Internet Law

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

On October 16, 2024, the Federal Trade Commission announced sweeping changes to the Negative Option Rule.  The final “click-to-cancel” rule will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up.  Most of the final rule’s provisions will go into effect 180 days after it is published in…

U.S. Origin Claims Should Not be Based Upon Assumptions the Components Obtained from U.S. Suppliers are “All or Virtually All Made in USA”

As noted in a prior post by an FTC Made in USA attorney, manufacturers and marketers cannot simply assume that the components or ingredients they obtain from U.S.-based suppliers are “all or virtually all made in the USA.”  Instead, they should seek certification from suppliers concerning the percentage of U.S. content therein. The FTC Labeling…

FTC Issues Refreshed Made in USA Guidance

On July 2, 2024, the Federal Trade Commission announced a “refreshed version” of the agency’s Complying with the Made in USA Standard guidance document.  The refreshed guidance document includes, without limitation, updated information about how consumers understand Made in USA claims, how FTC attorneys evaluate advertisements, and how the laws and rules the FTC enforces…

Three Things Lead Generators Must Know About the New FCC Single Seller Rule

As previously blogged about here, the Federal Communications Commission recently published the final, single-seller lead generator consent rule (the “Rule”).  The Rule amends the definition of “prior express written consent” for purposes of the Telephone Consumer Protection Act and will dramatically impact the lead generation industry. How Does the FCC’s One-to-One, Single Seller Rule Impact…

United States Sues Telehealth Providers and Executives

On June 10, 2024, the U.S. Justice Department announced that together with the Federal Trade Commission, it filed an amended complaint against telehealth company Cerebral Inc., Cerebral’s founder and former Chief Executive Officer, Kyle Robertson; former Cerebral executive Alex Martelli; telehealth companies Zealthy Inc., Gronk Inc. and Bruno Health P.A. and an executive of those…

FTC Proposed Revisions to COPPA Rule

The Children’s Online Privacy Protection Rule requires operators of websites and online services that are directed to children under 13 years of age, or that have “actual knowledge” they are collecting personal information from children under 13 years of age.  The COPPA Rule imposes notice, consent, data security and data minimization requirements. On December 20,…