Comment by db48x

> but your goalpost moving requirement of updating all marketing doesn't meet the bar for me there

I didn’t move the goalposts here. The new rules that are at issue here were about much more than just providing a button that cancels your subscription. See the actual text of the amendment to the rules <https://www.ftc.gov/system/files/ftc_gov/pdf/p064202_negativ...> if you don’t believe me. But I’ll quote the summary here:

    The Federal Trade Commission (“FTC” or “Commission”) issues final amendments to the Commission’s trade regulation “Rule Concerning Use of Prenotification Negative Option Plans,” retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs” (“Rule,” “final Rule” or “Negative Option Rule”). The final Rule now applies to all negative option programs in any media, and, among other things, (1) prohibits misrepresentations of any material fact made while marketing using negative option features; (2) requires sellers to provide important information prior to obtaining consumers’ billing information and charging consumers; (3) requires sellers to obtain consumers’ unambiguously affirmative consent to the negative option feature prior to charging them; and (4) requires sellers to provide consumers with simple cancellation mechanisms to immediately halt all recurring charges.