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FTC Ratchets Up “Conspicuous” Bar For Negative Option Disclosures

It was a busy Fall for the Federal Trade Commission in its non-stop enforcement campaign against “continuity” programs it feels do not “clearly and conspicuously” disclose the terms of a “negative option” offer (under which the consumer agrees to recurring … Continue reading

Posted in Direct Response, FTC, Online Marketing | Tagged , , , , | 1 Comment

FTC Snares Ingredient Supplier in Widening Liability Net

My last article and others before discussed a new core enforcement strategy at the Federal Trade Commission (FTC): widening the net of liability and consumer redress recovery through actions against third-party service providers to marketers, such as payment processors and … Continue reading

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FTC Sues Processors for Being ‘Unfair’ to Consumers

We think of the Federal Trade Commission (FTC) as an anti-deception agency, and it is just that. The vast majority of its cases are brought against deceptive business practices. By statute, however, the FTC is also empowered to prevent practices … Continue reading

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