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Articles by Sara Skinner Chubb
Subscriptions Meet Sensitive Data: The FTC and States Sue Hims & Hers
We have written before about the FTC's steady run of subscription enforcement, from Amazon and JustAnswer to Instacart and Uber. Separately, the FTC has pursued enforcement on the theory that health and sensitive data flowing to advertising platforms can violate a company's own privacy promises, in matters like GoodRx and BetterHelp.
Flags, Boots, and Dartboards—The FTC Is Coming for False American Origin Claims
By: Sara Skinner Chubb Companies marketing products with any variation of a "Made in the USA" claim — on packaging, labels, company websites, in social media, or anywhere else — should heed a clear message from the Federal Trade Commission that it is on the lookout for unsubstantiated claims and enforcement is a priority. On April 14, 2026, the FTC announced a coordinated enforcement sweep targeting companies for allegedly false "Made in the USA" claims.
From JustAnswer to Instacart: The FTC’s Latest Subscription Enforcement — InfoLawGroup LLP
by: Sara Skinner Chubb Since securing a landmark $2.5 billion settlement in September 2025 against Amazon for deceptive practices relating to Prime subscriptions, the Federal Trade Commission’s subscription program compliance enforcement hasn’t slowed. Subscription programs with inadequate disclosures and consents, misleading free-trial conversions and difficult cancellation flows are squarely in the FTC’s crosshairs. Here, we round-up recent FTC activity in the subscription compliance space.
Coke and Danone: The Latest Twists in the Green Marketing Legal Landscape — InfoLawGroup LLP
Earlier this month a New York federal judge tossed a class action filed against Danone Waters of America alleging “carbon-neutral” certification labels on its Evian water bottles were deceptive and misleading. In the complaint, customers claimed they believed the label meant the product did not produce any carbon emissions, which is not the case.
Text Message Litigation Du Jour: Taking Aim at Refer a Friend Texts Under Washington’s CEMA — InfoLawGroup LLP
by: Sara Skinner Chubb In what may emerge as a new trend in text message litigation, several class action lawsuits targeting “refer-a-friend” text message programs allege violations of Washington’s Consumer Electronic Mail Act (CEMA). Earlier this year, Robinhood settled a CEMA case filed in 2021 stemming from its refer-a-friend program for $9 million. More recently, class actions alleging CEMA violations have been filed against Block Inc., parent company of Cash App, and Capital One.
Text Message Litigation Du Jour: Taking Aim at Refer a Friend Texts Under Washington’s CEMA
In what may emerge as a new trend in text message litigation, several class action lawsuits targeting “refer-a-friend” text message programs allege violations of Washington’s Consumer Electronic Mail Act (CEMA). Earlier this year, Robinhood settled a CEMA case filed in 2021 stemming from its refer-a-friend program for $9 million. More recently, class actions alleging CEMA violations have been filed against Block Inc., parent company of Cash App, and Capital One.
Events, Productions and Promotions: Media Buying Beyond IAB 3.0 — InfoLawGroup LLP
The AAAA/IAB Standard Terms and Conditions for Internet Advertising for Media Buys One Year or Less Version 3.0 remain the standard governing terms in the media industry fourteen years after their initial release (although a Task Force of industry members, including Justine Gottshall on the ILG team, are hard at work on much needed updates). Throughout this time, the advertising opportunities offered by media companies continue to expand beyond traditional digital media placements.
The FTC and California Take Aim at “Junk Fees” — InfoLawGroup LLP
Last month, the Federal Trade Commission announced a proposed rule that targets unfair and deceptive practices relating to advertised fees for goods or services. Specifically, the proposed rule would prohibit companies from misrepresenting the total costs of goods and services by omitting mandatory fees from advertised prices and misrepresenting the nature and purpose of fees.
FTC Releases Updated Endorsement Guides: 10 Key Takeaways — InfoLawGroup LLP
by: Sophia Allen with contributions by Jamie Rubin, Ben Stein and Sara Chubb Just a few weeks ago, the FTC released its updated Guides Concerning the Use of Endorsements and Testimonials in Advertising (aka: the FTC Endorsement Guides). We’ve finished digesting the updates. Alongside the revised Guides, the FTC also released an updated set of Endorsement Guides FAQs and a proposed rule that would ban fake reviews and testimonials.
Feeling Ambushed by Ambush Marketing Season? Tips to Get Beleaguered Teams Through It
The beginning of February sees football fans putting finishing touches on Super Bowl snack spreads while official Super Bowl sponsors put finishing touches on high-production commercials featuring the NFL’s valuable – and aggressively protected – intellectual property. It is quickly followed by other massively popular cultural events such as March Madness and the Oscars. And every day, there are popular television, movie, and other pop culture moments driving public conversation.
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