[rtkwe]

The economic impact here is only factoring in how much it would cost companies to comply with the measure which is inherently designed to give an extra hurdle by not counting the money saved by consumers not trapped by dark cancellation patterns.

[db48x]

Right. It doesn’t count the money consumers save by not being trapped primarily because most businesses are legitimate. This threshold is all about identifying rules that are costly for legitimate businesses to implement and allowing them time to suggest alternative rules. If the alternative rules would be just as effective while being cheaper to implement, then the FTC is supposed to drop their own proposed rules in favor of the cheaper alternatives.