Comment by axus

Of course now that the FTC rule is well known, anyone designing a new system would require click-to-cancel. The new burden is low, but at the time the big companies probably spent millions to fix it.

A more extreme example would be the US Clean Air Act and how the EPA extended the rules to regulate carbon dioxide emissions. Obviously going to cost a lot of money, but a necessary change to dodge climate disaster. That rule had to wait for Congress to pass the Inflation Reduction Act to become legal. Hopefully this minor consumer protection rule will be supported by Congress as well.