Mornings for advertising lawyers usually start slow – coffee in one hand and phone in the other while we glance at emails. Imagine our surprise the other morning when we saw that the Federal Trade Commission (FTC) had issued a press release and Federal Register Notice at 6 a.m. so that Chair Lina Khan could … Continue Reading
Most of the Federal Trade Commission’s (FTC) law enforcement actions involving payment processors have exclusively focused on allegations that processors did not do sufficient due diligence before onboarding questionable merchants. The latest payment processing case, however, has a bit of a novel twist and focuses instead on alleged deceptions aimed at the merchants that were … Continue Reading
Policy statements are neither rules nor notices of penalty offenses, but when the FTC issues a policy statement discussing an area that has been the subject of a lot of enforcement activity, it warrants serious attention, particularly when the press release discusses ramping up enforcement on “illegal dark patterns that trick or trap consumers.” That’s … Continue Reading
The Rent to Own industry has been a frequent target of Federal Trade Commission (FTC or Commission) action. While the industry notes that it provides an ownership option for consumers who are unable to pay up front and who may not qualify for traditional credit, critics point to the fact that the final cost of … Continue Reading