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California Expands “Dark Pattern” Automatic Renewal Legislation

On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more

The FTC and Multi-Party Liability

The FTC often initiates enforcement actions seeking to hold companies responsible for consumer injury caused by others or in which they directly participated in the misconduct. FTC CID and investigation attorney previously...more

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

Telephone Consumer Protection Act Rules on Revoking Consent for Unwanted Robocalls and Robotexts Effective April 2025

On October 11, 2024, the Federal Communications Commission announced that the effective date for Telephone Consumer Protection Act (TCPA) rules on revoking consent for unwanted robocalls and robotexts is set for April 11,...more

FTC Compliance Attorney on Common Mistakes Made by Business Coaching Program Providers

The FTC continues to prioritize the investigation of online business coaching and mentoring programs, particularly business coaching scams that promise guaranteed income, large returns, “proven systems,” free or low-cost...more

FTC Drops the Hammer on Security Camera Firm Over Charges it Failed to Secure Videos and Personal Data, and that it Violated...

On August 30, 2024, the Federal Trade Commission announced that the Department of Justice filed a complaint upon notification and referral from the FTC against a surveillance camera company that allegedly failed to provide...more

FTC Announces Final Rule Banning Fake and False Consumer Reviews and Testimonials

On August 14, 2024, the Federal Trade Commission announced a Final Rule combatting bogus consumer reviews and testimonials by prohibiting their sale or purchase. The Rule allows FTC lawyers to strengthen enforcement, seek...more

FTC Action Leads to Settlement Against Defendants Alleged to Have Operated a Business Opportunity Scheme

On August 8, 2024, the Federal Trade Commission announced that as a result of a lawsuit, two defendants that allegedly helped operate a purported business opportunity scheme known by several names have agreed to settlements...more

FTC Investigation Leads to Lawsuit Against TikTok and ByteDance for Alleged Violations of the Children’s Online Privacy Protection...

On August 2, 2024, on behalf of the Federal Trade Commission, the Department of Justice sued video-sharing platform TikTok, its parent company ByteDance, as well as its affiliated companies, with allegedly violating the...more

Federal Trade Commission and Department of Justice Joint Task Force News

The Federal Trade Commission and the Department of Justice possess both overlapping and distinct authority to challenge anti-competitive practices under federal law. The FTC enforces, without limitation, the FTC Act and the...more

1MM FTC Settlement With Online Used Car Dealer Over Alleged Misrepresentations and Failing to Deliver on Time

On July 2, 2024 the Federal Trade Commission announced that it initiated action against online used car dealer Vroom for allegedly misrepresenting that it thoroughly examined all vehicles before listing them for sale and...more

First Case Where FTC Charges Company in Gig Economy With Violating the Business Opportunity Rule

On July 2, 2024, the Federal Trade Commission announced that it is taking action against a gig work company for allegedly misleading consumers about the money they could make on the company’s platform and marketing its...more

FTC Made in USA Labeling Rule Compliance and Defense Lawyer on Refreshed Agency U.S. Origin Claim Guidance

On July 2, 2024, the Federal Trade Commission announced a “refreshed version” of the agency’s Complying with the Made in USA Standard guidance document. The refreshed guidance document includes, without limitation, updated...more

Three Things Lead Generators Need to Know About the FCC Single Seller Ruling

As previously blogged about, here, the Federal Communications Commission recently published the final, single-seller lead generator consent rule (the “Rule”). The Rule amends the definition of “prior express written...more

FTC Alleges Adobe and Executives Deceived Consumers About Early Termination Fees and Prevented Easy Cancellation of Subscriptions

On June 17, 2024, the Federal Trade Commission announced an action against software maker Adobe and two of its executives for allegedly deceiving consumers by hiding the early termination fee for its most popular subscription...more

Ad Agency Liability and the FTC

Advertising agencies are potentially liable to the Federal Trade Commission for deceptive acts or practices, along with their clients. The FTC will consider numerous factors, including, but not limited to, the extent to...more

Whoa! U.S. Lawsuit Against Telehealth Providers and Executives Should Turn Heads

On June 10, 2024, the U.S. Justice Department announced that together with the Federal Trade Commission, it filed an amended complaint against telehealth company Cerebral Inc., Cerebral’s founder and former Chief Executive...more

CFPB Warns Against Deception in Contracts for Consumer Financial Products and Services

On June 4, 2024, the Consumer Financial Protection Bureau issued a circular warning against the use of unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. According to the...more

Recent FTC Settlement a Reminder of Agency Focus on Disclosing Health Information to Third-Parties

On April 11, 2024, the Federal Trade Commission announced that it has banned an alcohol addiction treatment firm from disclosing health data for advertising purposes in order to settle agency charges that the company shared...more

Leading FTC Defense Lawyer on Agency Consumer Protection Investigation Procedures

Generally speaking, investigatory procedures, including use of compulsory process, may be used by Federal Trade Commission (FTC) attorneys in connection with the spectrum of activities that the agency is authorized or...more

When a Company Can be Liable to the FTC for Participating with Another Company in Misconduct

The FTC has initiated a number of investigations and enforcement actions in recent years holding companies responsible for consumer injury caused by others or in which they directly participated in the misconduct. For...more

FTC Chair Testifies Before House Subcommittee to Discuss Ongoing Work

On May 15, 2024, the Federal Trade Commission Chair Lina M. Khan appeared before the House Appropriations Subcommittee on Financial Services and General Government to discuss the agency’s FY 2025 budget request and ongoing...more

Update for Lead Generators Concerning FTC’s New TSR Recordkeeping Rules

As previously blogged about, on March 7, 2024, the Federal Trade Commission announced a final rule extending telemarketing fraud protections to businesses and updating the Telemarketing Sales Rule’s recordkeeping...more

Insurance Lead Generation Industry Beware: Court Rules Insurer Vicariously Liable for Actions of Independent Contractors and...

Insurance lead generation industry take note because an Illinois federal court recently held that Allstate violated the Telephone Consumer Protection Act as a result of the actions of its third party, independent contractors...more

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