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Mining Law Monitor - Volume 23, Issue 1 - (Fall/Winter 2006)

Client Alert | less than 1 min read | 12.22.06

  • "Climate Change: Things Are Starting to Heat Up," Co-Authors: Ann Klee and Chet Thompson.
  • "On-Site Health Clinics: The Privacy Risks of Providing Care," Co-Authors: Tim Means and Ben Butler.
  • "Dust in the Wind: EPA Revises the PM National Ambient Air Quality Standards," Author: Chet Thompson.

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 As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....