Practical perspectives for contemporary legal challenges.
The Federal Trade Commission’s (FTC) negative option rule, better known as the “Click-to-Cancel” rule, which was set to go into effect July 14, 2025, has been vacated in its entirely by the Eighth Circuit in Custom Communications, Inc. v. FTC, Case No. 24-3137 (8th Cir. July 8, 2025). The court held that the FTC flouted …
Continue reading “Rule Interrupted: “Click-to-Cancel” is “Click-to-Gone””
On January 27, 2025 (the “Effective Date”), the Federal Communications Commission’s (“FCC”) “1:1” consent rule for telemarketing texts and auto-dialed, i.e., robocalls and robotexts will go into effect (the “Final Rule”). The Final Rule will require consumers to provide separate, written consent for each company that wants to send the consumer marketing messages, and it …