Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.
"You accepted the terms, which disclosed the renewal"
high likelihoodThe trader points at a terms page or a single acceptance checkbox.
What answers it
These statutes require the automatic renewal terms to be clear and conspicuous and presented close to the request for consent, and several require consent to the renewal separately from acceptance of the contract as a whole — Vermont expressly so for contracts of a year or more. A link, or one box covering everything, does not satisfy that.
"We were not required to remind you"
high likelihoodThe trader denies any obligation to send a renewal notice.
What answers it
Several states require exactly that — Colorado, Connecticut, Florida and others require notice before the automatic renewal of a longer-term contract, and free-trial conversions attract reminder duties in most of the statutes. Ask the trader to identify the state law it says applies and to confirm whether a reminder was sent and when.
"The FTC rule was struck down, so there is no requirement"
medium likelihoodThe trader treats the vacatur of the federal negative-option rule as removing its obligations.
What answers it
The Eighth Circuit vacated a federal rule on procedural grounds. It did not touch ROSCA, it did not touch section 5 of the FTC Act, and it certainly did not touch state law. State automatic-renewal statutes are unaffected and several were strengthened during 2024 and 2025.