Judge: Amazon violated ROSCA with Prime sign-up tactics

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Judge: Amazon violated ROSCA with Prime sign-up tactics

A federal judge ruled that Amazon violated a consumer protection law by using deceptive design tactics to enroll users in its Prime subscription service. The September 2025 ruling comes ahead of a trial initiated by the Federal Trade Commission.

The case stems from a lawsuit the FTC filed against Amazon in 2023. The commission accused the company of utilizing manipulative design strategies, often referred to as “dark patterns,” to enroll consumers in Amazon Prime without their full consent. The lawsuit alleges that Amazon intentionally designed a convoluted cancellation process to retain subscribers who wished to exit the service. Amazon Prime, a service known for providing benefits such as two-day shipping, media streaming, and exclusive commercial deals, has faced regulatory examination regarding its user-facing procedures. The FTC’s action is part of a broader regulatory focus on ensuring user consent and protecting consumer data privacy across digital platforms.

In the recent development, the presiding federal judge determined that Amazon was in violation of the Restore Online Shoppers’ Confidence Act (ROSCA). According to information reported by The Verge, the specific breach involved Amazon collecting billing information from consumers for Prime subscriptions before the complete terms of the service were disclosed. ROSCA mandates that online retailers must clearly and conspicuously disclose all material terms of a transaction before obtaining a consumer’s billing information. The judge’s agreement with the FTC on this point marks a significant step in the legal proceedings as the case moves toward a full trial.

The trial is scheduled to begin on the Monday following the ruling. This judicial decision is viewed as a partial victory for the FTC, as the judge concurred that the Prime cancellation process was intentionally difficult and that users were misled. The court has also indicated that if the FTC successfully proves its case during the trial, two senior Amazon executives could be held individually accountable for the violations. In response to the allegations and the court’s finding, Amazon has denied any wrongdoing. The company maintains that its sign-up and cancellation functionalities are both lawful and straightforward for customers to navigate.

A victory for the FTC in the upcoming trial could compel Amazon to fundamentally redesign its Prime subscription interface. Such a court-mandated change would require the company to ensure all terms are presented with greater clarity and that the cancellation process is simplified.

This outcome would not be confined to Amazon alone; it could establish a new precedent for the wider subscription economy. The case may influence how digital services structure their subscription models, potentially leading to an increased industry focus on transparency in user agreements and billing practices. Amazon’s legal representatives are currently preparing for the trial proceedings.


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