troutman Pepper Locke

Paddle's Payment Predicament: Unpacking FTC's Compliance Crackdown — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, hosts Keith Barnett and Carlin McCrory examine the recent $5 million settlement between the Federal Trade Commission (FTC) and Paddle.com, a UK-based payment processor. The discussion centers...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

Alston & Bird

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

Alston & Bird on

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

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

Goodwin

FTC Settles with UK-Based Payment Processor Over Alleged Tech Support Scams

Goodwin on

​​​​​​​On June 16, 2025, the FTC announced ​it had reached a settlement ​with a UK-based payment processor, resolving allegations that the company facilitated deceptive tech-support schemes by processing payments for...more

Venable LLP

FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

Venable LLP on

In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...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

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