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Cancelling Subscriptions Could be Easier, or Maybe Signing Up Will Get Harder
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January 15, 2025
Cancelling Subscriptions Could be Easier, or Maybe Signing Up Will Get Harder
By: Jordan Briggs
Drawn in by the appeal of steady revenue, nearly three-quarters of direct-to-consumer companies now include a subscription model.[1] Everything has a subscription these days: video games, groceries, dating apps—you can even subscribe to a service to cancel your other subscriptions.[2] These subscriptions were not deterred from joining their most prominent predecessor (the gym membership) as an age-old punchline about how hard they are to cancel. However, cancelling subscriptions started to look less like a joke and more like a “trick” or even a “trap,”[3] so the FTC stepped in with the “click-to-cancel” rule to provide clarity to both companies and consumers on what the subscription cancellation process should look like. The click-to-cancel rule is the headliner for a few new…
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Temporary relief from compliance obligations under the Corporate Transparency Act
December 5, 2024
Temporary relief from compliance obligations under the Corporate Transparency Act
By: Steven Eichorn
On December 3, 2024, a U.S. District Court[1] issued a nationwide preliminary injunction that enjoins the federal government from enforcing the Corporate Transparency Act (the CTA)[2]. The CTA requires “reporting companies” in the United States to disclose basic identifying information about their beneficial owners — the individuals who ultimately own or control a company — to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN). The…
Will Free Speech Become Expensive for Big Tech?
December 2, 2024
Will Free Speech Become Expensive for Big Tech?
By: James Trusty
Section 230 of the Communications Decency Act[1] is the federal law that allows internet platforms to host online content without fear of lawsuits based on third party content. In other words, for hosting free speech, internet providers are given immunity from liability if the speech somehow crosses the line from protected free speech into unprotected territory (defamatory, criminal solicitation, etc.). With the recent presidential and…
Privacy Pointers for Employees of the Teleworking World
March 26, 2020
Privacy Pointers for Employees of the Teleworking World
By: Nicole Kardell
Work got a lot more personal when it moved in with my family. For people used to keeping a healthy divide between their business and personal lives, the new telework dynamic can be particularly stressful. That “healthy divide” can crumble under the weight of quarantine as tiny voices (kids and pets) infiltrate teleconference and video conference calls – “I didn’t know Joe had kids!” “Who’s…
Telework: Businesses Need Smart Practices ASAP to Reduce the Threat of Data Security Incidents. Here’s the Quick and Dirty of Smart Practices
March 25, 2020
Telework: Businesses Need Smart Practices ASAP to Reduce the Threat of Data Security Incidents. Here’s the Quick and Dirty of Smart Practices
By: Nicole Kardell
COVID19 is not the only viral threat we face these days. Malware is a very real vulnerability for businesses large and small, among a host of other data security threats. We have rapidly transitioned to telework. For many (perhaps most) businesses, that transition took place without a clear inventory of hardware leaving the office and without a clear telework policy for employees. As a business,…
Allowances Made for COVID-19 Don’t Mean Telehealth Providers and Employers Can Share Protected Information Without Consequences
March 23, 2020
Allowances Made for COVID-19 Don’t Mean Telehealth Providers and Employers Can Share Protected Information Without Consequences
By: Drew Barnholtz
COVID-19 has become a pervasive concern for everyone. Older Americans are particularly susceptible to contracting COVID-19. On March 17th, the Trump Administration and the Department of Health and Human Services (HHS) announced the expansion of Medicare beneficiaries’ access to telehealth services during the COVID-19 outbreak. Importantly, the HHS Office for Civil Rights (OCR) announced it will waive potential HIPAA penalties for good faith use of…
Raising Money for COVID 19 Related Causes? Read this First.
March 23, 2020
Raising Money for COVID 19 Related Causes? Read this First.
By: Nicole Kardell
Cause Marketing Social causes are an important part of both community and business culture. Increasingly, businesses identify social causes to support as a part of their company mission. When they fold that mission into their marketing, it can trigger federal and state consumer protection laws (as well as federal tax laws). Why? To prevent fraud and deception. Regulators do not want for-profit companies to mislead…
One revision, two revisions … three revisions or more?: The California Attorney General Releases A Second Round of Edits to its Draft CCPA Regulations
March 17, 2020
One revision, two revisions … three revisions or more?: The California Attorney General Releases A Second Round of Edits to its Draft CCPA Regulations
By: Nicole Kardell
While the world is uni-focused on the Corona virus, companies doing business in California and impacted by the California Consumer Privacy Act must face another dizzying round of revisions to the California Attorney General’s draft implementing regulations. The AG released its latest set of revisions on March 11, providing an additional notice and comment period through March 27. The latest round of revisions reveals the…
