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How Did We Get Here and Where Are We Headed?

Client Alert | 1 min read | 12.19.12

Although much uncertainty remains, there is an emerging consensus that overall budgetary cuts are likely to occur in the coming weeks, whether as a result of sequestration or an alternative deficit reduction plan. In "Cliff Notes: The Long, Slow Trudge Toward Sequestration," published by Law360 on December 17, C&M attorneys Angela Styles, Steve McBrady, and Stephan Rice provide a brief retrospective of the developments in 2012 and a short overview of what contractors can expect in the weeks ahead as the countdown to sequestration approaches.


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 As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....