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FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more

Eight Questions Advertisers Should Be Asking About Tariffs

The Trump administration transformed global trade policies by implementing a series of sweeping tariffs. Advertisers should ask the following questions...more

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more

FTC Files Brief Defending “Click to Cancel” Negative Option Rule

Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more

National Advertising Division Targets Celebrity, Influencer, and Third-Party Marketing in Recent Decisions

The National Advertising Division (NAD) recently issued a series of decisions addressing influencer and third-party marketing. The NAD is a self-regulatory body that assesses the truth and accuracy of claims made in national...more

[Webinar] #BadForTheBrand: What to Do When Your Influencer Goes Rogue - March 27th, 2:00 pm - 3:00 pm ET

When working with influencers, companies can do everything right, from drafting an influencer agreement to creating a stellar marketing plan. All elements of the ideal campaign are in place. But when you tune in to see the...more

[Event] 11th Advertising Law Symposium - March 20th, Washington, DC

Venable's AdLaw Symposium is back! Please join us in our Washington, DC, headquarters for this highly anticipated event focused on providing you with the information you need to promote your brand with confidence....more

New Executive Orders Declare “So-Called” Independent Agencies No Longer Independent

Last week, President Trump issued two executive orders aimed squarely at upending the long-accepted authority and independence of certain federal agencies. The first order, Ensuring Accountability for All Agencies, derides...more

FTC Forges Ahead in Court Battle on FTC Act's Scope Over Nonprofit Institutions (And Loses)

With much of the administrative state in turmoil, the Federal Trade Commission (FTC) appears to be holding steady and continuing to litigate its current cases. We previously discussed the FTC’s lawsuit against Grand Canyon...more

The Fifth Circuit Slams the Brakes and Vacates FTC CARS Rule

This week, the U.S. Court of Appeals for the Fifth Circuit vacated the Federal Trade Commission’s (FTC) Combatting Auto Retail Scams (CARS) rule....more

Fast VAST Update: Federal Court Declines to Stay FTC Negative Option Rule During Challenge

Last Friday in a 2-1 order, the Eighth Circuit Court of Appeals rejected an initial challenge to the Federal Trade Commission’s (FTC) Negative Option Rule. The challengers had asked the court to stay the Rule from taking...more

Welcome to the New Federal Trade Commission! But First, a Look Back at FTC Rulemaking

With the Biden-Harris administration and Federal Trade Commission (FTC) Chair Lina Khan tenures now completed, we take a look back at the mountain of rulemaking carried out over the last few years. Khan’s ambitious agenda led...more

FTC Issues Scaled-Back Final Fee Rule Targeting Live-Event Tickets and Short-Term Lodging

This week, the Federal Trade Commission (FTC) issued its long-awaited Final Rule on Unfair or Deceptive Fees. When the FTC released the proposed rule over a year ago, the rule covered any business that offered goods or...more

Telemarketing Sales Rule Amendment Sparks Debate Between FTC Republicans Ahead of Administration Transition

Just before Thanksgiving, the Federal Trade Commission (FTC) announced a Final Rule significantly expanding the coverage of the Telemarketing Sales Rule (TSR). The amendment extends the TSR’s prohibition against deceptive...more

The Dueling Views of FTC Commissioners Ferguson and Holyoak on the Scope of Agency Authority

Last month, the Federal Trade Commission (FTC) announced an enforcement action against Evolv Technologies, alleging that the company made deceptive claims about the capabilities of its AI-powered security screening system,...more

Foul! SEC Faults Investment Adviser for Inadequate Disclosures on Professional Athlete Endorsements

The Federal Trade Commission (FTC) isn’t the only regulator in town when it comes to endorsements and testimonials. The Securities and Exchange Commission (SEC) regulates investment adviser marketing under its “Marketing...more

Business Groups Rush to File Federal Court Challenges to the FTC’s Negative Option “Click-to-Cancel” Rule

As we previewed last week, industry and trade groups wasted no time in filing challenges against the Federal Trade Commission’s (FTC) Final Negative Option Rule....more

FTC Announces Final “Click-to-Cancel” Rule on Negative Options, Autorenewals, Free-to-Pay, and Subscription Services

By a 3-2 vote, the Federal Trade Commission (FTC) announced its Final Negative Option Rule that covers negative option programs for both consumer and B2B transactions in any media, including online, telephone, print, and...more

California Amends Autorenewal Law, with Stricter Consent Requirements and a “One Save” Rule: Fast VAST Update

This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more

California Privacy Protection Agency Warns Businesses Against “Dark Patterns” and Urges “Symmetry in Choice”

Not to be left behind by other regulators, the California Privacy Protection Agency (CPPA) recently issued an enforcement advisory on “dark patterns” in the context of the notice and consent required under the California...more

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more

FTC Commissioner Claims Agency Creates Favorable Precedent Through Venue Selection

During the dog days of August, the Federal Trade Commission (FTC) brought two complaints against auto companies involving alleged deceptive and discriminatory price advertising....more

Court Rules FTC’s Non-Compete Rule Is Unenforceable Nationwide

The Federal Trade Commission’s (FTC) rulemaking crusade suffered a serious blow this week, when Judge Ada Brown of the Northern District of Texas set aside the agency’s Final Rule that made most employment-related non-compete...more

Federal Court Narrowly Construes FTC Jurisdiction Over Nonprofit Institutions

In a surprising ruling, a federal district court in Arizona has held that the Federal Trade Commission (FTC) cannot prosecute claims under the FTC Act against a nonprofit educational institution. Late last year, the FTC...more

FTC Fines Car Companies $10 Million Calling Out Influencers and Endorsers

This summer the Federal Trade Commission (FTC) has turned up the heat on two companies that provide extended car repair coverage, CarShield and American Auto Shields, for deceptive and misleading advertising and telemarketing...more

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