On June 23, 2023, WLF joined a coalition of legal-policy groups in a formal comment on proposed amendments to the FTC’s Negative Option Rule. The proposed rule is aimed at combatting unfair or deceptive practices arising from recurring charges for products or services consumers do not want and cannot cancel without undue difficulty. As the comment explains, if the FTC is to have the authority it claims in the rule to impose civil penalties for ordinary misrepresentations, even for certain classes of transactions, only Congress can confer that power—and only by amending the Act. The comment was prepared by Tech Freedom’s Berin Szóka.