Renew This: The New FTC “Click to Cancel” Rule and State Automatic Renewal Laws

New Automatic Renewal Laws (ARLs) and amendments to existing ARLs—statutes governing continuity programs and automatically renewing contracts—have proliferated throughout the United States in recent years. In 2024, California amended its heavily litigated ARL, and the Federal Trade Commission (FTC) issued its long-anticipated Final Rule on negative options. California and the FTC are joined by a host of states that have recently adopted or strengthened their statutes.

There has also been an increase in government enforcement actions and private litigation based on both federal law and state ARLs. That trend will likely continue upward as more states pass ARLs or adopt increasingly stringent consent and cancellation requirements.

In this new webinar, Manatt will discuss the risks that companies face in the current and increasingly complex ARL landscape, including how existing and proposed ARLs impact companies’ ability to conduct business and comply with sometimes contradictory statutes and rules.

Key topics that will be covered include:

1. Current legislative trends;
2. Distinctions between California amendments and the FTC Final Rule;
3. ARL disclosure requirements;
4. ARL consent requirements;
5. Post-purchase acknowledgements;
6. Pre-renewal notices;
7. Cancellation requirements and save attempts;
8. Litigation trends and common vehicles for litigation;
9. Potential penalties, remedies and exposure in ARL litigation, investigations and enforcement actions;
10.  The good faith exception and defenses; and
11.  Predictions on upcoming shifts in the ARL legal landscape.

Speakers:

• , Partner, Consumer Protection
• , Partner, Litigation and Consumer Protection
• , Partner, Consumer Protection

Date and Time:

Wednesday, January 29, 2025
10:00 a.m. – 11:00 a.m. PT
1:00 p.m. – 2:00 p.m. ET