On January 14, 2025, the first part of the Federal Trade Commission’s (“FTC”) update to the Negative Option Rule went into effect. Negative options are contract terms that allow a seller to interpret a customer’s silence or failure to affirmatively cancel an agreement as a tacit acceptance of a renewal option—thereby creating automatically renewing contracts. While auto-renewing contracts are often intended to make subscriptions to goods and services easier and more efficient, the FTC’s stated position has been that consumers and other businesses can become “trapped” in contracts that they did not intend to renew and cannot easily cancel.