Consumer Rights
12/7/2025
12 min read
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Subscription Traps and Dark Patterns: How Companies Make It Impossible to Cancel—and How to Fight Back

Amazon paid $2.5B for "Iliad Flow" cancellation maze. 76% of subscription sites use dark patterns. FTC cracking down. Complete guide to cancel, file complaints, recover charges.

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By Compens.ai Editorial Team

Insurance Claims Expert

Subscription Traps and Dark Patterns: How Companies Make It Impossible to Cancel—and How to Fight Back

Updated: December 2025

The $2.5 Billion Wake-Up Call

In September 2025, Amazon agreed to pay a historic $2.5 billion to settle Federal Trade Commission charges over its Prime subscription practices. The settlement included $1 billion in civil penalties—the largest ever in an FTC rule violation case—plus $1.5 billion in consumer refunds.

What did Amazon do? They created what internal documents called the "Iliad Flow"—a cancellation process so complex it was named after Homer's epic poem. To cancel Prime, consumers had to navigate a four-page, six-click, fifteen-option sequence filled with diversions, discount offers, and reminders of benefits. The FTC called it a deliberately manipulative design intended to frustrate consumers into giving up.

Amazon isn't alone. An FTC study of 642 subscription websites and apps found that 76 percent used at least one dark pattern, and 67 percent used more than one. These aren't bugs—they're features designed to extract money from consumers who want to leave but can't figure out how.

The Dark Patterns Epidemic

| Statistic | Figure | |-----------|--------| | Subscription sites using dark patterns | 76% | | Sites using multiple dark patterns | 67% | | Sites hiding auto-renewal opt-out | 81% | | Amazon Prime settlement | $2.5 billion | | Care.com settlement (2025) | $8 million | | Adobe facing DOJ complaint | June 2024 |

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Understanding Dark Patterns: The Tricks They Use

What Are Dark Patterns?

Dark patterns are user interface designs deliberately crafted to manipulate users into actions they didn't intend—or prevent them from taking actions they want. In subscription contexts, they're specifically designed to:

  • Make signing up effortless
  • Make canceling nearly impossible
  • Hide important terms until it's too late
  • Create confusion, frustration, and abandonment

The Most Common Dark Patterns

Roach Motel

Easy to get in, nearly impossible to get out. One-click signup, fifteen-click cancellation. The Amazon "Iliad Flow" is the textbook example.

How it works: Sign up online in seconds; cancel only by calling a phone number during limited hours, navigating endless menus, or completing a maze of web pages.

Forced Continuity

Your free trial converts to a paid subscription without clear warning. The company has your payment information from the trial, and charges begin automatically.

How it works: "Start your free trial" requires credit card entry. The trial end date is buried in fine print. Charges appear with no reminder.

Hidden Costs

The advertised price isn't the real price. Fees, taxes, and mandatory add-ons appear only at checkout—or worse, on your first bill.

How it works: "$9.99/month" becomes $14.99 after "service fees," "platform fees," or mandatory add-ons are included.

Confirm-Shaming

Using guilt or shame to manipulate decisions. The "No thanks, I don't want to save money" button is designed to make you feel stupid for opting out.

How it works: Cancel button says "No, I'd rather pay full price" while the continue button says "Yes! I want amazing savings!"

Misdirection

Visual design that draws attention away from options the company doesn't want you to choose.

How it works: The "Continue subscription" button is large, colorful, and prominent. The "Cancel" link is small, gray, and buried at the bottom.

Sneaking

Adding items to your cart or subscription without clear consent. The FTC found 81 percent of subscription sites made it impossible to turn off auto-renewal during signup.

How it works: "Premium protection plan" is pre-checked during checkout. Annual billing is selected by default instead of monthly.

Obstruction

Making a process unnecessarily difficult by requiring extra steps, waiting periods, or contacting customer service.

How it works: To cancel, you must: (1) log in, (2) navigate to account, (3) find subscriptions, (4) click manage, (5) click cancel, (6) complete a survey, (7) decline three retention offers, (8) confirm via email, (9) confirm again.

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Major Enforcement Actions: The Tide Is Turning

Amazon Prime ($2.5 Billion - September 2025)

The landmark case that changed the landscape:

What Amazon did:
  • Created a deliberately confusing cancellation flow
  • Used "dark patterns" to frustrate consumers
  • Required 4+ pages and 15+ options to cancel
  • Bombarded users with retention offers during cancellation
  • Made "continue membership" options prominent while hiding cancel buttons
The consequences:
  • $1 billion civil penalty (largest ever for FTC rule violation)
  • $1.5 billion in consumer refunds
  • Required to simplify cancellation process
  • Named executives personally in lawsuit (rare)

Adobe (DOJ Complaint - June 2024)

The Department of Justice filed an FTC complaint alleging:

  • Failed to clearly disclose "Annual, Paid Monthly" plan terms
  • Hid early termination fees (up to hundreds of dollars)
  • Made cancellation "unreasonably difficult"
  • Named two executives personally as defendants

Status: Ongoing litigation

Care.com ($8 Million - Summer 2025)

The caregiving platform settled charges that it:

  • "Systematically deceived" caregivers seeking jobs
  • Failed to provide a simple cancellation method
  • Trapped users in paid memberships

The Pattern

Notice that the FTC is increasingly naming individual executives—not just companies. This signals a shift toward personal accountability for dark pattern decisions.

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Your Legal Rights

Federal Protections

The FTC Act (Section 5)

Prohibits "unfair or deceptive acts or practices." Dark patterns that trick consumers into unwanted purchases or prevent legitimate cancellations violate this standard.

ROSCA (Restore Online Shoppers' Confidence Act)

Requires that online sellers:
  • Clearly disclose material terms before charging
  • Obtain informed consent before billing
  • Provide simple cancellation mechanisms

Violations can result in FTC enforcement and civil penalties.

The Click-to-Cancel Rule (Complicated Status)

The FTC finalized this rule in October 2024, requiring cancellation to be as easy as signup. However, a federal court struck it down in 2025, finding the FTC failed to properly weigh costs and benefits.

Despite this setback: The FTC continues enforcing existing laws against manipulative cancellation practices. The Amazon and Adobe cases prove that companies can still face massive liability under current law.

State Protections

Many states have additional protections:

| State | Protection | |-------|------------| | California | Automatic Renewal Law requires clear disclosure and easy cancellation | | New York | General Business Law prohibits deceptive practices | | Illinois | Automatic Contract Renewal Act requires notice before renewal | | Virginia | Consumer Protection Act covers subscription deception |

California's law is particularly strong, requiring:
  • Clear disclosure of automatic renewal terms
  • Acknowledgment of terms before charging
  • Easy online cancellation if signup was online

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How to Fight Back: Step-by-Step Guide

Before You're Trapped

Document the signup process:
  • Screenshot every page during signup
  • Note what disclosures were (or weren't) made
  • Save confirmation emails
  • Mark calendar for trial end dates
Read the fine print for:
  • Automatic renewal terms
  • Cancellation procedures
  • Early termination fees
  • Price increases after promotional periods

When You Want to Cancel

Step 1: Document the cancellation attempt

  • Screenshot every page of the cancellation flow
  • Note the time spent and number of steps
  • Record any "retention offers" or obstacles
  • Save confirmation (or lack thereof)

Step 2: Try the direct approach

  • Look for account settings > subscriptions > cancel
  • Check the company's help pages for cancellation instructions
  • Try the mobile app (sometimes easier than website)

Step 3: If that fails, escalate

Email method: Send a clear cancellation request to the company's support email. Include:
  • Your account information
  • Clear statement: "I am canceling my subscription effective immediately"
  • Request for written confirmation
  • Statement that you do not consent to further charges

Chat method: Use live chat if available. Screenshot the entire conversation. Get the agent's name and confirmation number.

Phone method: If required to call:
  • Record the call (legal in most states with one-party consent; announce you're recording in two-party states)
  • Get the representative's name and ID
  • Request a confirmation number and email
  • Note exact time and duration

Step 4: Stop the payments

If the company won't cancel:
  • Contact your credit card company about blocking future charges
  • File a chargeback for any unauthorized charges
  • Document your cancellation attempts for the chargeback dispute

Filing Complaints

Federal Trade Commission
  • Report at reportfraud.ftc.gov
  • Complaints build enforcement cases
  • Include documentation of dark patterns encountered
Consumer Financial Protection Bureau
  • For billing and payment issues
  • consumerfinance.gov/complaint
State Attorney General
  • Most states have consumer protection divisions
  • Find yours at naag.org
  • State AGs have brought major dark pattern cases
Better Business Bureau
  • File at bbb.org
  • Companies often respond to avoid negative ratings

Legal Action

For significant damages, consider:

Small claims court:
  • No lawyer needed
  • Limits vary by state ($5,000-$25,000)
  • Can recover unauthorized charges plus damages
Class actions:
  • Check topclassactions.com for existing cases
  • Many dark pattern class actions are ongoing
  • You may already be a class member

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Company-Specific Cancellation Guides

Streaming Services

Netflix: Relatively straightforward. Account > Cancel Membership. But watch for "pause" options presented as cancel.

Amazon Prime: Post-settlement, should be simpler. Account > Prime Membership > End Membership. Document if still difficult.

Hulu: Account > Cancel. Expect retention offers. Keep clicking cancel.

Fitness and Wellness

Gym memberships: Often require certified mail or in-person cancellation. Check your contract. Some states (like California) mandate online cancellation if signup was online.

Fitness apps: Usually in app settings. Check for "annual" commitments that prevent immediate cancellation.

Software and Services

Adobe: Settings > Plans > Cancel Plan. Expect early termination fee warnings for annual plans. This is the subject of the DOJ complaint—document everything.

Microsoft 365: Account > Services & subscriptions > Cancel. Relatively straightforward but watch for auto-renewal reactivation.

News and Media

New York Times: Account > Subscription > Cancel. Known for aggressive retention tactics. Be persistent.

Wall Street Journal: Similar to NYT. Expect multiple retention offers.

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The Bigger Picture: Why This Matters

The Economics of Friction

Companies know that every obstacle to cancellation saves them money:

  • Even a 1% reduction in cancellations across millions of subscribers = massive revenue
  • Frustrated users who give up = continued billing
  • Complex processes = plausible deniability ("the option was there")

One study estimated that dark patterns in subscriptions extract billions of dollars annually from consumers who would cancel if they could.

The Psychological Manipulation

Dark patterns exploit known cognitive biases:

  • Sunk cost fallacy: "I've already paid, might as well keep it"
  • Default bias: People tend to stick with whatever is pre-selected
  • Decision fatigue: Complex processes exhaust people into compliance
  • Loss aversion: Framing cancellation as "losing" benefits

The Power Imbalance

Individual consumers face:
  • Teams of designers optimizing for manipulation
  • A/B tested friction that's been proven to work
  • Legal teams that craft TOS to protect the company
  • Customer service trained in retention tactics

This is why regulatory enforcement and collective action matter. Individual complaints, combined with FTC action and class action litigation, can shift the balance.

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What's Next: The Future of Subscription Rights

Despite Setbacks, Progress Continues

The Click-to-Cancel rule may have been struck down, but:

  • The FTC continues enforcing existing laws aggressively
  • The $2.5 billion Amazon settlement proves liability is real
  • Individual executives are being named in complaints
  • State laws continue to strengthen

What Would Comprehensive Reform Look Like?

Advocates are pushing for:

  • One-click cancellation mandate: If you can subscribe in one click, you must be able to cancel in one click
  • Pre-renewal notifications: Required reminder before any automatic renewal
  • Prorated refunds: Right to refund for unused portion upon cancellation
  • Dark pattern prohibition: Explicit ban on manipulative design in commercial contexts
  • Private right of action: Let consumers sue directly, not just wait for FTC

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Resources

Complaint Filing

  • FTC: reportfraud.ftc.gov
  • CFPB: consumerfinance.gov/complaint
  • State AGs: naag.org
  • BBB: bbb.org

Research and Advocacy

  • Consumer Reports: consumerreports.org
  • Electronic Frontier Foundation: eff.org
  • Public Knowledge: publicknowledge.org

Class Action Information

  • Top Class Actions: topclassactions.com
  • Class Action.org: classaction.org

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Conclusion: You Have More Power Than You Think

The subscription economy depends on consumer inertia. Companies count on you being too busy, too frustrated, or too confused to cancel. Dark patterns are the weapons they use to maintain that advantage.

But the tide is turning. The Amazon settlement proves that manipulative design has consequences. The FTC is watching. State attorneys general are acting. Class action lawyers are circling.

What you can do:

  • Document everything when you sign up and when you try to cancel
  • File complaints with the FTC and your state AG—they matter
  • Use your credit card as a weapon against unauthorized charges
  • Join class actions against companies with manipulative practices
  • Share your experiences to help others avoid the same traps

The subscription trap depends on your silence. Don't give them that advantage.

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This guide provides general information and does not constitute legal advice. Subscription practices and laws vary. Consult with a consumer protection attorney for specific situations.

Sources: FTC, CFPB, Consumer Reports

Last Updated: December 2025

Tags

Dark Patterns
Subscription Traps
Cancel Subscription
FTC
Amazon Prime
Consumer Rights
ROSCA
Deceptive Practices

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