It is that “direct proximity” element that has resulted in a significant amount of litigation over whether having the terms on the same page, as opposed to immediately adjacent to, the 'Submit Order' button suffices. California’s ARL requirements are technically detailed: the terms of the subscription program must be in “larger type than the surrounding text, or in contrasting type, font, or color to the surrounding text of the same size, or set off from the surrounding text of the same size by symbols or other marks, in a manner that clearly calls attention to the language,” and in “direct proximity” to the check-out button. While state and federal ARLs vary, they all impose clear notice requirements so consumers are aware that they will automatically be charged on a recurring basis until they cancel. Automatic Renewal Laws-General Requirements Nevertheless, a recent settlement between the FTC and MoviePass signals the allure of penalties for the government to bring claims under the federal Restore Online Shoppers’ Confidence Act (ROSCA), 15 U.S.C. Arguably, consumer-protection laws, such as California’s Unfair Competition Law (UCL), vitiate the need for separate automatic renewal laws (ARLs). In two recent cases, the California Supreme Court and the Federal Trade Commission (FTC), respectively, have addressed the overlap between consumer-protection laws prohibiting unfair and deceptive conduct, and laws imposing technical requirements for automatic renewal programs.

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