Summary of Action

In December 2019, submitted a comment to the Federal Trade Commission, which was seeking public comment on ways to improve its existing regulations for negative option marketing, including whether the agency should use its rulemaking authority under the FTC Act to expand the scope and coverage of the existing Negation Option Rule.

In its comment, urged the FTC to provide further consumer protection in this area and summarized relevant statistics concerning the scope of the problem (e.g., the growth of consumer complaints regarding free trials). also explained how, in its current form, the FTC’s Negative Option Rule leaves consumers vulnerable to deception and that updating the Rule would be minimally burdensome to companies, essentially requiring them to be straightforward with its customers.

To read’s full comment, use the menu.

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