News & Analysis as of

Subscription Services Unfair or Deceptive Trade Practices Disclosure Requirements

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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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

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....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

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

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

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

Venable LLP

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

Venable LLP on

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

Massachusetts Finalizes Junk Fee Regulation

BakerHostetler on

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

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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

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

Foley & Lardner LLP

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

Foley & Lardner LLP on

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

Davis Wright Tremaine LLP

Stay ADvised: Brand Protection & Advertising Law News - August 2023 - 2

Kardashian Kopycat? Energy Drink Company Claims Competitor Stole Kim's Copyrighted Look - The Instagram posts look nearly identical, in a blink-and-you'll-miss-the-difference kind of way—or so says the complaint filed by...more

McDermott Will & Emery

How the FTC’s Proposed Rule Could Affect Your Business

McDermott Will & Emery on

In March 2023, the Federal Trade Commission (FTC) proposed tightened requirements on the Negative Option Rule in an effort to combat unfair or deceptive practices such as recurring charges for products or services that...more

WilmerHale

FTC Issues New Dark Pattern Guidance

WilmerHale on

On September 15, 2022, the Federal Trade Commission (FTC) released a report on dark patterns (the, “Report”) that identifies the types of misleading and manipulative interface practices that the agency believes can harm...more

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