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Rules that give leeway to act when consumer costs are estimated to be above a certain threshold, instead of when company costs are below a certain threshold would be a much better, if still imperfect, rule that would satisfy the “correct direction in a useful way”.

Just off the top of my head, you could have a rule that if some business activity is estimated to cost consumers $100 million or more, then FTC can implement it instead of looking at the cost to companies. The “average US household” spends $200 a year on forgotten or unused subscriptions [1], if even 10% of those are due to a lack of click to cancel, that is $2.6 billion per year.

[1] https://thedesk.net/2025/05/cnet-subscription-survey-2025/