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dfxm12

But where is the line exactly?

This is what courts are for. There is no exact line because many situations are different.

Surely you don't have to have a big red cancel button on every page of your platform

Why not?

Some examples would be helpful

The text you quoted is clear enough to me, and it's probably clear to any reasonable person (most rules are written this way). If you're worried about gaming the system to find the exact process that just on the "legal" side of things, you probably aren't reasonable.

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Ya, a reasonable interpretation would likely mean that where you sign in and manage your accounts and payments you have the means to discontinue further service. Anyone trying to push these boundaries will likley find themselves on the wrong side of the law.

well we have done it before, cookie banners. Notwithstanding that a users software running on their system (ostensibly a web client), chooses to store cookies, which are not in fact edible... now we have to suffer through it.

> This is what courts are for. There is no exact line because many situations are different.

So now you’ve opened a bunch of businesses up to liability from an upset customer who files a complaint, even if they are making a good faith effort to follow this law.

That is why clear and specific details should be in the law, not vague hand wavy things that require lawyers and judges to interpret.

Making it more specific only invites malicious compliance. If businesses TRULY make a good faith effort, they’ve got nothing to worry about.

What does malicious compliance mean to you? I've heard it used, but never in a way that makes sense in this context. If they had examples, it would be clearer what the intent was, and businesses would be able to be held the appropriate standard. As it stands, I can't figure out if many of the businesses I deal with are in compliance, and anyone who claims to know is naive, or simply hasn't read the rule closely.

Complying in a way that follows the letter of the law, while clearly contradicting the intent.

For example, finding a loophole to keep it difficult unsubscribe. Or making it easy to unsubscribe, but adding an egregious cancellation fee to all subscriptions.

Another good example is when NYC passed minimum pay laws for delivery drivers, and the big delivery companies immediately all colluded to hide the normal tip screen behind a bunch of submenus (until eventually forced to change it back).

Is it really unclear to you what the intent is here? What specifically about the rule do you think is ambiguous?

The last thing I'd want is to have to end up in court in NY to figure out what is or is not in compliance with this law. They should include examples, like many regulations do. We don't need more lawsuits for laws that could have been clarified in the first place.

Put a nice simple cancel button easily visible in your account settings and you’ll be fine. Don’t overcomplicate it.

No a law should never include examples. If you do, you will get push back saying they can ignore the law since they don’t fit the examples.

They did include examples. The city’s own website has a dedicated page describing the rule with a multitude of examples[0]. What exactly do you think is missing?

> - You were not clearly told the terms of the subscription.

- It was hard to cancel the subscription. For example, you signed up online, but were forced to cancel your subscription on the phone, in person, or another way.

- The business delayed canceling your subscription

...

[0] https://www.nyc.gov/main/click-to-cancel

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