On December 3, 2025, the Federal Trade Commission (FTC) announced it had approved, 2–0, a final order against NextMed and its two founders for allegedly deceptive advertising, billing and cancellation practices, and review manipulation of subscription weight-loss programs. The FTC originally brought an administrative complaint against the defendants and issued a proposed order in July 2025 and has now entered the final order after the required public comment period.
Allegations
The FTC alleged that NextMed and its founders had deceptively marketed their weight-loss programs by claiming they provided access to popular GLP-1 weight-loss drugs. The FTC alleged that despite charging monthly subscription costs ranging from $138 to $188, the company did not properly disclose that the price did not actually include the GLP-1 drugs themselves or the costs of necessary lab work and required consultations with medical providers.
The FTC also alleged that the company’s cancellation practices failed to adequately disclose that memberships required a one-year commitment with early termination fees and that the company failed to maintain sufficient customer service staffing that led to significant delays in processing customer cancellation and refund requests.
According to the FTC, the company suppressed negative reviews by:
- Selectively challenging reviews critical of the company.
- Offering incentives such as gift cards to consumers in exchange for the removal of negative reviews.
- Conditioning refund approvals on the removal of negative reviews.
The FTC also alleged that the company created fake positive reviews and used fake testimonials and before-and-after pictures from people who did not actually use NextMed’s services or GLP-1 drugs.
Final Order Terms
The final order requires NextMed and its two founders to pay $150,000 to the FTC. It also prohibits:
- Misrepresentations about the cost of telehealth services.
- Representations about average or typical results without proper substantiation.
- Misrepresentations of the truthfulness of an endorsement or review.
- Any manipulation of reviews, including by selectively soliciting reviews, offering incentives for the removal of reviews, or disputing reviews without reason.
The final order also requires the defendants to clearly disclose important cancellation and refund terms before asking consumers for payment, provide a simple cancellation and refund method, and promptly approve cancellation and refund requests allowed by the policies and terms that were effective at the time of purchase.
Key Takeaways
Although the monetary penalties involved are relatively modest, this order is a good example of many types of conduct that can lead to FTC enforcement under the Trump-Vance FTC. As we have previously covered, the FTC has long focused on subscription and cancellation practices, and companies should continue to carefully monitor compliance.
Additionally, companies that use or solicit reviews should avoid taking any actions to manipulate those reviews or related ratings, either through selective solicitation or improper attempts to remove negative reviews.
If you have any questions, or would like additional information, please contact one of the attorneys on our Consumer Protection/FTC team.
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