Amazon is in court on charges that it guided shoppers toward Prime and made quitting the subscription unnecessarily difficult. The company used so-called “dark patterns” — design choices meant to push users into certain outcomes they might otherwise avoid, the Federal Trade Commission alleges — to boost Prime enrollments and lower churn, according to people familiar with its operations. And now the case, which will be decided by a jury, has the potential to reshape how subscription giants create their sign-up and cancellation flows.
What the FTC Alleges About Amazon’s Prime Sign-Ups
Regulators say Amazon violated the Restore Online Shoppers’ Confidence Act by hiding key terms of auto-renewals and making Prime too easy to join — sometimes with unclear consent — while forcing shoppers who wanted to leave through a multi-step gauntlet. The company once made users click through multiple pages and selections to cancel a membership, an effort known internally as “Iliad,” as in a long odyssey, according to the FTC’s complaint.
The agency has said tens of millions of consumers were affected. The court documents reference design elements that pushed disclosures about billing cadence and renewal off-screen, directed buyers toward free trials in the checkout process, and defaulted to selections that would lead to enrollment. Coverage from The Wall Street Journal and The Verge has noted that the trial is set to focus on internal emails, user interface tests and product roadmaps, as well as testimony from high-ranking executives named in the suit.
Inside ‘Iliad’: Why Canceling Prime Became a Chore
At issue in the case is friction. At other key decision points, like on the cancellation path, “the process was heavily layered with further prompts, warnings regarding consequences of canceling including loss of benefits or costs,” according to the FTC — an approach we’re all too familiar with in the subscription economy. Behavioral economists refer to this as a “sludge” tactic: small barriers that add up to significant effort. Norwegian Consumer Council research in its “Deceived by Design” series and academic work on friction costs illustrate that even incremental added friction in the form of extra clicks or confusing language can effectively suppress opt-outs.
Prime is an incentive system to reckon with! Fast shipping, streaming, exclusive discounts and bundled services cudgel you into sticking around — especially if the alternative is to sacrifice convenience at peak shopping times. Given that the company has north of 200 million members worldwide, even small changes to cancellation rates can have a substantial impact on revenue. In the U.S., Prime is priced at $139 annually, again emphasizing just how much money is at stake in keeping customers around.
Amazon’s Response to the FTC’s Dark Pattern Claims
Amazon has denied the accusations, claiming Prime sign-up and cancellation are meant to be transparent and easy. The company also says that it iterates on user experience all of the time and follows consumer protection laws. It has also cited adjustments it made in Europe after the European Commission and national authorities turned up the heat, such as an agreement to streamline Prime cancellation and simplify language — “a sign that we’re willing to alter what gets to customers” — when regulators have concerns.
Look for the defense to argue that there are clear disclosures regarding price and renewal, free trials are clearly labeled, and Prime members may leave online without reaching out to support.
Expect Amazon to highlight customer satisfaction metrics and internal audits that demonstrate progress over time, while characterizing the FTC’s definition of “dark patterns” as too expansive and inconsistent with prevailing industry design standards.
A Wider Regulatory Crackdown on Dark Pattern Designs
This trial is part of a larger wave of enforcement against manipulative interfaces. The FTC has previously won large settlements over design practices it considered deceptive, such as action against Vonage for making it difficult to cancel and a landmark penalty against Epic Games regarding unwanted in-game charges. The agency also has brought a case against Uber’s membership program, accusing it of unauthorized sign-ups and obstacles to cancellation, an indication that scrutiny over auto-renew tactics transcends sectors.
States are also making it harder. California’s regulation of auto-renewals insists on clear consent and easy cancellation, and other such statutes are becoming widespread. Internationally, watchdogs are moving in tandem; the European Union has cautioned companies against interface tricks that make choices unclear or conflate consents. Should the jury conclude that Amazon crossed a line, the verdict could serve as a template for future cases and lead to broad renovations within the subscription economy.
What the Jury Will Consider in the Amazon Prime Case
Jurors will probably be presented with user-flow diagrams or A/B test results or clickstream data, as well as internal naming conventions such as “Iliad” that might influence how they divine intent. Did Amazon optimize for clarity or inertia? Was there a clear means for consumers to say no, upon sign-up and when leaving? And were disclosures of timing, price and renewal located in a place ordinary shoppers would reasonably see at checkout?
Appropriate remedies might include:
- Simpler, more direct cancellation flows
- Clearer enrollment disclosures at sign-up and checkout
- Independent, third-party audits
- Restitution if the court determines consumers were harmed
In any event, the case is likely to shape how digital subscriptions — from streaming video to software and meal kits — weigh growth against real consumer choice.
In the meantime, shoppers have a practical lesson in the scrutiny:
- Double-check renewal dates
- Review checkout pages for trial terms
- Refresh memberships on occasion; even veteran members should re-up and renew
Yet in a convenience economy, transparency — from platforms and also from users about their own habits — will determine who keeps subscribing, and why.
