What We're Thinkin

  Many have been asking about the status of the amended FTC Negative Option Rule and when it is likely to go into effect.      TL;DR.   Still don't know for sure, though not any time soon given a recent decision by the ALJ overseeing the three informal hearings conducted earlier this year on...

Pretty Much Everyone:  Any clue as to when the new FTC Negative Option rule will go into effect?  Did the recent Informal Hearings on the rulemaking process impact such timing, and what the heck were they about and how'd they go? Cobalt's Answer(ish):  Timing unclear, and somewhat of a sh!tsh0w....

Update on Auto Renewal legal developments in the past year.

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April 2022 State Auto Renewal Update

California Amends its Auto Renewal Law - October 4, 2021

Visa Withdraws Billing Descriptor Requirement

Summary of FTC v. Moviepass - Important 3 Minute Read

FTC issues Enforcement Policy Statement Regarding Negative Option Marketing

FTC May 2022 Rulemaking on the Telemarketing Sales Rule

          Hello all. Here is our review of and observations on the FTC's recent Negative Option Rule rulemaking.  Our “Full Story” write-up below, as long as it may seem, is a lot shorter than the 83-page proposal, so buckle up and grab some popcorn!  Or, if too much for you right...