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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…
A Review of Top-Rated AI Tech Companies Undermines the FTC’s Warning of Deception
March 22, 2023
A Review of Top-Rated AI Tech Companies Undermines the FTC’s Warning of Deception
By: Abbey Block
Artificial intelligence (“AI”) was once thought of as science fiction – something we could only see on a movie screen or read about in a comic book. But in recent years, the technology has become both accessible and popular, proliferating nearly every sector of society. From healthcare to the legal industry, AI technology has been praised for its…
Former Uber Security Chief Convicted of Federal Charges Stemming From 2016 Extortionate Data Breach
October 28, 2022
Former Uber Security Chief Convicted of Federal Charges Stemming From 2016 Extortionate Data Breach
By: Michelle Cohen
Uber’s former Chief Security Officer, Joe Sullivan, was convicted of two federal charges—obstruction of justice and misprision of a felony—for his role in covering up an extortionate data breach in 2016, which compromised more than 50 million personal records of Uber drivers and passengers, while the Federal Trade Commission (“FTC”) was probing Uber’s privacy protections. The San Francisco jury’s verdict marks a stunning development in…
New California Law Establishes Broad Protections for Children’s Online Privacy – Exceeding Federal Requirements
October 4, 2022
New California Law Establishes Broad Protections for Children’s Online Privacy – Exceeding Federal Requirements
By: Jake Gray
California made history in September as the first state to enact legislation that punishes technology companies for violations of minors’ privacy and for practices that jeopardize minors’ safety in an effort to prioritize “the privacy, safety, and well-being of children over commercial interests.” On September 15th, Governor Newsom signed The California Age-Appropriate Design Code Act (“the Act“) into law. The legislation, which was passed by…
The FTC Weighs In: Online Services Must Be Diligent When Kids’ Privacy At Stake
March 9, 2022
The FTC Weighs In: Online Services Must Be Diligent When Kids’ Privacy At Stake
By: Nicole Kardell
WW International (f/k/a Weight Watchers) seems to be doing children a service: the company developed an online program tailored to address childhood weight issues. The program, offered by WW subsidiary Kurbo, has an app, youthful professional coaches, and many features that look promising both to attract and to retain program young subscribers. Plus, the program touts peer-reviewed published research demonstrating its success. With some 20…
Federal Court Dismisses Illegal Lottery Claims Against Omaze, Emphasizing Adequacy of Fundraiser’s Alternative Means of Sweepstakes Entry
February 25, 2022
Federal Court Dismisses Illegal Lottery Claims Against Omaze, Emphasizing Adequacy of Fundraiser’s Alternative Means of Sweepstakes Entry
By: Jacob Grubman
As covered in this blog, in most states, companies that offer sweepstakes entries with certain purchases must also allow free entry (often called “alternative means of entry” or “AMOE”). This requirement stems from the three elements that generally make up regulated gambling: (1) consideration, (2) prize, and (3) chance. Random-chance giveaways inherently meet the latter two factors. To avoid running afoul of the gambling laws,…
