News & Analysis as of

Subscription Services Comment Period

Holland & Knight LLP

It's Simple to "Click to Cancel"

Holland & Knight LLP on

The Federal Trade Commission (FTC) has proposed several amendments to the current Negative Option Rule (Rule) that, if enacted, will drastically change how subscription- and membership-based businesses operate. Generally, the...more

Manatt, Phelps & Phillips, LLP

FTC Proposal Restricts Health Tech and Digital Health Companies’ Use of Auto-Renewal Provisions

Many health tech and digital health companies offer subscription or membership services to clients and patients on an auto-renewal basis. Under this model, a subscriber’s credit card is automatically charged on a monthly,...more

Venable LLP

The FTC's Proposed "Rule Concerning Recurring Subscriptions and Negative Options": Improving Regulations or Interfering with...

Venable LLP on

Payment service providers should take note of an expansive new rule proposed by the Federal Trade Commission (FTC) intended to protect consumer shoppers of goods and services sold on a subscription basis. For merchants...more

Venable LLP

Click to Cancel: FTC Proposes New Rule Regulating Subscription Services and Negative Option Programs with Broad Implications

Venable LLP on

Last week, the Federal Trade Commission announced that its proposed rule replacing its Prenotification Negative Option Rule would result in new, expansive requirements for all forms of negative option offers, including...more

Sheppard Mullin Richter & Hampton LLP

FTC Increases Scrutiny of Negative Option Marketing

Retailers and service providers should take note: the Federal Trade Commission (FTC) is increasing its scrutiny of negative option marketing activity to combat unfair or deceptive practices related to subscriptions,...more

Eversheds Sutherland (US) LLP

Texas Comptroller finally gets serious; proposes amendments to franchise tax sourcing in light of Sirius XM 

The Texas Comptroller of Public Accounts (the Comptroller) published proposed amendments to Texas’ franchise tax apportionment rule in the January 20 issue of the Texas Register, discarding the now-repudiated...more

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