Naomi Caldwell
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In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”). The Rule sparked significant debate, with the original proposal garnering over 16,000 comments. Following some revisions based on this feedback, … Continue Reading
The Southern District of New York recently reconsidered its partial denial of Defendant Danone Waters of America’s motion to dismiss claims alleging Danone falsely advertised Evian water as “carbon neutral.” Reversing his prior ruling, Judge Nelson S. Román concluded that the carbon neutral labeling on Evian water bottle products was not plausibly misleading to reasonable … Continue Reading
Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule
By Baldassare Vinti, Jennifer Yang, Alyson Tocicki and Naomi Caldwell on Posted in Class Actions, FTC, Regulatory
S.D.N.Y. Waters Down Prior Ruling on “Carbon Neutral” Consumer Deception Claim
By Baldassare Vinti, Jeff Warshafsky and Naomi Caldwell on Posted in Class Actions, Deceptive Trade Practices, Labeling Claims
