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Will This Be on the Exam? FTC Staff Issues Two Initial Reports on Surveillance Pricing

On January 17, 2025, the staff at the Federal Trade Commission (FTC) released their first results from the FTC’s Surveillance Pricing market study. The FTC staff reports, including both a “staff perspective” and an “issue...more

FTC Junk Fees Rule Targets Ticket Sales and Hotel Rentals

The Federal Trade Commission has issued a long-anticipated final Rule on Unfair or Deceptive Fees (the Rule), colloquially known as the “Junk Fees” Rule, targeting mandatory hidden fees and ensuring transparent pricing...more

Are You Preparing to Comply with the FTC “Click-to-Cancel” Rule?

The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more

California, FTC Lead Push To Add Autorenewal Requirements

If it’s been a while since you’ve looked at the state and federal laws governing autorenewals, subscriptions, and continuous service offers, your business is likely in need of an update. Multiple jurisdictions, on both state...more

What the FTC Final Rule Means for Reviews and Testimonials: A Six-Part Series

The Federal Trade Commission (FTC) has published a long anticipated Final Rule on the Use of Consumer Reviews and Testimonials that prohibits certain practices the FTC deems misleading or deceptive, provides additional...more

Part 6: What the FTC’s Final Rule on Reviews and Testimonials Means for Enforcement, Penalties

In this post, the final part of our six-part series, we explore the nuances of the “teeth” of the FTC’s Final Rule on consumer reviews and testimonials—the money the FTC can recover for violations of the Final Rule....more

What the FTC’s Final Rule Means for Fake Indicators of Social Media Influence and Fake Review Websites

In this post, part of a six-part series on the FTC’s Final Rule on Consumer Reviews and Testimonials, we explore what the FTC means in prohibiting the use of fake indicators of social media influence, and fake review...more

Part 4: What the FTC’s Final Rule Means for Insider Reviews

In this post, part of a six-part series on the FTC’s Final Rule on Consumer Reviews and Testimonials, we explore what the Final Rule means for so-called “insider” consumer reviews and testimonials, and also review...more

Part 3: What the FTC’s Final Rule Means for Incentivized Reviews

In this post, part of a six-part series, we explore what the FTC’s Final Rule on consumer reviews and testimonials means for incentivized reviews. The Final Rule prohibits businesses from providing compensation or other...more

Part II: What the FTC’s Final Rule Means for Fake Reviews, Testimonials

The Federal Trade Commission, as we previously reported, has published a Final Rule on consumer reviews and testimonials that prohibits certain practices the FTC deems to be deceptive or misleading in six areas: (1) fake or...more

What the FTC’s final rule means for reviews and testimonials - part I

The Federal Trade Commission (FTC) has published a long anticipated Final Rule that prohibits certain practices that the FTC deems misleading or deceptive when it comes to consumer reviews and testimonials. As we anticipated...more

Year in Review: 2021 Food, Beverage & Supplement Litigation Round-Up

Federal Made in U.S.A. Rule - In June 2021, the Federal Trade Commission (FTC) adopted its final rule for using “Made in U.S.A.” or any variation of that statement, including the U.S. flag. While this rule imposes no new...more

FTC Warns Companies Against Advertising CBD Products as Treating or Curing Diseases

The U.S. Federal Trade Commission has announced that it sent warning letters to three companies that sell “oils, tinctures, capsules, ‘gummies,’ and creams containing cannabidiol (CBD),” a chemical compound derived from the...more

FTC Warns Against Warranty Conditions in Violation of Magnuson-Moss Warranty Act

The FTC has sent warning letters to six major companies that market and sell automobiles, cellular devices, and video gaming systems warning against warranty tie-in provisions that state consumers must use specified parts or...more

Beware of Phantom Price Markdowns: Ruling Against Hobby Lobby Highlights Risk

Over the past several years, there has been a rise in class action lawsuits against retailers for allegedly deceptive price comparison advertising. Many of these lawsuits have alleged that retailers advertised “phantom”...more

“Made in the USA” Claims

Although every product imported into the United States must be marked with its country of origin pursuant to Section 304 of the Tariff Act of 1930, most products manufactured domestically are not required to list the United...more

FTC Takes Action Against Personal Care Product Companies for Making False All-Natural Claims

The Federal Trade Commission has approved four final consent orders against companies that allegedly misrepresented their personal care products as "All-Natural" or "100% Natural," despite the fact that they contain man-made...more

Native Advertising: Recent FTC Cases Require Disclosure of Paid Endorsements on Social Media

Two recent cases by the Federal Trade Commission (“FTC”) demonstrate its position that paid endorsements in social media must be disclosed. These cases reinforce the FTC’s stance on transparency in native advertising, which...more

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