Tracy Marshall

As we discussed in Part 1 of this series, while the Children’s Online Privacy Protection Act (COPPA) remains the primary federal law protecting children’s online privacy, there is a growing patchwork of state laws aimed at protecting both children and teens online. These laws identify a variety of potential harms, but many of them expand the universe of businesses subject to “children’s privacy” obligations and greatly complicate their compliance challenges.

In the midst of the busiest shopping season of the year, Federal Trade Commission (FTC or Commission) staff reminded companies of their obligations under the Rule on the Use of Consumer Reviews and Testimonials (Consumer Review Rule).

Businesses making negative option or auto-renewal subscription offers, beware: Federal Trade Commission (FTC or Commission) enforcement is alive and well in 2025. Although the U.S. Court of Appeals for the Eighth Circuit struck down the FTC’s much-criticized Biden-era “click to cancel” rule earlier this summer, on September 25, 2025 the FTC announced that Amazon.com, Inc.