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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…
SEC and FTC Warn Celebrities Must Disclose Financial Connection For ICO Endorsements
November 27, 2017
SEC and FTC Warn Celebrities Must Disclose Financial Connection For ICO Endorsements
By: Ifrah Law
Cryptocurrency is the latest trend to be embraced by celebrities, so much so that the federal government this month issued a warning about the possible risks involved. Both the U.S. Securities and Exchange Commission (SEC) and the Federal Trade Commission (FTC) have made clear that if a celebrity is being paid to promote a product on social media, the financial connection between the endorser and…
Deadline Fast Approaches for Final DMCA Registration
November 7, 2017
Deadline Fast Approaches for Final DMCA Registration
By: Steven Eichorn
The Digital Millennium Copyright Act (DMCA) provides a safe harbor from copyright infringement liability for online service providers. While not a particularly famous law, it is a critical law because it enables websites to accommodate user-generated content without being concerned for copyright infringement claims by hosting that content. However, in order to preserve their safe harbor qualification, online service providers must submit an online registration…
Congress Saves Consumer Arbitration
October 25, 2017
Congress Saves Consumer Arbitration
By: George Calhoun
In July 2017, the Bureau of Consumer Financial Protection (“CPFB”) announced a new rule broadly barring arbitration provisions in a wide swath of consumer contracts. See 12 CFR part 1040. To go into effect next Spring, the final rule would have prohibited providers of certain consumer financial products and services from using an agreement with a consumer that provides for arbitration of any future dispute…
GDPR D-Day: If Not Prepared, It Could Cost You Europe
September 26, 2017
GDPR D-Day: If Not Prepared, It Could Cost You Europe
By: Nicole Kardell
GDPR D-Day: May 25, 2018. If you are not prepared, the results could cost you Europe. In the U.S., we’ve had a pretty business-friendly approach to consumer data protection. And while federal and state authorities have their respective consumer protection laws, there is no single federal law that clearly defines U.S. policy on how consumer data may be collected and used. Businesses have come to…
A Giant Demanding Piece of … Restrictiveness: Do you need to pay attention to the coming GDPR?
August 28, 2017
A Giant Demanding Piece of … Restrictiveness: Do you need to pay attention to the coming GDPR?
By: Nicole Kardell
GDPR. If you see those letters and think it is an acronym for Gosh Darned Pain in the Rear (or an edgier equivalent) you are in large-part correct. But if you don’t know any more than that, and you are a company with any ties to Europe, then you need to read further. GDPR, the General Data Protection Regulation, is an extensive and broad-reaching regulation…
