The Federal Trade Commission (FTC) has once again announced that it is seeking public comment on ways to improve existing regulations for negative option programs, including the existing Negative Option Rule. The FTC issued an...
Update – 7/8/2025: On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s Negative Option Rule in its entirety, meaning that the Rule will not go into effect as scheduled...
On May 19, 2025, President Trump signed the TAKE IT DOWN Act into law. The Act creates new obligations for online platforms to remove certain nonconsensual intimate visual depictions of both adults and minors within 48 hours...
The Massachusetts Attorney General has released final regulations (“the Final Regulations”) imposing obligations on businesses that offer auto-renewing subscriptions, as well as businesses that impose purportedly hidden or misleading fees (referred to as “junk fees”). The Final...
Update – 7/8/2025: On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s Negative Option Rule in its entirety, meaning that the Rule will not go into effect as scheduled...
Automatically renewing subscriptions continue to be a prime target for state legislatures. The first six months of 2024 have seen a steady flow of new auto-renewal laws, as well as class action complaints and regulatory...