Internet Law

Eleventh Circuit Vacates TCPA One-to-One Consent Rule Immediately After FCC Postpones its Effective Date

On the eve prior to its effective date, the FCC’s One-to-One Consent Rule which sought to redefine the meaning of “prior express written consent” under the Telephone Consumer Protection Act, was postponed for one year by order of the FCC’s Consumer and Government Affairs Bureau.  Just minutes thereafter, the rule was struck down by the…

FTC Proposes Changes to Business Opportunity Rule to Deter Deceptive Earnings Claims – Republican Commissioners Dissent

On January 13, 2025, the Federal Trade Commission announced that it is seeking comment on proposed changes to the Business Opportunity Rule and a proposed new Earnings Claim Rule.  According to the FTC, the two, taken together, “would strengthen the agency’s tools to curb deceptive earnings claims in industries where they are pervasive: multi-level marketing…

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…