16 CFR Part 429, Rule Concerning Cooling-Off Period For Sales Made At Homes Or At Certain Other Locations, FTC File No. P087109 #563691-00006 

Submission Number:
563691-00006 
Commenter:
John Gear
Organization:
John Gear Law Office, LLC
State:
Oregon
Initiative Name:
16 CFR Part 429, Rule Concerning Cooling-Off Period For Sales Made At Homes Or At Certain Other Locations, FTC File No. P087109

Rather than diminish the protections afforded by the cooling off rule, the FTC should instead make clear that all internet sales are presumptively governed by the rule, and require that sellers adhere to the rule for goods and services purchased over the internet except (1) When the "goods" consist of software that is downloaded immediately upon conclusion of the purchase transaction, or (2) when the buyer is informed, with a clear and conspicuous disclosure, that the cooling off period is limited to the lesser of three days or the period before delivers the goods to the delivery carrier for delivery to the consumer, AND, if the seller does not transfer the goods to the carrier within the promised period, then the buyer may refuse the goods at delivery and receive a full refund of the total price paid, including delivery charges.