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DOJ Reports $3.5B Haul from FCA Enforcement in FY15

Client Alert | less than 1 min read | 12.11.15

On December 3, 2015, DOJ reported that it had obtained more than $3.5 billion in recoveries (settlements and judgments) from civil FCA cases in FY15, making it the fourth year in a row that recoveries have exceeded this amount. Of the FY15 recoveries, $1.1 billion related to procurement, $1.9 billion to health care fraud, and the remainder to mortgage fraud and other federal programs.


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 As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....