free-to-pay conversion

California Automatic Renewal Law

California Strengthens its Automatic Renewal Law

On July 1, 2022, California Assembly Bill No. 390 (the “Amended Law”) will go into effect. The Amended Law revised Section 17602 of California’s Business and Professions Code, requiring businesses to adapt to a stricter Automatic Renewal Law (“ARL”). After July 1, companies offering automatically renewing subscription services to California State customers must, among other things, […]

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FTC Settles Another Free Trial Law Investigation

June 6, 2019 Last week, the Federal Trade Commission (“FTC”) announced that it had settled a free product trial lawsuit brought against Triangle Media Corp., Jasper Rain Marketing LLC, Hardwire Interactive Inc., Global Northern Trading Ltd., Brian Phillips, and Devin Keer (collectively, “Defendants”). The FTC’s free trial law complaint and amended complaint both alleged that

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Mastercard Free Trial Requirements

March 6, 2019  Last month, Mastercard Incorporated (“Mastercard”) announced an important change to its policies that will require merchants to provide specific automatic enrollment disclosures to consumers at the conclusion of all free-trial offers. The Mastercard free trial terms are intended to protect consumers from merchants that offer misleading “free to pay” conversions, continuity plans,

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Skincare Product Marketer’s Continuity Billing Draws FTC Scrutiny

March 4, 2019 Beauty product marketer, F9 Advertising, LLC, several related entities, and their individual owner, have been sued by the Federal Trade Commission (“FTC”) for allegedly fraudulent continuity billing practices.   The FTC alleges that the non-compliant continuity billing practices and related marketing violate the Restore Online Shoppers’ Confidence Act (“ROSCA”). How do the entities’

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Spotify’s Automatic Renewal Problem Continues

July 27, 2017 Spotify USA, Inc.’s (“Spotify”) efforts to have class action claims regarding its automatic renewal practices dismissed were recently denied by a federal court in California.  The decision represents another data point in the recent upward trend of class action lawsuits involving claimed violations of California’s Automatic Renewal Law (“ARL”). How do Spotify’s

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