On October 22, the Federal Trade Commission (“FTC”) issued a policy statement providing further guidance on its enforcement of federal law with regard to negative option marketing. The FTC noted in an associated press release that they are “ramping up” enforcement efforts against companies that “trap consumers into subscriptions.”  The policy statement is intended to “put companies on notice that they will face legal action if their sign-up process fails to provide clear, up-front information, obtain consumers’ informed consent, and make cancellation easy.”… Continue Reading