Month: June 2021

FTC Announces More Aggressive Use of ROSCA to Obtain Monetary Relief

On June 7, 2021, the Federal Trade Commission (FTC) announced a proposed settlement with MoviePass.  Interestingly, FTC staff attorneys used the used the proposed settlement to announce a completely new and original way of obtaining monetary relief.  The case raises legitimate concerns for digital marketers that offer negative option programs because it indicates that the FTC now…