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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
On September 25, 2024, the Federal Trade Commission (FTC) announced the launch of “Operation AI Comply,” an initiative created to tackle unfair and deceptive business practices involving the use of artificial intelligence...more
On September 17, the FTC announced that the U.S. District Court for the Middle District of Florida approved the Commission’s order, effectively shutting down several companies named in the FTC’s June complaint and required...more
Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more
In a lengthy ruling, a Seattle federal judge has allowed the Federal Trade Commission (FTC) to proceed with its groundbreaking case alleging that Amazon’s Prime online subscription marketing tactics constituted deceptive...more
In this episode of his "Clearly Conspicuous" podcast series, "The FTC Takes Action Against the Amazon Prime Program," consumer protection attorney Anthony DiResta examines the recent actions that the Federal Trade Commission...more
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
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
The Federal Trade Commission (FTC) last week filed a civil case against Amazon alleging that the company used “manipulative, coercive, or deceptive user-interface designs known as ‘dark patterns’ to trick consumers into...more
Risk management personnel who underwrite e-commerce merchants should have some basic understanding of the types of online merchant marketing and sales practices that are deceptive and misleading....more
The FTC has issued a new Enforcement Policy Statement Regarding Negative Option Marketing (Policy Statement), generally warning companies about their compliance obligations relating to negative option programs and against...more
On October 28, 2021, the FTC issued an enforcement policy statement warning companies against utilizing illegal dark patterns that trick or trap consumers into subscription services. Dark patterns apply deceptive techniques...more