On May 27, the Connecticut governor signed into law a comprehensive artificial intelligence (“AI”) bill that regulates safety, transparency, and consumer protection, including subscription marketing (“SB 5”). Alongside key provisions on Employee Reporting Protections, AI Companions, and Automated Employment-Related Decision Technology (discussed in more detail here), SB 5 also sets
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New York City Adopts ‘Click to Cancel’ Rule
On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.
Continue Reading New York City Adopts ‘Click to Cancel’ RuleFTC and DOJ Continue Focus on Consumer Reviews Rule with Complaint Against Premium Home Service
On May 11, 2026, the Department of Justice, acting on notification from the Federal Trade Commission, and the Illinois Attorney General, filed a complaint against “Premium Home Service” and its owner for alleged violations of Section 5 of the FTC Act, the Consumer Reviews Rule, and the Gramm-Leach-Bliley Act (GLB Act). The Complaint seeks injunctive relief, monetary relief, and civil penalties.
Continue Reading FTC and DOJ Continue Focus on Consumer Reviews Rule with Complaint Against Premium Home ServiceFTC Seeks Comment by May 18 on Food Delivery Pricing and Fees
On April 14, 2026, the Federal Trade Commission (“FTC” or “Commission”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) seeking public comment on whether a new rule is needed to address fee practices by online food and grocery delivery platforms that may obscure total pricing or impede consumers’ ability to
Continue Reading FTC Seeks Comment by May 18 on Food Delivery Pricing and FeesFTC Seeks Public Comment on Proposed Rulemaking for Unfair or Deceptive Rental Housing Fee Practices
On March 12, 2026, the Federal Trade Commission (“FTC”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) seeking public comment on a proposed rulemaking focusing on potential unfair or deceptive acts or practices in the rental housing market. This ANPRM contemplates requiring landlords and property managers to provide full, upfront
Continue Reading FTC Seeks Public Comment on Proposed Rulemaking for Unfair or Deceptive Rental Housing Fee PracticesFTC Negative Option Rule ANPRM
On March 11, 2026, the Federal Trade Commission (“FTC” or “the Commission”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding its Rule Concerning the Use of Prenotification Negative Option Plans, commonly known as the Negative Option Rule (“the Rule”). This ANPRM signals the beginning of a rulemaking process that will expand the scope of the rule and drive a major priority for the Trump-Vance FTC.
The ANPRM was published in the Federal Register on March 13, 2026. Comments from the public are due on April 13, 2026. After reviewing the record developed through the ANPRM, the Commission may decide whether to proceed to a notice of proposed rulemaking, propose specific amendments, or take no further action.
Continue Reading FTC Negative Option Rule ANPRMFTC Sets Aside Rytr Final Order Pursuant to White House AI Action Plan
On December 22, the Federal Trade Commission (“FTC”) issued an order setting aside its 2024 final consent order against Rytr, LLC (“Rytr”) on the grounds that the facts alleged in the Rytr complaint did not violate Section 5. The Commission further found that the Rytr order did not provide any
Continue Reading FTC Sets Aside Rytr Final Order Pursuant to White House AI Action PlanFTC Issues Warning Letters for Violations of Consumer Reviews Rule
The Federal Trade Commission (FTC) sent letters to 10 companies—whose identities were not publicly disclosed—on December 22, 2025, warning them about potential violations of the Consumer Reviews Rule. The Rule, which took effect in October 2024, targets deceptive online review and testimonial practices. These warning letters mark the FTC’s first
Continue Reading FTC Issues Warning Letters for Violations of Consumer Reviews RuleFTC Sues LA Fitness Operators for Unfair Gym Cancellation Policies
On August 20, 2025, the Federal Trade Commission (“FTC”) sued Fitness International, LLC and Fitness & Sports Club LLC – the parent companies of LA Fitness and other gym chains – for violations of Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”) in connection with alleged practices that make it difficult for their customers to cancel their gym memberships and other add-on services. The FTC seeks a court order prohibiting the allegedly unfair and unlawful conduct and restitution to consumers harmed by the difficulty in cancelling memberships.
Continue Reading FTC Sues LA Fitness Operators for Unfair Gym Cancellation PoliciesFTC Takes Aim at Online Lead Generator
On August 7, 2025, the Federal Trade Commission (“FTC”) announced a $45 million settlement with online lead generator MediaAlpha, Inc. and its subsidiary QuoteLab, LLC (collectively, “MediaAlpha”), resolving allegations that the companies misled consumers seeking health insurance products. According to the FTC, MediaAlpha tricked consumers into sharing sensitive personal information under the guise of offering health insurance options through their lead generation sites. MediaAlpha allegedly then used that data for abusive telemarketing, including calling numbers on the National Do Not Call Registry. The FTC also alleged that MediaAlpha auctioned off consumers’ information to third-party lead generators and telemarketers, who similarly used that data to make illegal telemarketing calls.
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