Prospective Relief - Practice Changes. Prospectively, Defendant is revising the presentation and wording of the automatic renewal terms on the checkout pages in its mobile and desktop platforms and in its direct mail offers to be consistent with the requirements of Cal. Bus. & Prof. Code § 17602(a)(1)-(2). Defendant agrees to provide consumers who submit an order for a new automatically renewing subscription with an e-mail or paper acknowledgment (appropriate to the method of subscription) that includes the automatic renewal terms, cancellation policy, and information regarding how to cancel in a manner that is capable of being retained by the consumer, consistent with Bus. & Prof. Code § 17602(c).
Prospective Relief - Practice Changes. Prospectively, Defendant agrees to present on the checkout page the automatic renewal offer terms (including cancellation policy) in a clear and conspicuous manner before the subscription or purchasing agreement and in visual proximity to the request for consent to the offer and obtain affirmative consent to the agreement containing the automatic renewal terms in a manner that substantially complies with the automatic renewal laws of the states at issue. Defendant further agrees to disclose, in a manner that substantially complies with the automatic renewal laws of the states at issue, how to cancel and by when in an acknowledgment email that is capable of being retained by consumers. The costs to Defendant in implementing these changes are estimated to be at least $250,000.
