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Congress Pressures DHS To Expedite Safety Act Approvals

Client Alert | 1 min read | 10.06.06

During House Homeland Security Subcommittee hearings on DHS implementation of the SAFETY Act, C&M's David Bodenheimer testified that the new regulations (71 Fed. Reg. 33147) and application kit (available at https://www.safetyact.gov/) have simplified the process, but further improvements are needed to (1) assure confidentiality of SAFETY application data, (2) encourage breakthrough technologies, (3) synchronize procurements and SAFETY Act approvals, (4) extend the duration of protection, and (5) establish an appeals process. In these same hearings, the new DHS Under Secretary (Science & Technology) identified additional initiatives to encourage new anti-terrorism technologies by reducing the application cycle to 120 days and identifying more technologies suitable for block approvals.

Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....