US Court nullifies FTC requirement for click-to-cancel
237 comments
·July 8, 2025pjmlp
The consumer protection laws are so bad the other side of Atlantic.
Most European countries, have their own version of consumer protection agencies, usually any kind of complaint gets sorted out, even if takes a couple months.
If they fail for whatever reason, there is still the top European one.
Most of the time I read about FTC, it appears to side with the wrong guys.
aqme28
Absolutely. I don't know if it's the FTC or FCC, but the moment I swap back to my American SIM card on trips to the US, I start getting spam texts that I cannot get rid of. Meanwhile I get absolutely zero of these with my European number.
sabellito
Consumer protection laws are mostly fine in Brazil and Uruguay, and I'd bet also on more countries on the other side of the Atlantic.
mrtksn
True but generally speaking American companies usually have much better customer service and better refund policies than European ones. The issues usually stem when a company corners the market or has no viable alternatives.
So maybe the American way of doing things can also work if a healthy competitive environment is preserved.
The problem lately is that American companies have become monopolies and the formula firms extracting profits or stock hikes for the shareholders dictate that they screw the user up until barely legal territory.
So maybe America can roll without consumer protection laws and agencies if they can fix the business environment.
They just need to find a way out of enshittification, a process US companies perfected.
mokash
>True but generally speaking American companies usually have much better customer service and better refund policies than European ones. The issues usually stem when a company corners the market or has no viable alternatives.
this does not track with my experience
mrtksn
Any examples of American company having worse customer experience than European ones?
I will give you 2 for the opposite: Amazon and Apple do no question asked refunds all the time. Much higher bar than European regulators require.
kkosser
Delusional.
delfinom
Not the FTC's fault.
The problem is US congress has not functioned for 2 decades. They no longer pass actual laws. This means the FTC is stuck reinterpreting their existing powers to try and squeeze out regulation that they can but that's it.
sneak
If the FTC can’t do what the FTC is supposed to do, then that is the FTC’s fault for continuing to exist. It’s unfit for purpose and should be shut down.
evilduck
The FTC have no say in choosing to exist or not exist, or what laws are passed that they are supposed to enforce. In some cases, an agency intentionally choosing to not carry out their duties would even be breaking the law and subject to penalty or punishment. How the FTC goes about interpreting their duties and then the court system correcting their behavior when they disagree or misbehave is the system working as intended. If they don't have laws to interpret for an issue though, that's a legislative problem.
The real question is why isn't congress doing their job? They control both the existence and funding of the FTC and additionally the laws the FTC are tasked with interpreting and enforcing. If congress is unfit for purpose they should be replaced.
sorcerer-mar
Even if we were to accept your premise (if broken, throw out), it's still Congress that decides whether the FTC exists or not.
xphilter
The ftc isn’t supposed to create laws though. I tend to overshoot on the consumer’s side, but the ftc is overstepping with actions like this. There should be a law passed on this point and then ftc can enforce. Or ftc can sue based on existing law and let courts buy their interpretation.
b00ty4breakfast
neoliberal deregulation and regulatory capture, not necessarily in that order, has basically killed federal consumer protection in the US.
scrubs
And it can get worse. Over shooting right (left) invariably leads to overshoot left (right) which we absolutely do not need either.
The American sense (when we get off our butts and do it) is common sense, slowly changing law that always apportions control in equal parts to accountability.
It's the last part that is more galling (because increasingly we've failed) and ultimately will be the more decisive in any future inflection point.
Arubis
When we “overshot left” it was by electing a centrist cishet man who identified as Christian and had different colored skin from the prior presidents.
Overshooting right has us building concentration camps.
idiotsecant
I think the century of American dominance is probably over. Maybe we can fight our way back to having a functional government, maybe not. I think either way our position in the world order is already diminished and will steadily diminish further. I can see a future where America is a strange backwater, reliant on resource extraction and rules over by a grubby and constantly shifting mafia state.
MSFT_Edging
When has the US actually overshot left though? There was a short period of social justice awareness, but that didn't translate to actual leftwing economic legislation. Even protests and movements with left wing goals were co-opted by the nominally center-right establishment and neutered.
This both-sides stuff gets me, man. Our history is by and large very right wing and every time there's a flutter of left leaning ideas, people chalk it up to some far-left political success and therefore the far right backlash is deserved, as if things ever actually went left in the first place.
fuzzy_biscuit
I don't see the neoliberal deregulation you're talking about, so I'll bite.
Regulatory capture I have seen too often e.g. net neutrality getting killed by a Verizon cronie masquerading as a public servant in the FCC. However, from my perspective, it's been mostly conservative powers undoing consumer protections. Unless you mean liberalism in the more European sense, in which case I agree.
nyeah
"Neoliberal" means free markets. Most US conservatives insisted on free markets from the 1980s until 2016, claiming it would benefit the overall US economy (and maybe it has), and claiming those benefits would be shared by all Americans (which listen to them now).
claytongulick
Did you read TFA? This had nothing to do with neoliberalism or whatever.
Everyone agreed with the spirit of the rule, even the two republican appointees who voted against it.
They voted against it because the FTC cheated and broke their own rule making process, they believed it would be struck down by the courts because of this.
They were right. The courts sympathized with the rule, but held that the FTC cheated it's process, and that if left unchecked it could create a tyrannical FTC issuing rules at their whim, ignoring the true economic impact of their rule.
All this court ruling said is that the FTC needs to follow the law and their own defined process for rule making.
They are free to implement this rule, they just need to do it the right way.
While we may not be happy with the short term effect, this was a good ruling. The FTC will go back and do this properly, and hopefully next time will follow the law when making rules.
beezlewax
I've used a learning platform called Brilliant in the past. The cancellation process was so convoluted that it was impossible to cancel the account. Dark patterns and confusing language.
They refused to refund me and after I thought I'd cancelled and I had to run a charge back from my bank.
This is nefarious behaviour on their part and consumers need to be protected from it.
trueismywork
In contrast in EU, I sent an email to my service to cancel and they forgot to cancel. I just sent them another email with proof of email and they realised they missed the old one and canceled retroactively and refunded money to my account.
fuzztester
Do you mean brilliant.org ?
injidup
I call bullshit. https://help.brilliant.org/en/articles/741701-how-can-i-canc...
whycome
What happens when you click the link in that article?
“You can cancel your subscription at any time by clicking the "cancel" button on your subscription settings page, here.“
It leads to a 404. With the benefit of the doubt, I’m not logged in — but it shouldn’t lead to a 404.
everdrive
One consequence here that people need to think about is that ALL subscription services should be viewed with suspicion. Once you sign up how much of your life will be deranged simply by trying to cancel the service. It's a hidden cost which shouldn't be forgotten.
quitit
This is one of the reasons why providers -hate- IAP subscriptions, even if the profit share was 0%, they'd still not be happy because with IAP it's just one click to cancel.
It's not even a practice limited to "shady" companies, the New York Times would let you sign up online, but only cancel via a convoluted phone call with one of their subscription retainment reps.
These days you're better off obtaining a credit card which lets you instantly block transactions. These companies with their b/s unsubscribe gauntlets aren't worth your time.
cyral
Well, the "one click" cancel is hidden deep in the settings app - and when customers contact us asking to cancel, they don't like to hear that we cannot cancel or refund them from our end. (Apple doesn't even provide a way to look up the customer. Most people don't understand that Apple is actually managing the entire billing process)
pona-a
So there's a business argument for this regulation. If the consumers feel unsafe giving their credit cards to most companies, they'll spend less on subscription services in total, harming the industry more than they gain from milking zombie customers.
whycome
Is zombie customer an official term. And how much of their profits are from that sector? Is this like airlines over selling seats?
fwlr
The FTC was warned at the time that they were flouting required procedures and that their rule would therefore not survive legal scrutiny. Lo and behold it did not.
hshdhdhj4444
Please point to an example of these warnings.
VWWHFSfQ
> The FTC is required to conduct a preliminary regulatory analysis when a rule has an estimated annual economic effect of $100 million or more. The FTC estimated in a Notice of Proposed Rulemaking (NPRM) that the rule would not have a $100 million effect.
> But an administrative law judge later found that the rule's impact surpassed the threshold, observing that compliance costs would exceed $100 million "unless each business used fewer than twenty-three hours of professional services at the lowest end of the spectrum of estimated hourly rates," the 8th Circuit ruling said. Despite the administrative law judge's finding, the FTC did not conduct a preliminary regulatory analysis and instead "proceeded to issue only the final regulatory analysis alongside the final Rule," the judges' panel said.
It says it in the article
braiamp
The fact that it takes more than 24 hours to put a 1 click cancel button is alien to me.
guelo
Why are you pasting the article when it doesn't include any warnings that were given to the ftc at the time?
guelo
who warned them?
Hnrobert42
A then-commissioner who is now the head of the FTC.
guelo
That commissioner also hated the fact that consumers were going to stop being robbed by big corps.
dboreham
Because systematic corruption presumably?
tbrownaw
More that they mistakenly thought that doing the right thing meant they didn't have to do the thing right.
bjt12345
But, if you want to make it look like you are doing the right thing but don't want to be remembered as having done that right thing, maybe this was the right thing to do given that now it won't be done.
techpineapple
Right, if they were screwing over customers, we’d call it disruption and give them a medal, if not $1 billion dollars. Since they’re trying to help people, we wag our fingers at them.
weberer
>they were flouting required procedures
jibe
If you are sniffing out corruption, aren’t the ones flouting required procedures likely the corrupt ones?
hshdhdhj4444
Almost never.
Whistleblowers are almost always revealing information that they are legally prevented from revealing, otherwise you wouldn’t need a whistleblower. A simple FOIA request would suffice.
Aeolun
Kinda, but corruption in my favor is unlikely to see me complain about it.
wqaatwt
What if the “required procedures” are held in place by corruption?
db48x
For those of you wondering what the actual decision says: <https://ecf.ca8.uscourts.gov/opndir/25/07/243137P.pdf>
xedrac
I always felt like those click to unsubscribe links were nothing more than a "please prove to us with certainty that this is an actively used account so we can set a sticky bit on it and sell that info for $$$"
orev
That’s a commonly held idea for spam emails. This is about services you’ve signed up and pay for on a recurring basis, and was targeted at companies who make it very easy to open an account, but then require byzantine methods to cancel.
whycome
It’s like browser popups that only give you the option of block or allow. I want neither! Block means I add that site to a permanent local list and I really need no record of it at all.
DANmode
That is a valid paranoia,
but also, not the kind of subscription the article is about.
globalnode
just mark them as spam, hurts them more and doesnt notify them of anything.
SuperSandro2000
3rd world country customer protection laws...
Irongirl1
FYI: Everyone just use privacy.com
It allows you to make virtual cards that are single use.
So if a merchant keeps trying to charge you, it will automatically decline.
Until the powers that be gets its act together and stops allowing businesses to run all over us...this is the way.
Shank
> So if a merchant keeps trying to charge you, it will automatically decline.
I learned this the hard way with the New York Times doing this, but merchants can “force settle” a transaction if they want and it’ll override the decline they get. This is a violation of the merchant agreement but companies do it anyway (like NYT did to me). Privacy isn’t as bullet-proof as you would think.
reginald78
Yes, Capital One offers a similar virtual card service and when I read into the fine details it wasn't as useful as a thought. There were seemingly exceptions that could override spending limits for subscriptions and the control was mostly an illusion.
DaSHacka
How could it override the decline if you cancel the card entirely in Privacy?
crazygringo
Then it just gets sent to collections, and worsens your credit score, so your next car loan or mortgage has a higher interest rate.
You have to actually resolve the issue with the company charging you, and do a chargeback if necessary which requires submitting evidence. It sucks, but virtual numbers don't make your bills go away.
KomoD
Then you risk getting sent to collections instead.
ourmandave
Privacy.com is a fintech platform offering virtual debit cards to secure online transactions. Based in Iceland and partnered with FDIC-insured banks, the service allows users to control card usage through pausing, unpausing, or closing. Privacy.com prioritizes security through firewalls, encryption, and PCI DSS compliance.
blendergeek
> Privacy.com prioritizes security through firewalls, encryption, and PCI DSS compliance.
That line of cyber security mumbo jumbo does not inspire confidence
bramhaag
Is there anything like this that accepts EU customers?
pimterry
Revolut along with quite a few other modern EU banks let you manage recurring billing directly - in Revolut I can pick any transaction in the app, click "Block future payments" and that vendor won't be able to bill my card again until I unblock them. That's separate from virtual/disposable cards - you can use your normal card and still block individual vendors.
Honestly this seems like a pretty obvious core banking feature nowadays, I'm surprised it's not more widespread (even in the US - reliable cancellation features across all recurring card payments would surely make people more comfortable with subscriptions). Under the hood all banks (AFAIK) are handle recurring payments by issuing an authorization token at first purchase, and validating it on later transactions. Allowing customers to see the list of active tokens that were recently used and then revoke them explicitly seems like a no brainer.
sensanaty
Revolut has a disposable card feature. I'm sure there's some regular old school banks that have this as well, ING in the Netherlands does as far as I remember.
anon191928
revolut and others still try to charge you, even if you cancel the VIRTUAL card. when you ask them, why and how they you do that, they say you have some sort of agreement for the subs. service and you need to end it on your own via them. Bank can't do that?? they said something like that to me. So they literally support the dark pattent side, not on your side obv.
diggan
Your bank might offer this already, just to check in case you haven't already. I think all banks I've had in Spain and Sweden has offered this feature within their web portal.
firesteelrain
Never heard of this; thanks for the tip!
mrheosuper
Great, another service that collects my purchase information.
Hnrobert42
This is why I've never used these services.
postalrat
I should be able to go into my bank or card service online. View a list of all my subscriptions. Click on a subscription (or select all). And cancel.
If there is a card that offers this let me know because I'll be switching immediately.
astatine
You can absolutely do this in India. Every card based subscription requires an explicit authorization to set up. And every such authorized subscription can be seen in the bank app/site. You can choose to cancel those subscriptions at the bank end and the subscribed services will fail their next renewal. This is not just a service specific thing and is required by regulation for all recurring payments, incl utility bills, insurance premia, entertainment service, cloud services.
wobfan
Not gonna lie, I actually have canceled many service because of this single reason. If I get the feeling they want to hide these options specifically to keep me in a subscription, I immediately feel the urge to cancel even more, and also it gives me the feeling that the service itself is obviously, objectively, not good enough that they can just be honest and offer a easy cancel option - because they fear that too many people would.
tonyhart7
You are absolute minority that conscious about your financial but sorry to tell you that "most" people is "forgot" they sign up something and not open it in years
that's happen more often than you think
also financial illiterate is real
LoganDark
> You are absolute minority that conscious about your financial
Maybe but idk. I have calendar events for every single monthly expense & BNPL. Anything that isn't on-demand is in the calendar. That makes it easy to calculate future expenses and also serves as a reminder of what I'm paying for so I can cancel anything I don't think I'll need for a while. At least one subscription I've canceled and restarted a lot because I use it a bunch and then don't use it at all and then use it a bunch again and so on.
I also have a spreadsheet that I log every transaction into, because it gives me an easy way to see how my finances are doing and also gives me a way to keep track of charges that aren't properly descriptive on their own (for example, "wl *steam purchase" doesn't say which product was purchased; on the spreadsheet, I can see exactly, as well as for every other transaction, what I purchased, without having to look at each individual order). It's also faster to check than having to log into my bank, which ever since I switched to Mac has been forcing me through SMS verification every single time I log in no matter what.
rlpb
Legally, this isn't sufficient. Your subscription contract is independent of your payment method. If you don't pay, that doesn't necessarily mean that your subscription is cancelled, and you could end up in court and lose.
What is necessary is regulatory (or statutory) enforcement of easy, online notice of cancellation, without a company able to frustrate you giving them (and them recording and acknowledging) that notice.
babyshake
You can use privacy.com as another commenter has written. But one catch is I believe you can be on the hook for subscriptions where your card no longer works but you haven't cancelled your subscription. So they can send you invoices and even send it to collections. Although I strongly feel that at least for transactions of a sufficiently small size (normal retail subscriptions) cancelling your card should be legally considered sufficient enough for voiding your future subscription. I'm open to hearing counter arguments but I think the consumer shouldn't have to jump through even the smallest of hoops setup by vendors in order to indicate that they are no longer interested in future transactions.
anonzzzies
I always try via official means, but, failing that, I just cancel the (virtual) card. I have been threatened a lot that if I do that, my first born will be punished etc but of course nothing ever happens. I don't live in the US though.
venkat223
This type of activity is happening with Amazon Netflix and other medias also with various E-Commerce sites Apple particularly is asking for all particulars train to debit after the expiry of the period but is not allowing cancellation properly as the bandwth work remains down in many many areas sporadically we are not able to cancel at will.This is a user unfriendly activity which is monopolistic or coercive.People will lose faith in digitization slowly
vincenzothgreat
use an alias with an alias email, the Privacy.com card will accept any name and address. Never had any sort of issue in all the years using them
LiamPowell
Simply move to Australia, all the major banks here offer this service: https://payto.com.au/
Not all services offer this yet, but it's gaining momentum, especially with Amazon now offering it for non-subscriptions.
missedthecue
I had a recurring charge on my Capital One credit card and canceled it from my Capital One app. The next month, the charge went through again and they proactively gave me an account credit equal to the charged amount, with an emailed apology. I'm not sure why they couldn't cancel it, or if it will go through again this month, but it surprised me!
nico
I had a subscription with an account that I couldn’t access anymore, and there wasn’t any other way to cancel
So I contested the charge through the bank. They would refund me, but then the company would charge me again for the subscription
This went on for several months. At some point the card expired, the bank automatically sent me a new card, and somehow the company was still able to charge the subscription to my new card, even though I couldn’t even access my account
It was a couple of years ago, and I don’t remember how I finally stopped it. But it was kinda shocking to me to see the charges “jump” through different cards. Especially given that usually any service that I don’t want cancelled, gets immediately cancelled if my card on file expires
__david__
Credit cards explicitly do a type of forwarding so that your old subscriptions continue to work if you get a new card. If you ever tell your bank that you've lost your card or had it stolen then they will reissue it differently without that "forward" feature, to prevent fraudulent activity. I learned this when I had fraudulent activity on my card and they accidentally did a normal reissue, and so the fraudulent activity continued even after I got the new card.
pimterry
The company doesn't actually keep your card details at all (at least, all reputable companies). They take the details to the payment processor at first purchase, but they then get swapped for a token which can be used to process transactions (usable only for transactions to you by this one vendor, so tokens can't be stolen/leaked, unlike card details) and then future transactions all just use the token.
When your card details change, all issued tokens generally stay valid, they're effectively independent. A payment card is basically an initial authentication process for the account, it's not really the payment method.
sebbadk
I work for a company called Subaio that does exactly that, but it only works because EU (and some other countries) consumer protection laws requires that companies have to let us cancel subscriptions. So we're mostly working with european banks for now.
The protection specifically requires that cancelling is at least as easy as signing up.
average_r_user
Could you point me to some European banks that integrate your product? My current bank doesn't have something similar, and I would like to have an option to view all my subscriptions at a glance
null
thanatos519
Here in the Netherlands, via my bank I can list all of my pre-approved transfers and block them. I'm pretty sure every bank here is required to support this. PayPal also has this feature.
I recently had to cut down on expenses starting with extraneous subscriptions and charitable donations, of which I had dozens. Many ad a click-to-cancel or at least fill-out-a-form-to-cancel process, but some of them said 'call us'. Then I discovered that I could cut them all off from my side!
I got a few 'hey your donation stopped' messages, and answered the first ones, but they all eventually went away.
ldsd
Be careful there. You can block further payments, but that won't necessarily cancel your subscription.
You may still be responsible for the payment, and may need to pay collection fees as well at that point.
bpodgursky
From a different article [1]:
> But the U.S. Court of Appeals for the Eighth Circuit said the FTC erred in its rulemaking process by failing to produce a preliminary regulatory analysis, a statutory requirement for rules whose annual effect on the national economy would exceed $100 million.
> The FTC had argued that it was not required to prepare the preliminary analysis because its initial estimate of the rule’s impact on the national economy was under the $100 million threshold — even though ultimately the presiding officer determined the impact exceeded the threshold.
This is a case where congress really did pass a concrete law, and the court is requiring the FTC to follow it. Sucks that a reasonable rule is getting voided for the sloppiness but I really don't think the courts are indefensibly out of line.
[1] https://thehill.com/policy/technology/5390731-appeals-court-...
skort
It's interesting that businesses can build an obviously toxic subscription model that robs consumers of both money and time, but when asked to change it now we have to consider their costs.
I understand the idea behind the threshold for changing rules but this still feels very broken. There is a constant struggle of having to do everything perfectly to make any positive progress, but bad actors can operate however they like with seemingly little repercussions.
avhception
While I share your frustration, I don't think we should lower the bar for positive progress. Because that's how one becomes a bad actor themselves.
braiamp
The bar should be where changes happen to move in the correct direction easily, while moving in the incorrect direction harder. If the rule was to "force companies to have confusing cancel processes", the rulemaking process would have zero burdens, because the "potential gains" of doing so would be enormous.
matthewdgreen
I think we should absolutely lower this particular bar.
immibis
When bad actors have a low bar but good actors have a high bar, the country is bound to collapse. Look at how many rules the current regime is flouting. But the other side has to dot every i for some reason.
hamilyon2
I am not getting it. The rule makes competition in markets higher. Because dollars flow to best offers faster. And thus improve economic situation, not only in markets affected by rule, but also on all other markets, in case customer wants to take his money elsewhere.
And on international scale, because more competitive companies presumably out-compete foreign competitors.
So, FTC needs some permission and review to make national economy money?
sokoloff
The FTC was not given unlimited rule-making power by Congress, and has to live within the power granted to them.
Issuing an NPRM (Notice of Proposed Rulemaking) and conducting a regulatory analysis for certain rules are examples of such limits. The FTC did not follow the second (as was required) in this case.
Whether I happen to agree with the change they enacted (I do) doesn’t change the fact that I want my government agencies to follow the rules laid out for them. Because as surely as the sun rises in the east, sooner or later they’ll propose a rule I don’t agree with and I want there to be a lawful process and framework in place then, and therefore also now.
MangoToupe
A major unwritten rule of american society is that there is no bigger crime than economic friction to the shareholder... including statute itself.
jordanb
From googling apparently the "presiding officer" is appointed by the FTC chair. So it sounds like the FTC spiked its own case.
bpodgursky
It was Lina Khan. She just felt strongly about going out the way she came in — losing every single case.
jordanb
There is a new FTC administration.
I interpret this as being the incoming FTC wanted to kill this but not withdrawal (due to bad optics).
They wanted to lose the case and did so by changing a judgment they controlled so that the rule could fail a legal procedural challenge.
fxtentacle
Illumina, Tapestry, Kroger, Lockheed Martin would disagree.
Also, didn’t she „build“ the right to repair laws?
sameermanek
Devil is in the details, they said each company would have to pay for less than 23 hrs to a low level engineer to avoid the $100 mil impact.
How much time do you think an intern would need to render a button on screen that says "cancel" in red mapped to an already implemented function in the code base. Especially with trillions poured into the AI?
This is non sense and horse shit, and these bench full of idiots know it
arzig
There’s a non trivial chance this interacts with credit card processing. There is also app the legal liability of you tell someone meet are cancelled and continue charging them. So probably so not something you trust an intern to do.
fzeroracer
This is stuff that companies already handle with their current cancellation pipelines. Hooking up a short circuit that flags whatever user in their DB as having cancelled is something that I would absolutely toss a junior engineer at and expect them to finish in three or so working days, maybe slightly longer.
The only way it's more onerous than that is if companies have an absolutely shit design under the hood, or they're using malicious compliance to argue that this feature specifically needs eight weeks of planning poker and at least five senior engineers to sign off on each iteration of the design phase.
firesteelrain
These “bench full of idiots” are not blind to the fact that there are deceptive practices regarding subscriptions. FTC didn’t do their job right unfortunately and here we are. Now, new administration and it’s doubtful this will get picked up again barring any law passed by Congress.
Dylan16807
It sounds like they did their job fine. 23 hours on average is plenty. Most companies can do this in 2 hours, and a few of them can spend a lot longer.
jagged-chisel
Your argument presumes that “cost” is “money spent to implement,” when in reality any reduction in predicted revenue is also a “cost.”
The cost of allowing people to cancel subscriptions is more than the cost to implement a button.
fritzo
The U.S. Court of Appeals has therefore quantified the severity of this issue.
renewiltord
Typical decel nonsense to add all these preliminary analyses. This is CEQA/NEPA type garbage.
Fortunately, California law should be unaffected by this and that will probably be sufficient.
bpodgursky
Normally I'm aligned but this is sort of a NEPA rule making sticking a monkeywrench in the gears creating new regulations, so I'm not totally opposed to the principle, as irritating as it is here.
renewiltord
Convincing. I guess I was thinking at step 1 deceleration but this actually depowers step 1 deceleration.
Ideally, we don't have all these structures slowing down societal adaptation. It's like we anneal over time, and that makes us brittle. We need to always be ready to bend to a new wind.
What consumer does this serve at all? What citizen does this serve at all?
This only serves to allow firms to erect effort barriers to keep rent seeking fro their customers. The "gotcha" that the Khan FTC didn't "follow the rules making process" is parallel construction.