Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”). The Rule sparked significant debate, with the original proposal garnering over 16,000 comments. Following some revisions based on this feedback,……