Isn't the argument that making it easier to cancel subscriptions means that more customers will cancel and the cumulative effect across the industry will be much more than $100M?
Any dollar “lost” as a result of customers being able to cancel results in customers gaining more money to empower industries that are actually productive.
> But an administrative law judge later found that the rule's impact surpassed the threshold, observing that compliance costs would exceed $100 million "unless each business used fewer than twenty-three hours of professional services at the lowest end of the spectrum of estimated hourly rates," the 8th Circuit ruling said.