Litigation

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Click to Cancel Just Got Cancelled: Eighth Circuit Vacates Entirety of FTC’s Negative Option Rule

On July 8, 2025, the US Court of Appeals for the Eighth Circuit vacated the entirety of the Federal Trade Commission’s new Negative Option Rule – popularly known as the Click-to-Cancel Rule – just days before it was scheduled to take full effect. While the rule has been vacated, the FTC can still police unfair and deceptive subscription practices under existing statutory authority. Companies also must continue …

Crypto Shake-Up: Narrowing Risks, From Securities Scrutiny to Consumer Claims

Crypto is now in Washington’s good graces – or at least that’s how it may seem. The return of the Trump administration has injected new energy into the crypto asset space, with sweeping rhetoric about “unleashing innovation” and a flurry of early moves that suggest a dramatically more hands-off regulatory approach. The president’s appointment of pro-crypto voices to key posts at the Securities and Exchange Commission …