April 2025

AG Chronicles: a monthly newsletter breaking down State Attorneys General consumer protection issues and highlighting news from the states.

LAW360 EDITORIAL SERIES

The Kelley Drye State AG team was recently invited to be a guest columnist for Law360. Commentary includes a monthly article detailing significant AG news, trends, and compliance implications in the state of Texas. The first two articles in the series may be read here:

Inside State AGs’ Arguments Defending The CFPB

AG Watch: Texas Is Entering New Privacy Enforcement Era

IN THE NEWS AND LATEST UPDATES

Pennsylvania Attorney General Dave Sunday Appointed Co-Chair of NAAG Consumer Protection Committee

On April 8, the National Association of Attorneys General (NAAG) announced the appointment of Pennsylvania Attorney General Dave Sunday as the new co-chair of NAAG’s Consumer Protection Committee. The Committee’s mission is to support and empower state attorneys general nationwide on consumer protection issues through various initiatives, in collaboration with NAAG’s https://​www​.naag​.org/​o​u​r​-​w​o​r​k​/​c​e​n​t​e​r​-​f​o​r​-​c​o​n​s​u​m​e​r​-​p​r​o​t​e​c​tion/. This appointment highlights the AG’s commitment to consumer protection enforcement and priorities.

Auto-Renewal Laws: 2025 Round Up

Businesses offering subscriptions or other ongoing services continue to face a growing, and increasingly complex, patchwork of state auto-renewal laws (ARLs). 2025 brings a fresh wave of developments across the states.

In addition to newly introduced and enacted ARL legislation this session, a number of state laws are now in effect as of January 1, 2025. Together, these proposed and new laws reflect a continued trend toward more prescriptive disclosure, notice, and cancellation requirements, with each state introducing its own unique take.

State AGs Support Effort to Revive TCPA 1:1 Consent Rule

On March 17, a bipartisan group of attorneys general from 27 states and the District of Columbia filed an amicus brief in the Eleventh Circuit Court of Appeals in support of the National Consumer Law Center’s proposed petition for rehearing en banc of the court’s decision to overturn the FCC’s so-called one-to-one” consent rule for telemarketing calls and texts under the Telephone Consumer Protection Act (TCPA). The rule, intended to address what the FCC called the lead generator loophole,” would have amended the definition of prior express written consent” by requiring a consent agreement to be specific to no more than one identified seller” and be logically and topically associated with the interaction that prompted the consent.”

Kansas Seeks to Stop Ford County From Usurping” its Sovereignty

In January, Ford County, Kansas joined a class action complaint filed in Missouri against eleven plastics manufacturers, seeking to represent all persons or entities” in 35 states who purchased relevant plastics since 1990. In a prior complaint relating to these same issues, Ford County declared that the plastics problem” requires a a national, 50-state solution,” and proposed a class consisting of “[a]ll counties located within the State of Kansas which have incurred and will continue to incur sanitation costs.” That complaint was dismissed when Ford County joined the Missouri action.

Junk Fee” Legislative Roundup – 2025 Edition

2024 was an action-packed year for followers of federal and state laws and regulations governing the disclosure of fees, or so-called junk fee” laws. In the waning days of the Biden administration, the FTC released a significantly narrowed version of its initial proposed rule that would apply exclusively to the sale of live-event tickets and short-term lodging, as we summarized here.

New York AG Settles with School Calendar App, Saturn

This week, New York Attorney General Letitia James announced a settlement with app developer Saturn Technologies (Saturn) following an investigation into privacy practices that promised teens an exclusive community but allegedly did not deliver on its claims. The Assurance of Discontinuance (AOD) states that Saturn’s actions constituted violations of New York’s Executive Law 63(12) and General Business Law 349, its main UDAP statutes. Saturn must pay New York $200,000 (with an additional $450,000 payment suspended).

Click here to read Ad Law Access, our blog that provides updates on issues related to advertising law, consumer protection, and more.

UPCOMING EVENTS

The Kelley Drye State AG team will be attending the NAAG 2025 Spring Consumer Protection Conference, May 6 – 8 in Chicago. If you are attending this event or are local to the Chicago area, please reach out to one of the contacts below for more information on the events we are organizing around the conference.

For more information about the State Attorneys General Practice group, click here.