FTC announces "click-to-cancel" rule making it easier to cancel subscriptions

I am very curious what exactly this means? Is it the number of pages or forms you had to fill out? People you had to talk too?

So if for my internet I had to have someone come out to install it before service would start could they argue that they require someone to physically come out to turn off service? Or a call since a call would be "easier" than someone coming out?

Could they make the signup and cancel process worse at the same time at certain times of the year if there is a certain time of the year where cancelations are high to justify a worse process? Or does this require knowing what the process was like when each customer signed up?

It feels like this could be fairly easily manipulated. Throw in an extra page during sign up just so they can add in an extra "please stay" page when you try to cancel.

> most notably dropping a requirement that sellers provide annual reminders to consumers of the negative option feature of their subscription.

I assume this means sending yearly reminders that a subscription is about to charge and how to cancel? This is fairly disappointing if so.

I really wish they just required what Apple requires on the App Store. It requires 2 clicks, clicking cancel and then confirm. No upselling since it all happens within Apple's Settings.

Then any yearly apps I always get an email about a week or so (not 100% sure of the timing) that it is going to renew soon with instructions on how to cancel.

Litigation could resolve malicious attempts to "complicate" signups for the purposes of complicating cancellation.

I am struggling a bit to understand how Comcast could not argue that it is required?

I don't fully remember but I don't think I started paying anything for my service until someone came out to install when self install wasn't an option. (I could possibly see them justifying removing self install in the name of retention later, since how many people really have a choice in their ISP and will just not deal with waiting for someone to come?).

If service was unable to start until someone came out, to me that could be argued as part of the sign up process.

I am not necessarily agreeing that it is part of the signup process. But we know that these companies love their shady practices and will have their lawyers finding any loophole they can find.

In the case of in-person consent the rule requires that they also offer an online or telephone cancellation option.

> Could they make the signup and cancel process worse at the same time [...]

"must be at least as easy to use as the mechanism the consumer used to consent to the Negative Option Feature.". I read that it must hold true for every specific consumer based on how hard it was for them to consent.

The rules also sets general restrictions to the online and phone options in addition to the "at least as easy" restriction. For Online the cancellation option must be "easy to find" and explicitly bars forced interaction with representatives or chatbots during cancellation unless they were part of the sign-up process. For Telephone the cancellation must be prompt, the number must be answered or accept voice messages, must be available during normal business hours, and must not be more costly than a call used to sign up.

It's complicated.

If all anti-piracy measures were enforced successfully, such as they are on Apple platforms; if there were insurmountable paywalls everywhere; but, subscriptions were cheaper, would you be better off? What about the average person? What is the right policy?

Is there a requirement that a signup flow is a single process that you do all at once?

What if they just moved the last contract you had to sign to something that you clicked on the technicians phone after they set everything up?

I get that it is part of the install process and we think of it as a different phase. But in reality how much of a diasctintion is that really?

I am trying to understand what is realistically stopping Comcast from saying that the signup process is not complete until service has been activated? Nothing I am seeing or what is being said here is telling me they could not argue this.

> If people originally signed up for your program in person, you can offer them the opportunity to cancel in person if they want to, but you can’t require it. Instead, you need to offer a way for people to cancel online or on the phone.

In theory, the economics of this don't work out (Comcast/ISPs might be an exception). It would raise their onboarding costs a lot and raise their offboarding costs too. But if they're a local monopoly the might get away with it.

Like how multiple courts (up to the Louisiana Supreme Court) ruled that it was reasonable that when a suspect said "I want a lawyer, dawg." that police interpreted it as him asking for a canine who had been admitted to the bar, and since they couldn't find one, he had not made a valid request for counsel, and so they were free to continue to interrogate him without one, and not be in violation of his rights?

Or how about SCOTUS ruling that in order to invoke your right to remain silent, you actually have to state that you are doing so specifically, and that merely remaining silent doesn't mean you are ... remaining silent?

That kind of reasonableness?

Captcha games are going to become an olympic sport.

We have an epidemic of overly-textualist, conservative courts living in an alternate reality.

Now only are these people unreasonable, they strive to be as unreasonable as possible, in order to project their political will of stopping progressivism, whatever that may mean to them.

Plenty of them are in the business of stopping regulation purely for the sport of stopping regulation, meaning regardless of what the regulation is.

That doesn't side step this - if you sign up in person they have to provide a telephone or online option to cancel that is just as easy as it was to sign up.

Now you'll need to return the hardware if you're using Comcast's hardware. Nothing changes there.