Deceptive Subscription & Auto-Renewal Dark Patterns Class Action (Amazon Prime)

In June 2023, the Federal Trade Commission filed a landmark lawsuit against Amazon alleging that the company employed deceptive user interface designs — commonly known as "dark patterns" — to enroll customers in its Amazon Prime subscription service without their explicit, informed consent. According to the FTC's complaint, Amazon's sign-up flows were engineered to confuse consumers into subscribing when they simply intended to complete a purchase, while critical cost disclosures were hidden or de-emphasized. The complaint further alleged that Amazon internally referred to its cancellation process as "Iliad" — a reference to the epic journey required to cancel — having deliberately designed it to be so cumbersome and confusing that many consumers gave up. The FTC alleged these practices violated the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA).

Parallel private class action lawsuits were filed by consumers in the Western District of Washington, consolidating claims from Amazon Prime members who were unwittingly enrolled, charged recurring fees without clear authorization, or were unable to easily cancel their subscriptions. Plaintiffs allege violations of state consumer protection statutes including the Washington Consumer Protection Act. With an estimated 200 million Prime subscribers worldwide — roughly 100 million in the U.S. — the potential class is enormous. The FTC case and the private litigation are proceeding simultaneously, with Amazon contesting the government's characterizations of its enrollment and cancellation flows. Discovery is ongoing as of mid-2025.