Venable's Autorenewal Solutions Team (VAST) guides clients through all phases of automatic renewal programs. As states continuously enact regulations on subscription services plans, Venable attorneys provide experienced counsel to help reduce the risk of investigations and litigation.
Automatic Renewal Law
Experience
Experience
Federal Trade Commission Experience
- Resolved the first FTC investigation into alleged ROSCA violations
- Resolved the first FTC ROSCA civil penalty inquiry
- Defeated an FTC temporary restraining order and asset freeze
- Successfully obtained closure of an FTC compliance inquiry
- Successfully convinced the FTC to abandon ROSCA claims against a seller of background reports
- Successfully convinced the FTC to abandon a Telemarketing Sales Rule compliance inquiry into a company that offered subscription products via telemarketing
State Regulatory Experience
- Defended companies on state autorenewal laws before multiple state attorneys general, including in New York, Oregon, Pennsylvania, and Texas, who challenged subscription box services, news and media companies, dietary supplement sellers, and an events sign-up subscription program
- Obtained closure on behalf of a national security systems company inquiry in Georgia with no action by the state attorney general
- Obtained full closure of an investigation by the Nebraska state attorney general
- Obtained full closure of an autorenewal element of inquiry in NevadaObtained full closure of an autorenewal lawsuit in Ohio
- Obtained a favorable settlement for a nutritional supplement company targeted by the California Autorenewal Task Force
- Defended companies targeted by the California Autorenewal Task Force in all verticals, including subscription box, consumer goods seller, and dietary supplement companies
- Successfully resolved a Better Business Bureau (BBB) inquiry into a dietary supplement subscription program and achieved an A+ rating following the investigation
Class Action Lawsuits
- Obtained dismissal of class action allegations that a subscription program violated the Electronic Funds Transfer Act
- Successfully compelled arbitration in a Florida class action lawsuit challenging a subscription program and alleged hidden fees, in a matter of first impression
- Obtained a favorable class action settlement resolving retroactive exposure in a lawsuit challenging an adult streaming content website
- Successfully resolved multiple class action demands and obtained full walkaways from prolific class action plaintiffs' attorneys, including demands challenging cosmetic products, subscription box services, dietary supplements, and consumer goods
