News & Analysis as of

Section 5 Subscription Services

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

Goodwin

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

Goodwin on

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

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

Foster Garvey PC

FTC Escalates Enforcement Against Cancellation Policies Utilized with Subscription Product Orders

Foster Garvey PC on

The Federal Trade Commission (“FTC”) has increased its campaign against businesses that impose unreasonable barriers to consumer cancellation of memberships and subscriptions. Recent actions demonstrate the agency’s intent to...more

DLA Piper

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

DLA Piper on

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

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

Winstead PC

8th Circuit Vacates FTC’s “Click to Cancel Rule”

Winstead PC on

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...more

Troutman Pepper Locke

FTC and Illinois AG Settle Matter Against Grubhub for $140M

Troutman Pepper Locke on

On December 17, 2024, the Federal Trade Commission (FTC) and Illinois Attorney General (AG) Kwame Raoul settled their lawsuit against Grubhub for $140 million (Grubhub will only have to pay $25 million, with the balance...more

WilmerHale

FTC Targets "Dark Patterns" in Actions Against Amazon and Publishers Clearing House

WilmerHale on

The Federal Trade Commission (FTC) in recent years has made clear its intention to adopt a more aggressive enforcement posture toward so-called dark patterns. The FTC defines unlawful dark patterns to include any online...more

Ballard Spahr LLP

FTC settles lawsuit against Publishers Clearing House involving alleged use of “dark patterns”

Ballard Spahr LLP on

Less than a week after announcing that it had filed a civil case against Amazon alleging that the company used “dark patterns” to enroll people in its Prime program, the FTC announced that it has entered into a settlement...more

Venable LLP

Compliance Deadline Approaching: Amendments to California's Autorenewal Law Take Effect in July

Venable LLP on

On July 1, new requirements under California's automatic renewal will take effect. As we previously blogged, the amendments will require businesses to make it even easier for consumers to cancel and impose new requirements on...more

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