16 CFR Part 425: "Rule Concerning the Use of Prenotification Negative Option Plans" #541909-00007

Submission Number:
Keisha Oldacre
Initiative Name:
16 CFR Part 425: "Rule Concerning the Use of Prenotification Negative Option Plans"

The FTC's current rule and policies surrounding negative option plans should not only continue, but should be expanded to cover other types of negative option plans such as continuity and automatic renewal plans. Given the increasing use of the internet for consumer purchases, the need for regulation in this area has greatly increased since the 1980s. Recently, I was "duped" into a hybrid continuity/automatic renewal plan with a company promising a free "30-day" trial of Resveratrol. In fact, the supply of the dietary supplement is 30 days' worth, but, unbeknownst to me, the "free trial" was only extended for 15 days. Admittedly, I didn't read every word on every page of the website. If I had, I would've discovered this somewhere amidst the fine print. But, these companies are very tricky. They use giant promising print to suck in the consumer, and tuck the true details of the "deal" on other pages of their website in much smaller print. Embarrassingly enough, I must admit that I am a recent law graduate and should know better. I never fall for these offers. I think that cuts even more in favor of not only continuing but strengthening the regulations surrounding negative option plans. If these companies are able to scam someone who graduated summa cum laude in English and in the top third of her law school class, they are very, very skilled in the trade of deception. Consumers need to be protected from such practices.