FTC v. Amazon.com, Inc.



FTC enforcement action against Amazon relating to Amazon Prime subscription, including explicit mappings in the complaint to five types of "dark patterns"

Our analysis

-The FTC lodged a complaint against Amazon, alleging the company's engagement in "dark patterns." These deceptive patterns included various methods aimed at misleading and coercing consumers into enrolling in Amazon Prime subscriptions that would automatically renew, while also deliberately obstructing the process of canceling these subscriptions.
-FTC explicitly maps the types of deceptive patterns used as follows: Amazon was accused of "Non-consensual Enrollment," where it allegedly duped customers into unknowingly signing up for automatic Prime subscription renewals without obtaining their informed consent. Amazon implemented a "Forced Action" strategy, compelling customers to make an enrollment decision before they could complete their purchases.
- The company used "Interface Interference" by manipulating the user interface to prioritize certain information, such as presenting Prime's terms and conditions in a small font and emphasizing "free shipping" to divert attention from the subscription's price.
-Amazon also employed the "Obstruction or 'Roach Motel' Technique" by complicating the subscription cancellation process, making it challenging to find the option to decline enrollment. Amazon asymmetrically presented choices by misdirecting and making it easier to enroll in Prime, using less prominent links to decline Prime, and directing attention away from the cancellation option.
- Amazon engaged in "Sneaking" by hiding or delaying the disclosure of pertinent information, including Prime's price and auto-renewal feature, during the enrollment checkout process.
-FTC alleged that Amazon used "Confirmshaming," involving emotive language to guilt users into selecting the favored option.
These deceptive practices were found to be in violation of Section 5(a) of the FTC Act (15 U.S.C. § 45(a)) and Section 4 of the Restore Online Shoppers' Confidence Act (ROSCA) (15 U.S.C. § 8403). Amazon's actions were alleged to contravene consumer protection laws, as they misled consumers and made it challenging for them to make informed decisions regarding their subscriptions.


Pending - Last Update (September 20, 2023)


Federal Trade Commission and Amazon.com, Inc

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