Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
The FTC Takes Action Against the Amazon Prime Program
AD Nauseam: Negative Options – From Wine, to Cookies, to Gyms – Everything You Need to Know
Podcast - The FTC's Click to Cancel Proposal
Autorenewals - The Crypto Exchange Podcast
Recent enforcement actions underscore the growing risks for businesses with automatically renewing subscriptions. In June 2025, New York Attorney General Letitia James announced a $600,000 settlement with fitness company...more
Companies selling subscriptions have been busy navigating compliance with the Federal Trade Commission’s Negative Option Rule, which is scheduled to go into effect July 14. But when it rains, it pours....more
On May 9, 2025, New York Governor Kathy Hochul signed a large budget bill with “major components of legislation necessary to implement the state transportation, economic development, and environmental conservation budget for...more
Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more
New York AG Letitia James entered into a settlement with Equinox Group, LLC (Equinox Group), which operates fitness services under Equinox, Equinox+, and SoulCycle, resolving allegations that its subscription and cancellation...more
From streaming services and gym memberships to software vendor agreements and e-commerce franchises, automatic contract renewals are common occurrences. Currently, California law protects consumers regarding automatic renewal...more
The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more
Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more
Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more
Our Consumer Protection/FTC Team notes that the Federal Trade Commission extended the compliance deadline of the Negative Option Rule (better known as the Click-to-Cancel Rule) by 60 days....more
Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more
A recent Ninth Circuit decision, Chabolla v. ClassPass, Inc., underscores critical considerations for retailers with online Terms of Service / Use agreements, particularly regarding arbitration provisions and related consumer...more
On February 25, 2025, the British Columbia government introduced Bill 4, the Business Practices and Consumer Protection Amendment Act, 2025 (Bill) for the stated purpose of protecting people from “unfair contract terms” and...more
Stronger consumer protections demand compliance or face penalties - Why should I read this? Subscription contracts, common in digital markets, have faced criticism as many consumers forget to cancel their free trials and...more
Two decisions from earlier this year illustrate the difficulty in enforcing terms of service (TOS) amendments against former subscribers or customers. Even when a company provides the former subscriber with notice of the TOS...more
In our last update on the Digital Markets Competition and Consumer Act (DMCC Act), we outlined some of the key consumer protection enhancements set to come into force in the UK. In particular, the DMCC Act sets out new rules...more
Ahead of the implementation of the new subscription contract regime set out in the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”), which is due to come into force during 2026, the UK Government is consulting on...more
The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more
If it’s been a while since you’ve looked at the state and federal laws governing autorenewals, subscriptions, and continuous service offers, your business is likely in need of an update. Multiple jurisdictions, on both state...more
California Continues to Tighten and Expand Automatic Renewal Law with New Restrictions Taking Effect July 1, 2025 On September 24, 2024, Governor Gavin Newsom signed into law Assembly Bill No. 2863, which amends California’s...more
This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more
Automatic renewals continue to be a big priority for state regulators. When companies work to develop strategies to comply with the growing patchwork of specific state laws in this area, they often start by looking at...more
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has recently received royal assent, following the announcement of the July General Election. We examine the key developments in our previous article. One very...more
Fund-level subscription-secured revolving lines of credit are a well-established instrument in the toolkits of a variety of private equity fund sponsors and managers, including for venture capital funds, hedge funds, debt...more
There are many basic contracting principles that can help streamline and create a readable and clear contract, including the proper use of defined terms. Consistent with the phrase, a defined term is a word or term, often...more