United States: Consumer Trading & Unfair Trading

The FTC has intensified enforcement against subscription billing practices, recently securing a court order to halt Genesis Tech's alleged deceptive subscription schemes spanning fitness apps, PDF tools, and self-help courses. In a separate action, Shutterstock agreed to pay $35 million to settle charges of unauthorized billing and difficult cancellation processes that affected millions of consumers.

The Federal Trade Commission has filed a sweeping complaint against Genesis Tech and related entities, alleging systematic deception in subscription funnels that lure consumers with free or low-cost offers while obscuring auto-renewal terms. The enforcement action signals heightened scrutiny of end-to-end consumer journeys, challenging not just missing disclosures but the overall impression created by quizzes, personalization claims, and pricing language that suggests one-time purchases. What compliance ris

A federal court examines whether egg carton claims about hens being "free to roam in a pleasant, natural environment" mislead consumers when the birds are actually confined to windowless facilities with minimal space. The case explores how production condition claims differ from product quality representations and whether industry-standard "cage free" terminology protects manufacturers from consumer protection lawsuits when additional marketing language creates different expectations.

Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken.

When the U.S. Court of Appeals for the Fifth Circuit vacated the FTC's Combating Auto Retail Scams (CARS) Rule in January 2025 on procedural grounds, some dealers may have interpreted...

What can a $35 million settlement teach companies about subscription billing, auto-renewals, and cancellation practices? In this episode, we unpack the FTC’s case against Shutterstock...

The EPA has added microplastics and pharmaceuticals to its draft Sixth Contaminant Candidate List under the Safe Drinking Water Act, marking a significant shift in federal drinking water priorities. Meanwhile, states await EPA's response to a 2024 petition requesting certain PFAS compounds be designated as hazardous air pollutants under the Clean Air Act, with the statutory deadline potentially missed. New Mexico has implemented comprehensive PFAS labeling requirements that extend beyond its existing report

New York City Mayor Zohran Mamdani has directed the Department of Consumer and Worker Protection to crack down on subscription-based businesses that make it difficult for consumers to cancel their services. The proposed rules would require businesses to provide clear pre-purchase disclosures, offer simple cancellation mechanisms through the same medium used for enrollment, and issue advance notices before renewals or price changes. Companies violating these requirements could face fines starting at $525 per

A federal judge in California has partially denied Uber's motion to dismiss an FTC lawsuit challenging its Uber One subscription practices, allowing key claims under ROSCA to proceed. The court found that allegations regarding unclear disclosures, timing of billing information collection, and burdensome cancellation processes raised plausible violations that cannot be resolved at the pleading stage. The ruling provides important guidance on subscription enrollment flows and cancellation mechanisms under fed