Quoted

December 18th, 2025

FTC Weighs Petition to Revive ‘Click to Cancel’ Rule

Holly Melton was quoted in a Law.com in an article discussing the Federal Trade Commission's consideration of a petition to revive the "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).