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FTC Updates (December 8 – 12, 2025)

By Megan L. Wolf & Kari Ferver on December 22, 2025
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Federal Trade Commission
The building of the Federal Trade Commission in downtown Washington DC.

The FTC has been active in the consumer protection realm this week, issuing refunds and warning letters, releasing Do Not Call Registry statistics, and announcing a new workshop. The FTC also denied a petition to reopen a long-running consent order related to “stalkerware” apps. These stories and more after the jump.

Monday, December 8, 2025

Bureau of Consumer Protection: Children’s Online Privacy Protection Act (COPPA)

  • The FTC announced an Age Verification Workshop scheduled for January 28, 2026. The workshop will be held in person at the Constitution Center in Washington, D.C. and webcast access will be available as well. The workshop promises to bring together researchers, academics, industry representatives, consumer advocates, and government regulators, and the event is open to the public.  Topics include regulations governing age verification, why age verification matters, existing tools for age verification and estimation, and the interplay between these tools and the COPPA Rule, which imposes certain requirements on operators of online services directed to children under age 13.  

Bureau of Consumer Protection: Stalkerware & Data Security

  • The Commission denied a petition from Scott Zuckerman to vacate or modify the FTC’s December 20, 2021 Consent Order involving Mr. Zuckerman and his company, Support King, LLC, which did business as SpyFone.com or SpyFone. The FTC’s 2021 complaint alleged that Zuckerman, via SpyFone, used “stalkerware” apps to harvest and share data on consumer movements, phone use, and online activities. The parties entered into a Consent Order in 2021, under which SpyFone and Mr. Zuckerman were (1) banned from promoting, selling, or advertising any surveillance apps, services, or businesses; (2) instructed to develop an information security program for SpyFone; and (3) directed to obtain third-party biennial assessments of said information security programs. In June 2025, Mr. Zuckerman petitioned to reopen this Consent Order on the grounds that it created an excessive burden on his new business ventures while serving no ongoing purpose. The Commission, after hearing public comment on the petition, denied it on the grounds that (1) Mr. Zuckerman showed no changed conditions of fact or law to justify reopening the Consent Order, and (2) maintaining the Consent Order was in the public interest.

Tuesday, December 9, 2025

Bureau of Consumer Protection: Property Management Software

  • The FTC sent warning letters to thirteen property management software providers to outline concerns with certain property management software practices that may violate the FTC Act and the Gramm-Leach-Bliley Act. Specifically, the letters highlight how property management software programs do not always display complete pricing information, including the total monthly rental price inclusive of all fees. The software also can restrict the ability to aggregate or convey cost information to consumers on third-party listing sites. The letters allege that this conduct harms consumers and may constitute unfair or deceptive acts in violation of the law. The letters summarize recent successful FTC enforcement actions in the rental housing market and conclude by asking the recipient to conduct a “comprehensive review of your practices” include websites and software.

Bureau of Consumer Protection: Billing Scams

  • An FTC complaint, filed in July 2024 against Legion Media and related companies and defendants, has been unsealed, and the FTC is now sending payments of over $27.6 million to consumers in relation to a trio of stipulated settlements filed in federal court in September 2024. The FTC alleged that the defendants defrauded consumers who purchased CBD and Keto-related products by charging more than the advertised price and enrolling them in plans without consent that continued to charge the consumer for products the consumer never intended to purchase. The payments are being issued to more than 1.2 million affected consumers via check or PayPal.

Thursday, December 11, 2025

Bureau of Consumer Protection: Deceptive Marketing

  • The FTC sent over $9.6 million to consumers in relation to a settlement in July 2024 between the FTC and CarShield, a seller of vehicle services contracts. The FTC’s complaint alleged that CarShield’s advertising and telemarketing for the contracts was deceptive and misleading, because the contracts called for consumers to make monthly payments for repairs that were not actually covered. CarShield and its contracts administrator, American Auto Shield, LLC, are prohibited under the settlement from making deceptive and misleading statements when advertising vehicle services contracts. The FTC is issuing payments to over 168,000 impacted consumers.

Bureau of Consumer Protection: Property Management Software

  • The Commission released its annual National Do No Call Registry Data Book compiling statistical data about the Registry. The number of active registrations on the Do Not Call List rose by nearly 5 million from 2024 to 258,515,050. The number of complaints received increased as well, with the FTC receiving over 2.6 million Do Not Call complaints annually. The majority of the complaints concerned robocalls, consistent with prior years. The nature of the topics in the calls at issue varied from debt reduction schemes, to medical and prescription issues, to outright impostors.
Photo of Megan L. Wolf Megan L. Wolf

Megan Louise Wolf is a partner in the firm’s Washington, D.C. office. Megan’s practice focuses on antitrust counseling, mergers and acquisitions, and criminal and civil antitrust investigations. Named as a “Rising Star” by Legal 500 and The Deal, Megan counsels and represents…

Megan Louise Wolf is a partner in the firm’s Washington, D.C. office. Megan’s practice focuses on antitrust counseling, mergers and acquisitions, and criminal and civil antitrust investigations. Named as a “Rising Star” by Legal 500 and The Deal, Megan counsels and represents clients in a wide range of transactional antitrust matters, including mergers and acquisitions, joint ventures, competitor collaborations, and issues related to compliance with the Hart-Scott-Rodino Antitrust Improvements Act. Megan represents corporate clients and individual executives in criminal antitrust investigations, including those into procurement fraud, hiring practices, financial services, generic pharmaceuticals, and numerous other industries.

Read more about Megan L. WolfEmail
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Photo of Kari Ferver Kari Ferver
Read more about Kari FerverEmail
  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Retail & Consumer Products Law Observer
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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