September 10, 2019

On July 12, 2019, the Federal Trade Commission (“FTC”) filed a complaint against AH Media Group, LLC, and its owners, Henry Block and Alan Schill (collectively, “Defendants”), for allegedly violating certain free trial laws as codified in Section 5(a) of the FTC Act, Section 4 of the Restore Online Shoppers’ Confidence Act (“ROSCA”), Section 907(a) of the Electronic Funds Transfer Act (“EFTA”), and Section 1005.10(b) of Regulation E, respectively. The Defendants have agreed to a preliminary injunction, barring them from continuing to run negative option plans tied to “free” trial offers.
How did the Defendants’ “free” trial offers allegedly violate free trial law?