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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…
Will The Floodgates Open As Consumer Backlash To Spam Unleashes?
December 23, 2015
Will The Floodgates Open As Consumer Backlash To Spam Unleashes?
By: Ifrah Law
Every e-mail user receives them, some days in numbers hitting the triple digit mark – those targeted, often annoying and unsolicited e-mails that clog our inboxes, originating from any of a multitude of establishments, including retailers, service establishments, and even our own social media. Regulation over unwanted e-mails has been limited mostly to the federal Can Spam Act of 2003, which doesn’t prohibit the…
Highlights And Takeaways from the October 30th FTC Lead Generation Workshop
November 3, 2015
Highlights And Takeaways from the October 30th FTC Lead Generation Workshop
By: Nicole Kardell
Exploiting consumers and exploiting consumer data were popular themes in the FTC’s October 30th workshop on lead generation, “Follow the Lead.” The day-long workshop explored the mechanics of lead generation and its role in the online marketplace. With a focus on the lending and education spaces, panelists discussed the many layers of marketing involved in lead generation—and importantly—how those many layers can add confusion…
Jumping To Judgment on For-Profit Education
October 15, 2015
Jumping To Judgment on For-Profit Education
By: Nicole Kardell
If you didn’t know any better, you might have gotten pretty fiery over for-profit education after reading one of the front page stories of Tuesday’s New York Times. The lengthy article titled “For-Profit Colleges Fail Standards, but Get Billions” is all about accusations of greedy institutions bilking taxpayers and taking advantage of students through fraud and other deceptive practices. Why the story ran on…
TCPA Trouble Continues: FCC Slams Lyft and First National Bank for Terms of Service Requiring Consent
September 16, 2015
TCPA Trouble Continues: FCC Slams Lyft and First National Bank for Terms of Service Requiring Consent
By: Michelle Cohen
Most of the attention involving the Telephone Consumer Protection Act (“TCPA”) has centered on the stream of class actions around the country. It is important to remember that the Federal Communications Commission (“FCC”) and state attorney generals can, and do, enforce the TCPA. In fact, the FCC recently issued citations to Lyft, the ride-sharing service, and First National Bank (“FNB”). Under the Communications Act,…
The Key to Steering Clear of the FTC’s Crack Down on Car Dealership Advertisements
August 13, 2015
The Key to Steering Clear of the FTC’s Crack Down on Car Dealership Advertisements
By: Ifrah Law
Car dealerships are notorious for running loud, flashy ads with too-good-to-be-true offers for outrageous deals to buy or lease cars. Some dealerships downplay or even hide the seemingly endless list of qualifications on those offers which render many potential buyers ineligible for the deals, much to the irritation of misled consumers. The FTC has taken action to stop these misleading practices by continuing its…
