United States of America: Federal Trade Commission announced settlement and refunds in lawsuit against Cerebral over alleged deceptive cancellation practices

On 8 May 2025, the Federal Trade Commission (FTC) announced it had reached a settlement with Cerebral, Inc., an online mental health service provider, over allegations of deceptive subscription and data practices. As part of the settlement, more than 40'000 consumers who requested cancellation on or before May 2022 but were still charged will receive refunds totalling over USD 5 million. The settlement resolves allegations that Cerebral engaged in deceptive practices by imposing a burdensome multi-step cancellation process, continuing to charge consumers after they had submitted cancellation requests, disclosing sensitive personal health information to third parties for advertising purposes, and violating the Restore Online Shoppers’ Confidence Act by failing to clearly disclose all material terms of its cancellation policy prior to charging consumers. Eligible recipients include consumers who requested cancellation on or before May 2022 but were nevertheless billed thereafter.