FTC Act

On May 13, 2026, the Federal Trade Commission (“FTC”) announced that Shutterstock, Inc. had agreed to a $35 million settlement resolving allegations that the company engaged in unfair and deceptive subscription practices. The FTC asserted claims under Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”), alleging that Shutterstock charged consumers who did not understand they were enrolling in a subscription, failed to adequately disclose material subscription terms, and made cancellation unnecessarily difficult. The complaint did not seek civil penalties, and the final settlement requires only consumer redress. 

Continue Reading FTC Settles with Shutterstock Over Subscription Practices

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 Policies

On February 1, the Federal Trade Commission (“FTC”) announced its first-ever enforcement action under its Health Breach Notification Rule (“HBNR”) against digital health platform GoodRx Holdings Inc. (“GoodRx”) for failing to notify consumers and others of its unauthorized disclosures of consumers’ personal health information to third-party advertisers.  According to the proposed order, GoodRx will pay a $1.5 million civil penalty and be prohibited from sharing users’ sensitive health data with third-party advertisers in order to resolve the FTC’s complaint. 

This announcement marks the first instance in which the FTC has sought enforcement under the HBNR, which was promulgated in 2009 under the Health Information Technology for Economic and Clinical Health (“HITECH”) Act, and comes just sixteen months after the FTC published a policy statement expanding its interpretation of who is subject to the HBNR and what triggers the HBNR’s notification requirement.  Below is a discussion of the complaint and proposed order, as well as key takeaways from the case.

Continue Reading FTC Announces First Enforcement Action Under Health Breach Notification Rule