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Zoe Schloss

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Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.

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On June 17, 2026, the Federal Trade Commission (FTC) announced that, at its request, a federal court temporarily halted a sprawling enterprise of alleged deceptive subscription schemes, comprising 15 corporations and eight individuals, from continuing to deceive consumers with hidden costs and recurring charges, while failing to provide simple mechanisms to cancel subscriptions. The FTC filed its complaint in the U.S. District Court for the Northern District of California on a 2-0 commission vote.

On March 11, 2026, the Federal Trade Commission (FTC) issued an advance notice of proposed rulemaking (ANPRM) on negative option marketing. The ANPRM restarts the agency’s effort to regulate subscriptions and automatic renewals after the Eighth Circuit vacated the prior “Click to Cancel” rule, from the Biden administration era, on procedural grounds. Comments are due 30 days after Federal Register publication.

On March 12, 2026, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued Staff Advisory Letter No. 26-08 to all designated contract markets (DCMs), signaling a supportive stance toward prediction markets and other event-based derivatives, including contracts based on the outcome of sporting events. While reiterating existing compliance obligations, the advisory emphasizes the agency’s interest in fostering innovation and growth in these markets within the framework of the Commodity Exchange Act. At the same time, the CFTC released an advance notice of proposed rulemaking seeking broad public comment on whether and how to further regulate event contracts.

The Federal Trade Commission (FTC) has sent warning letters to 10 unnamed companies for practices that may allegedly violate its new Consumer Review Rule. The letters flag potential use of fake or misleading reviews, undisclosed insider endorsements, and suppression of negative feedback. The FTC cautions that violations could trigger enforcement actions and civil penalties exceeding $50,000 per violation.

A federal judge in the U.S. District Court for the Southern District of Florida stayed discovery in a putative Telephone Consumer Protection Act (TCPA) class action while the court considers whether text messages qualify as “calls” under the statute’s do-not-call (DNC) provisions. In McGonigle v. Pure Green Franchise Corp., the court granted the defendant’s motion to stay, finding that the key issues can be resolved as questions of law without discovery. 2026 WL 111338 (S.D. Fla. Jan. 15, 2026).

On October 7, 2025, Kalshi, a platform specializing in prediction market trading, filed a lawsuit against the Ohio Casino Control Commission (OCCC) and Ohio attorney general (AG), alleging that their regulatory actions overstep state authority. The complaint seeks to block enforcement of a cease-and-desist order that was issued by the OCCC in the spring, which accused Kalshi of “operating online sports gaming” and warned Ohio licensees that partnering with Kalshi could jeopardize their licensing status and integrity.

On September 25, 2025, Amazon agreed to pay $2.5 billion to settle claims brought by the Federal Trade Commission (FTC) alleging that the company misled consumers into signing up for Prime memberships and made it difficult for them to cancel. The settlement, announced just days into the start of litigation between Amazon and FTC, includes $1 billion in penalties and $1.5 billion in restitution to customers, which the FTC described as one of the largest settlements in the agency’s history.