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ARTICLE · 24 JANUARY 2022

Forgot To Cancel? Pay Attention To Recent Auto-Renewal Law Changes

Morrison Foerster
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As subscription models have gained exponential traction, legislatures are clamoring to ensure that their auto-renewal laws keep up with novel consumer protection issues.

United StatesConsumer Protection
Julie O'Neill
Julie O'Neill
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As subscription models have gained exponential traction, legislatures are clamoring to ensure that their auto-renewal laws keep up with novel consumer protection issues. Several states have introduced or revised their auto-renewal laws, and the Federal Trade Commission has affirmed its commitment to enforce against unlawful offers. Perhaps most notably, California—already a leader in state auto-renewal laws—has significantly amended its law, with the amendments taking effect on July 1, 2022. Other new state requirements took effect on January 1, 2022.

Key Takeaways

  • The FTC remains committed to bringing enforcement actions against allegedly unfair or deceptive auto-renewal offers, including those that employ so-called "dark patterns."

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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