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Sheppard Mullin Richter & Hampton LLP

Renewal Revolution: Compliance With FTC’s “Click to Cancel” Rule

On October 16, 2024, the Federal Trade Commission (FTC) issued a new rule, referred to as the “Click to Cancel” rule, which is intended to make it easier for consumers to cancel recurring subscriptions and memberships....more

Womble Bond Dickinson

New Click-to-Cancel Requirements… Welcome/Not Welcome?

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The Federal Trade Commission (FTC) announced its long-awaited final Negative Option Rule (the “Rule”) on October 16, 2024. “Negative Options” according to the FTC are arrangements “under which the consumer’s silence or...more

DLA Piper

Preparing for (More) Updates to California’s Automatic Renewal Law

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California has passed additional amendments to its Automatic Renewal Law (ARL), which will further strengthen that law’s already stringent requirements and likely present increased class action risk....more

Bass, Berry & Sims PLC

FTC Releases “Click to Cancel” Rule

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On October 16, the Federal Trade Commission (FTC) released the final version of its Rule Concerning Recurring Subscriptions and Other Negative Option Programs (Rule), which requires sellers of products and services to receive...more

Perkins Coie

FTC Finalizes “Click To Cancel” Rule With Substantial Requirements for Recurring Subscription Programs

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The Federal Trade Commission (FTC) announced its final Negative Option Rule (the Rule)—which the FTC often refers to as the “Click to Cancel” rule—for automatically renewing subscriptions, free trials that convert to paid...more

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

Katten Muchin Rosenman LLP

Cancel Culture - Kattison Avenue | Issue 13

The FTC's new rule makes it easier for consumers to cancel subscriptions and memberships they no longer want. The Federal Trade Commission (FTC) introduced a "click-to-cancel" rule on October 16, amending the 1973...more

Brownstein Hyatt Farber Schreck

FTC Finalizes “Click-to-Cancel” Rule Making It Easier for Consumers to Cancel Subscriptions

On Oct. 16, the Federal Trade Commission (FTC) voted 3-2 to finalize its “click-to-cancel” rule that will introduce new requirements to simplify the cancellation process for consumers wishing to terminate their subscriptions...more

Troutman Pepper Locke

FTC Adopts “Click-to-Cancel” Amendments to Its Negative Option Rule

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On October 16, the Federal Trade Commission announced final “click-to-cancel” amendments to its Negative Option Rule. Under the FTC’s amended Negative Option Rule...more

Morgan Lewis

FTC ‘Click-to-Cancel’ Rule Requires Canceling Recurring Charges to Be as Easy as Signing Up

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The Federal Trade Commission (FTC) recently issued its Final Rule requiring businesses subject to its authority to establish equivalency between the ease of signing up and canceling subscriptions, memberships, and other...more

Klein Moynihan Turco LLP

FTC Finalizes Subscription Renewal Rulemaking

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On October 16, 2024, the Federal Trade Commission (“FTC”) announced its final rules applicable to recurring subscription plans. According to the FTC, these rules were implemented to make it easier for consumers to stop paying...more

Wiley Rein LLP

FTC Adopts Final “Click-to-Cancel” Rule with Requirements for Recurring Subscriptions

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On October 16, 2024, the Federal Trade Commission (FTC or Commission) announced its adoption of a final “click-to-cancel” Rule that regulates both sign-up and cancellation processes for subscriptions or other recurring...more

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

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On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

BakerHostetler

What the FTC’s New ‘Click-to-Cancel Rule’ Means for Your Business

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The Federal Trade Commission (FTC) finally released its long-awaited Negative Option Rule (the Final Rule), aka the “Click-to-Cancel Rule,” on October 16. The Final Rule was approved by a partisan vote of 3-2, with the two...more

Wilson Sonsini Goodrich & Rosati

Subscription and Auto-Renew Offerings Face New Hurdles: FTC Issues Broad “Click-to-Cancel” Rule Imposing Nationwide Requirements

Companies that automatically renew customers’ subscriptions or memberships, take note. On October 16, 2024, the Federal Trade Commission (FTC) announced sweeping amendments to the Negative Option Rule, which would apply to a...more

Venable LLP

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

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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

BakerHostetler

[Podcast] AD Nauseam: Movie Pass – I Am Big. It’s the Pictures that Got Small.

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On today’s episode of Ad Nauseam Amy and Daniel talk about the FTC’s case against MoviePass and a recent HBO documentary called MoviePass Movie Crash....more

Venable LLP

The Federal Trade Commission's Enforcement Trends under the Restore Online Shoppers' Confidence Act: A Fast VAST Update

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The Federal Trade Commission (FTC) has made clear its focus on automatic renewal programs with high-profile lawsuits in recent weeks, alleging violations of the Restore Online Shoppers' Confidence Act (ROSCA). Below are some...more

Venable LLP

Negative Option and Continuity Marketing: An Excerpt from the Advertising Law Tool Kit

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The Federal Trade Commission (FTC), state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers. Negative option marketing can include pre-notification negative option...more

Venable LLP

Is a Checkbox Required to Obtain Consent to Subscription Programs?

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If you are a subscription marketer, you have likely heard the buzz about the Federal Trade Commission's Notice of Proposed Rulemaking (NPRM) concerning the Negative Option Rule. If implemented, the proposed rule would impact...more

BCLP

What the FTC’s Proposed Expansion of its Enforcement Powers over Autorenewal Subscription Programs Means for Your Business

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On March 23, the Federal Trade Commission announced proposed changes to its Negative Option Rule. This latest announcement appears to be another move by the Commission in its recent flurry of activities to ramp up its...more

Venable LLP

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

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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

BakerHostetler

FTC One-Ups Itself with One Proposed Rule to Rule All Subscription Services

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Mornings for advertising lawyers usually start slow – coffee in one hand and phone in the other while we glance at emails. Imagine our surprise the other morning when we saw that the Federal Trade Commission (FTC) had issued...more

Venable LLP

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

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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

Ankura

Advisory Note - IBM IPAA revisions and its impact

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Are you using any IBM software in your organization? IBM released the latest Version (11) of its International Passport Advantage Agreement (IPAA)/ International Passport Advantage Express Agreement (IPAEA) last week. The...more

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