Summary of Action

In July 2021, submitted a comment to the Federal Trade Commission, which was seeking public comment on a proposed consent order reached in a case it filed against MoviePass, a subscription-based movie ticketing service. In its comment, supported the FTC’s use of The Restore Online Shoppers’ Confidence Act (ROSCA) to pursue, for the first time, deceptive acts that relate to the primary service advertised and purchased rather than the terms of a negative-option or automatic renewal offer. On October 5, 2021, the FTC announced that it had given final approval to the proposed consent order.

Click here to read’s full comment.

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