A federal judge has ruled that Amazon violated the Restore Online Shoppers’ Confidence Act (ROSCA) by using deceptive design methods related to its Prime subscription service, setting the stage for a trial with the Federal Trade Commission (FTC).
The legal action originated with a lawsuit filed by the FTC against Amazon in 2023, alleging that the company employed manipulative tactics, often called “dark patterns,” to enroll customers into its Prime membership without their explicit consent. According to the FTC, Amazon also engineered the Prime cancellation process to be intentionally difficult, utilizing confusing prompts designed to make customers second-guess their decision to unsubscribe, resulting in users remaining subscribed against their wishes.
In the September 2025 decision, the judge found that Amazon violated ROSCA by collecting billing information from Prime subscribers before the service’s complete terms were fully disclosed. The court’s ruling affirmed that users were misled and that the process for canceling a Prime membership was overly complicated, marking a partial pre-trial victory for the FTC as the case moves forward.
The trial is set to commence on the Monday immediately following the judge’s ruling, with a significant component involving the potential for individual liability. Two of Amazon’s top executives may be held personally accountable if the FTC successfully proves its allegations during the trial proceedings, contingent upon the commission’s ability to demonstrate their direct involvement in or awareness of the alleged practices.
In response to the lawsuit and the recent ruling, Amazon has denied all claims made by the FTC, maintaining that its procedures for both signing up for and canceling Amazon Prime are straightforward and fully compliant with the law. Amazon asserts that its processes are clear and not designed to mislead customers, directly contradicting the commission’s allegations of deceptive and manipulative business practices.
Should the FTC win the case, the outcome could force significant changes to the Amazon Prime service, potentially requiring the company to redesign its subscription interface to ensure all terms are fully transparent and simplifying the cancellation process. Such a result could have wider effects on the digital subscription industry, potentially establishing new standards that place greater emphasis on user trust and transparency in service agreements.
