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: The FTC extended the deadline to comply with the Negative Option Rule’s consent, disclosure, and cancellation requirements from May 14, 2025, to July 14, 2025. Major News for Subscriptions and Auto-Renewing Contracts: The Federal Trade...

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...

Update 3/11/25: Massachusetts Finalizes Auto-Renewal & “Junk Fees” Regulations. View the update in our blog post here. In a growing effort to regulate subscription services and purportedly hidden or misleading fees (referred to as “junk...

Automatically renewing subscriptions continue to be a major area of focus for state legislatures. As many states’ legislative sessions come to a close, it is important to be aware of the significant developments in the...

On June 21, 2023, the FTC filed a complaint in federal district court against Amazon for allegedly using manipulative design choices (“dark patterns”) to enroll customers into Amazon Prime subscriptions and to make it difficult...

The Federal Trade Commission (“FTC”) issued a Notice of Proposed Rulemaking on March 23, 2023, with proposed amendments to its Negative Option Rule (as amended, the “Amended Rule” or “Proposed Rule”) that would significantly expand the scope of the Rule and...

The Consumer Financial Protection Bureau (“CFPB”) has kicked off 2023 by releasing a Circular on unlawful negative option marketing practices with a particular eye towards dark patterns. The guidance warns covered entities and service providers...

Earlier this month, the Federal Trade Commission (“FTC”) released its Staff Report, Bringing Dark Patterns to Light, which follows the FTC’s workshop on “dark patterns” in April 2021. The report emphasizes the FTC’s commitment to...

Colorado’s new auto-renewal law, which goes into effect January 1, 2022, imposes a unique renewal notice obligation that goes beyond what any other U.S. state or federal law currently requires. Under the existing patchwork of state...