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Subscription Services Unfair or Deceptive Trade Practices

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

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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

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

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Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

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Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Sheppard Mullin Richter & Hampton LLP

Lessons from the FTC: The Cleo AI Settlement

The FTC’s settlement with Cleo AI gives some indication as to what we might see from the agency in the coming months. The FTC alleged, among other things, that Cleo AI’s actions violated Section 5 of the FTC Act. In...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...more

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

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This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more

Robinson+Cole Data Privacy + Security Insider

Cleo AI Agrees to $17 Million Settlement with FTC

Sometimes, deals are too good to be true. That was the case for Cleo AI, an online cash advance company that promised consumers fast, up-front cash payments. According to the Federal Trade Commission (FTC), Cleo AI offered...more

Baker Botts L.L.P.

New CMA consumer protection regime in force next week

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A new UK consumer protection regime comes into force on 6 April 2025 through the implementation of the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 2) Regulations 2025 (SI 2025/272) (“the...more

Venable LLP

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

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In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more

Venable LLP

Do You Know Who You’re Paying? FTC Lawsuit Against an Online Bill Pay Platform to Proceed

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On March 21, a federal judge in Washington state denied Doxo Inc.’s motion to dismiss a complaint brought by the Federal Trade Commission (FTC) regarding Doxo’s alleged deceptive advertising practices. ...more

Sheppard Mullin Richter & Hampton LLP

FTC Orders Fintech Company to Pay $17 Million for Allegedly Deceptive Subscription Practices

On March 27, the FTC announced that a fintech company offering cash advances through a mobile app has agreed to pay $17 million to resolve allegations that it violated the FTC Act and the Restore Online Shoppers’ Confidence...more

Venable LLP

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

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Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more

BakerHostetler

FTC Files Brief Fully Supporting Its Click-to-Cancel Rule

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Just prior to the Federal Trade Commission’s (FTC or Commission) publication of its Click-to-Cancel Rule (the Rule) – which we wrote about in depth here – in the Federal Register, several trade associations filed petitions...more

BakerHostetler

Massachusetts Finalizes Junk Fee Regulation

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Earlier this month, Massachusetts issued regulations on two of the hottest areas for consumer protection: junk fees and subscriptions. In this blog post, we address the junk fee requirements....more

Troutman Pepper Locke

Massachusetts AG Campbell Releases “Junk” Fees and Auto-Renewal Regulations

Troutman Pepper Locke on

Massachusetts Attorney General (AG) Andrea Joy Campbell announced Massachusetts’ new consumer protection regulations prohibiting “junk fees” and providing consumers with greater transparency regarding trial and subscription...more

Blake, Cassels & Graydon LLP

B.C. Proposes Consumer Protection Reforms, Aims to Restrict Certain Contract Terms

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

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

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Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more

Fenwick & West LLP

CLE Takeaways: The Risks and Rewards of Recurring Subscriptions

Fenwick & West LLP on

For companies offering subscription-based services, the regulatory landscape is becoming increasingly complex, with recent updates to federal and state laws creating new compliance requirements that demand careful attention...more

Katten Muchin Rosenman LLP

Unsubscribe: What the FTC's "Click-to-Cancel" Rule Means for Retailers and Consumers - The Katten Kattwalk/Kattison Avenue | Issue...

A curated seasonal wardrobe delivered directly to your door, the return to a jam-packed gym, personally proportioned fresh weekly meals, a coffeemaker and a new pair of sneakers shipped within an hour, or a trial run on the...more

Venable LLP

Fast VAST Update: Federal Court Declines to Stay FTC Negative Option Rule During Challenge

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Last Friday in a 2-1 order, the Eighth Circuit Court of Appeals rejected an initial challenge to the Federal Trade Commission’s (FTC) Negative Option Rule. The challengers had asked the court to stay the Rule from taking...more

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

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The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Troutman Pepper Locke

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

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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

Cozen O'Connor

The State AG Report – 12.19.2024

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Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •Illinois AG’s and FTC’s Settlement Takes a $25 Million...more

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