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Areas of Interest
December 18th, 2025
FTC Weighs Petition to Revive ‘Click to Cancel’ Rule
Ms. Melton analyzed the FTC's potential next steps following the rule's invalidation by the Eighth Circuit Court of Appeals. She noted that when Amazon agreed to pay $2.5 billion in September to settle allegations of deceptive Prime subscription practices, the settlement document included language indicating that any future rulemaking on subscription cancellations would supersede the agreement's provisions. Mr. Melton emphasized that this language "reads like a deliberate placeholder—future-proofing the settlement for the reappearance of click to cancel," suggesting the commission anticipates reviving the rule in some form. She advised that businesses should maintain compliance with the rule's underlying principles, stating that "for advertisers and subscription-based businesses, the path forward is clear: provide transparent disclosures, obtain affirmative consent, and make cancellation as effortless as sign-up." Read the full article on the “Click to Cancel” rule here. ( Behind paywall).
Other Quoted
CalPrivacy Hits Ford for Opt-Out Friction in Connected Car Sweep Under CCPA
Privacy Daily recently quoted Andrew Folk’s blog post in the article “CalPrivacy Hits Ford for Opt-Out Friction in Connected Car Sweep Under CCPA.” Read more.
March 9 2026
California Disney Fine Pushes Companies to Fully Honor Opt-Outs
Bloomberg Law quoted Daniel M. Goldberg in their recent article about how California fined Disney $2.75 million for allegedly failing to fully honor consumers’ opt-out requests under the California Consumer Privacy Act, signaling increased scrutiny of how companies implement privacy rights across devices, services, and systems. The enforcement action underscores regulators’ growing expectation that opt-out mechanisms must work seamlessly and consistently, with technical compliance now under closer investigation. Read more.
February 25 2026
California’s attorney general issues largest CCPA fine to date
IAPP quotes Daniel Goldberg on evolving privacy enforcement trends, emphasizing the significant cost and complexity of responding to high-profile investigations and the challenges companies face in aligning technology with regulatory expectations under the California Consumer Privacy Act (CCPA). Read Read more.
February 13 2026
