# Dark Patterns Examples: 12 Real Cases and the Bill That Came After

> Dark patterns examples from FTC, EU and CMA cases: Amazon, Adobe, Epic, Uber and more. What each cost, and the honest version to ship instead.

- Published: 2026-10-09
- Category: Product
- Author: Vlad Hrynchuk
- Canonical: https://www.themasterly.com/blog/dark-patterns-examples

Three well-documented dark patterns examples: Amazon Prime's cancellation flow (roach motel, part of a $2.5 billion FTC settlement in 2025), Adobe's early termination fee shown in small print or behind hover icons (hidden costs, a $150 million settlement of alleged violations in 2026) and Fortnite's one-press purchases (misdirection, $245 million in FTC refunds).

**Key takeaways**

- The largest case in this article is Amazon Prime: $2.5 billion in September 2025, a $1 billion civil penalty plus $1.5 billion in refunds. Amazon settled; a settlement is not an admission.
- The SaaS case to study is Adobe: an early termination fee of 50% of the remaining first-year payments, which the FTC said was disclosed in small print or behind hover icons. Adobe agreed to $150 million in March 2026 to resolve the alleged violations.
- Dark patterns work in the short run. In a US experiment with 1,963 adults, mild dark patterns more than doubled acceptance of a dubious paid plan, from 11.3% to 25.8%, with no visible backlash.
- Over a longer horizon the honest default can win. In a field experiment with 1.4 million newspaper readers, auto-renewal cut subscription take-up by 35% and total subscribers by 23% over 20 months.
- Judge a billing or cancellation change on refunds, disputes, completed cancellations and renewal, not only on this week's conversion.

**Video:** [How do you design a subscription nobody can cancel?](https://www.themasterly.com/videos/dark-patterns-examples/roach-motel-720p.mp4) — transcript: "How do you design a subscription nobody can cancel? Leaving us? Of course! Cancelling is easy. Just a quick look at everything you'll miss. All 221 things. Step four of three? Totally normal. We just want to be sure you're sure. Back to the start! Nearly there, though. Just press Cancel. And done! Your membership's been renewed. For three years. Lovely! Masterly doesn't design like this. But if we did, it'd be the stickiest subscription ever."

Amazon agreed to pay $2.5 billion in September 2025 to settle an FTC case about how people joined and left Prime. According to the FTC, Amazon's cancellation flow had an internal name: the Iliad, after Homer's epic about a long and gruelling war.

[Dark patterns](https://www.themasterly.com/glossary/dark-patterns) are interface designs that steer people into choices they would not make if the options were laid out plainly. The glossary entry covers the definition, the types and the law. This article is the case file: twelve dark patterns examples from public enforcement records, what each one cost, and the honest version to ship instead.

What this guide covers:

1. Twelve examples from public cases, with the outcome, the status and the source under each
2. One SaaS company that redesigned its billing towards explicit approval
3. How the same patterns look in SaaS and apps
4. Whether dark patterns work, with the research and our own paywall tests
5. Where the law stands in October 2026, and six questions to ask about your own flow

We are a UI/UX design agency for B2B SaaS, so we read each case as a design decision somebody approved to move a metric. Every case comes from a regulator's press release, complaint or decision, linked under the card. A settlement is not an admission, and where a case is only alleged, we say so. The screens described are historical; several companies have changed them since.

## 12 dark patterns examples, and what each one cost

Each card names the pattern, what the interface did, what it cost, the honest version, and the evidence behind it.

### 1. Roach motel and confirmshaming: Amazon Prime

**What the interface did.** The FTC alleged that Amazon enrolled people in Prime without clear consent and made leaving hard on purpose. Joining took a click or two. Leaving ran through a multi-step flow the FTC says Amazon called the Iliad. Decline buttons used wording such as "No, I don't want Free Shipping", which is [confirmshaming](https://www.themasterly.com/glossary/confirmshaming).

**What it cost.** $2.5 billion: a $1 billion civil penalty and $1.5 billion in refunds for an estimated 35 million affected customers. The order requires a clear button to decline Prime and a way to cancel by the same method people used to sign up.

**Honest version.** Cancel in account settings, in about as many steps as joining took, with one retention offer and a neutral decline: "Cancel membership", not a sentence about losing free shipping.

**Evidence.** The order itself sets the standard. The internal documents in the complaint show the other cost: once a company is sued, its own design memos become exhibits.

Source: [FTC, settlement, 25 September 2025](https://www.ftc.gov/news-events/news/press-releases/2025/09/ftc-secures-historic-25-billion-settlement-against-amazon); [FTC complaint, 21 June 2023](https://www.ftc.gov/news-events/news/press-releases/2023/06/ftc-takes-action-against-amazon-enrolling-consumers-amazon-prime-without-consent-sabotaging-their). Status: settled. We acted out the [roach motel](https://www.themasterly.com/glossary/roach-motel) in a 43-second Short, [How do you design a subscription nobody can cancel?](https://www.youtube.com/shorts/jh676G22qmQ), a made-up product, not Amazon's flow.

### 2. Hidden costs: Adobe's early termination fee

This is the case a B2B reader will recognise, because the plan structure is common in SaaS.

**What the interface did.** Adobe sold an "annual, paid monthly" plan. According to the FTC's complaint, cancelling in the first year triggered an early termination fee of 50% of the remaining payments for that year, and the fee was disclosed in small print or behind optional text boxes and hover icons. The FTC said Adobe frequently [preselected](https://www.themasterly.com/glossary/preselection) that plan as the default, and alleged a multi-page online cancellation flow and phone calls that were dropped or transferred. This is [drip pricing](https://www.themasterly.com/glossary/drip-pricing) applied to the exit rather than the checkout: the real price of the plan appears when you try to leave.

**What it cost.** $150 million: a $75 million civil penalty and $75 million in free services to customers, to resolve what the Justice Department calls alleged violations. A settlement is not a court finding. The order requires Adobe to disclose the fee before enrolment and to remind customers before a free trial longer than seven days converts to a paid plan.

In the UK, the Competition and Markets Authority opened its own investigation into Adobe's cancellation fees on 19 March 2026. The CMA says it has reached no conclusions.

**Honest version.** Put the term, the auto-renewal and the fee formula next to the plan choice, in the same type size as the price: "Annual plan, billed monthly. Cancel in the first year and you pay half of the months left." If the fee would embarrass you in that position, the fee is the problem.

**Evidence.** The order doubles as a checklist for a SaaS billing team: disclose before enrolment, remind before conversion, make cancellation easy.

Source: [US Department of Justice, settlement, 13 March 2026](https://www.justice.gov/opa/pr/adobe-agrees-150-million-settlement-and-injunction-resolve-alleged-violations-restore-online); [FTC complaint, 17 June 2024](https://www.ftc.gov/news-events/news/press-releases/2024/06/ftc-takes-action-against-adobe-executives-hiding-fees-preventing-consumers-easily-cancelling); [CMA investigation, 19 March 2026](https://www.gov.uk/government/news/cma-investigates-adobe-over-concerns-about-cancellation-fees). Status: settled in the US; UK investigation open.

### 3. Forced continuity: Uber One (alleged)

**What the interface did.** The FTC alleges that cancelling Uber One could take up to 23 screens and 32 actions, and that some people were charged before their free trial ended. In December 2025, 21 states and the District of Columbia joined an amended complaint. None of this has been decided.

**What it cost.** No penalty or settlement has been announced; the case is pending.

**Honest version.** A reminder before the first charge, the charge date visible in the product, and cancellation in the place where the subscription lives. Those three steps answer [forced continuity](https://www.themasterly.com/glossary/forced-continuity) directly.

**Evidence.** In our own paywall tests, adding a "Remind me before my trial ends" toggle raised trial starts by 14%. Details and caveats are in the section on whether dark patterns work.

Source: [FTC complaint, 21 April 2025](https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-takes-action-against-uber-deceptive-billing-cancellation-practices); [amended complaint, December 2025](https://www.ftc.gov/news-events/news/press-releases/2025/12/ftc-states-file-amended-complaint-against-uber-deceptive-billing-cancellation-practices). Status: alleged, pending. The trial-trap version is in our Short [The free trial that won't let you leave](https://www.youtube.com/shorts/x5ZltwEE-JA).

### 4. Roach motel by channel: Vonage

**What the interface did.** Customers signed up online. To cancel, they had to reach a live retention agent on a number that was hard to find and open for fewer hours, according to the FTC. Promised callbacks did not come, and some people faced surprise termination fees or kept being charged after asking to cancel.

**What it cost.** $100 million in refunds. In October 2023 the FTC sent nearly $100 million to 389,106 people.

**Honest version.** Cancel through the channel people used to join. If sign-up is a web form, cancellation is a web form.

**Evidence.** The order requires exactly that.

Source: [FTC, settlement, 3 November 2022](https://www.ftc.gov/news-events/news/press-releases/2022/11/ftc-action-against-vonage-results-100-million-customers-trapped-illegal-dark-patterns-junk-fees-when-trying-cancel-service); [refunds, 30 October 2023](https://www.ftc.gov/news-events/news/press-releases/2023/10/ftc-sends-nearly-100-million-refunds-vonage-consumers-who-were-trapped-subscriptions-dark-patterns). Status: settled.

### 5. Misdirection: Epic Games and Fortnite

**What the interface did.** The FTC said Fortnite's button layout was counterintuitive, inconsistent and confusing, so players were charged with a single press, for example when waking the game from sleep mode or on a loading screen. Epic ignored more than a million complaints, according to the FTC, and locked the accounts of people who disputed charges with their card issuer.

**What it cost.** $245 million in refunds, part of $520 million in total with a separate children's privacy penalty. The first refund round paid more than $72 million to 629,344 people.

**Honest version.** A separate confirmation step for any purchase, a button that does not sit where a player presses to wake or skip, and a refund option people can find.

**Evidence.** The complaint shows how this happens in a normal team: the FTC cites internal testing on how to make the refund option harder to find. Treat A/B tests on refunds and cancellations as documents a regulator may read.

Source: [FTC, settlement, 19 December 2022](https://www.ftc.gov/news-events/news/press-releases/2022/12/fortnite-video-game-maker-epic-games-pay-more-half-billion-dollars-over-ftc-allegations); [refunds, 9 December 2024](https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-sends-refund-payments-consumers-impacted-epic-games-unlawful-billing-practices). Status: settled.

### 6. A cancellation with a condition: Cleo AI

**What the interface did.** Cleo, a cash-advance app, told users they could not cancel their subscription until they repaid an outstanding advance, according to the FTC. It also charged an "express" fee for instant cash that sometimes arrived the next day.

**What it cost.** $17 million.

**Honest version.** Let people stop the subscription and repay the advance on its own schedule. The two are separate obligations, and the interface should treat them separately. Our [fintech onboarding UX](https://www.themasterly.com/blog/fintech-onboarding-ux) teardown covers the other end of the same flow.

Source: [FTC, settlement, 27 March 2025](https://www.ftc.gov/news-events/news/press-releases/2025/03/cash-advance-company-cleo-ai-agrees-pay-17-million-result-ftc-lawsuit-charging-it-deceives-consumers). Status: settled.

### 7. Punishing disputes: Match Group

**What the interface did.** The FTC said Match made cancellation hard, advertised a "guarantee" with conditions people did not see, and suspended the accounts of users who unsuccessfully disputed charges, keeping the money they had already paid.

**What it cost.** $14 million. The order bans retaliation against people who dispute charges.

**Honest version.** Treat a chargeback as a signal about your flow. Someone who goes to their bank instead of your settings page could not find the exit, or did not know they were paying.

**Evidence.** The FTC's cases against Epic and Match both included allegations about how the companies treated people who disputed charges, and Match's order bans retaliation outright. Review disputes alongside the billing and cancellation screens that came before them.

Source: [FTC, settlement, 12 August 2025](https://www.ftc.gov/news-events/news/press-releases/2025/08/match-group-agrees-pay-14-million-permanently-stop-deceptive-advertising-cancellation-billing). Status: settled.

### 8. Drip pricing at checkout: the AA, BSM and StubHub

**What the interface did.** The AA and BSM driving schools showed more than 80,000 learners a mandatory booking fee only at checkout. In the US, the FTC said StubHub advertised ticket prices without showing the total, including mandatory fees, up front.

**What it cost.** The CMA fined the AA and BSM £4.2 million, reduced from £7 million for settling early, and ordered more than £760,000 in refunds. It was the first fine under the CMA's new direct enforcement powers. StubHub agreed to pay $10 million for consumer refunds.

**Honest version.** The total price on the pricing page. If a fee is mandatory, it is part of the price. In SaaS the same rule covers minimum seat counts and platform fees that appear only on the last step.

**Evidence.** This is a pattern a conversion-only test will reward. In an August 2015 field experiment on StubHub, users who saw fees only at checkout spent about 21% more over ten days than users who saw them up front ([Blake et al., Marketing Science, 2021](https://faculty.haas.berkeley.edu/stadelis/AIP.pdf)). That experiment is separate from the 2026 FTC case. It explains why the pattern survives A/B tests.

Source: [CMA decision, 15 April 2026](https://www.gov.uk/government/news/cma-orders-the-aa-and-bsm-driving-schools-to-refund-learner-drivers-over-drip-pricing); [FTC, StubHub settlement, 9 April 2026](https://www.ftc.gov/news-events/news/press-releases/2026/04/stubhub-refunding-10-million-fees-consumers-after-deceptive-ticket-pricing). Status: CMA decision; FTC settlement.

### 9. Preselection and false urgency: Wowcher

**What the interface did.** Wowcher signed customers up to a paid VIP membership through boxes that were already ticked, according to the CMA. The same case covered a permanent "Deals refresh in" countdown on the homepage and "Running out!" and "In high demand!" labels.

**What it cost.** About £4.27 million in refunds, paid as account credit that could be converted to cash, to more than 870,000 customers, under undertakings to the CMA. Wowcher made no admission.

**Honest version.** Paid extras start unticked. A default should be the option most customers would pick if asked, which is rarely the one that costs them more. More on this in [preselection](https://www.themasterly.com/glossary/preselection).

Source: [CMA, 19 July 2024](https://www.gov.uk/government/news/cma-secures-over-4-million-in-refunds-for-wowcher-customers). Status: undertakings, no admission.

### 10. False urgency: Emma Sleep

**What the interface did.** Emma, a mattress retailer, ran countdown timers on its headline discounts from January to October 2022 and again from December 2022 to March 2024, presenting the discounts as time-limited. In a High Court order it admitted to 55 instances of "high demand" claims in 2022.

**What it cost.** No fine. Emma gave undertakings to change its sales practices, approved by the High Court on 22 May 2026 and enforceable by contempt of court. A separate part of the case, on reference pricing, went to trial in June 2026.

**Honest version.** A timer only when a real deadline exists, and a stock label only when stock is low. Otherwise say nothing. See [false urgency](https://www.themasterly.com/glossary/false-urgency).

**Evidence.** In Luguri and Strahilevitz's experiment, a scarcity message had no significant effect on acceptance of the offer. That experiment did not test Emma's timers, but it is a reason to doubt that a fake countdown earns what it risks.

Source: [CMA, 28 May 2026](https://www.gov.uk/government/news/court-endorses-cma-action-as-emma-sleep-agrees-to-change-sales-practices); [High Court order](https://assets.publishing.service.gov.uk/media/6a18165859fb7a60f827f42a/High_Court_order.pdf); [Luguri and Strahilevitz, Journal of Legal Analysis, 2021](https://academic.oup.com/jla/article/13/1/43/6180579). Status: court-approved undertakings.

### 11. Asymmetric consent: Google and Facebook in France

**What the interface did.** On Google's and Facebook's sites, accepting cookies took one click and refusing took several, according to France's data protection authority, the CNIL. On Facebook, the CNIL found, refusing meant opening the data settings, scrolling through a second window and then pressing a button labelled "Accept cookies".

**What it cost.** €150 million for Google and €60 million for Facebook, with three months to comply or a penalty of €100,000 a day.

**Honest version.** "Reject all" next to "Accept all", the same size, the same weight, on the first screen.

**Evidence.** Nouwens and colleagues found that removing the "reject" option from the first page of a consent pop-up raised consent by 22 to 23 percentage points. That gap is the size of the nudge regulators object to.

Source: [CNIL, decisions of 31 December 2021, announced 6 January 2022](https://www.cnil.fr/en/cookies-cnil-fines-google-total-150-million-euros-and-facebook-60-million-euros-non-compliance); [Nouwens et al., CHI 2020](https://arxiv.org/abs/2001.02479). Status: regulator decisions.

### 12. Deceptive design under the DSA: X

**What the interface did.** X sold the blue checkmark as "verified" status without meaningful verification of who was behind the account, according to the European Commission.

**What it cost.** €120 million in December 2025, the first non-compliance decision under the Digital Services Act. The fine covered several findings, and the checkmark was one of them.

**Honest version.** A badge should mean what it says. If it means "pays for a subscription", label it that way.

**Evidence.** Article 25 of the DSA bans deceptive interface design by online platforms. It does not cover every website or SaaS product; the [glossary entry](https://www.themasterly.com/glossary/dark-patterns) explains the scope.

Source: [European Commission, 5 December 2025](https://digital-strategy.ec.europa.eu/en/news/commission-fines-x-eu120-million-under-digital-services-act). Status: decision.

### The counterexample: Figma's seat approvals

This is not a case against Figma, and no regulator was involved. It is a SaaS company describing a billing change towards explicit approval.

In December 2024 Figma wrote that seat upgrades were "driven by user actions" and that admins could review them only afterwards, which customers had told it was frustrating. From 11 March 2025, admins approve seat upgrades up front by default. People can request a seat, see it approved or declined, and keep temporary access for up to three days while the request is pending. The same post announced price increases.

What a B2B team can take from it: a seat request that shows the price, an approver who sees it before the bill, and access that continues while the request is pending. Sources: [Figma blog, 10 December 2024](https://www.figma.com/blog/billing-experience-update-2025/); [Figma help centre](https://help.figma.com/hc/en-us/articles/1500003870721-Approve-or-decline-seat-upgrade-requests).

## Dark patterns in SaaS and apps

Di Geronimo and colleagues examined 240 popular mobile apps for CHI 2020 and found that 95% contained at least one dark pattern. In a follow-up experiment, most of the 589 participants did not recognise the patterns they were shown.

In B2B SaaS, the same patterns appear in seat billing, trials and cancellation:

- **Drip pricing:** a minimum seat count or a platform fee that appears on the last step of checkout.
- **Roach motel:** self-serve sign-up, "talk to your account manager to cancel".
- **Hidden costs:** annual billed monthly, with the early termination fee in the terms of service.
- **Preselection and sneaking:** seats added automatically when someone invites a colleague, visible on the next invoice.
- **Forced continuity:** a trial that converts with no reminder to the person who holds the card.

We found no B2B-specific quantitative study of how dark patterns affect renewal, churn or payment disputes. The rest of this paragraph is our reasoning. The person who felt tricked at checkout is often the person who signs next year's renewal, and in B2B that conversation includes procurement. If your product looks like the list above, our [SaaS UI/UX design guide](https://www.themasterly.com/blog/saas-ui-ux-design-guide) and [SaaS onboarding guide](https://www.themasterly.com/blog/saas-onboarding-ux-guide) show what the honest flows look like on screen.

## Do dark patterns actually work?

Yes, in the short run, and that is why they keep shipping. The better question is what happens over a longer horizon. The largest field test we know of found that the less sticky default produced more subscribers after 20 months.

**The short run.** Jamie Luguri and Lior Strahilevitz ran a randomised experiment with 1,963 US adults on an online panel, offering a dubious paid "data protection" plan. In the control group, 11.3% accepted. Mild dark patterns raised that to 25.8%; aggressive ones to 41.9%. The aggressive version made people angry, and 65 of them quit the study, against 9 under the mild version. The mild patterns caused no visible backlash. "Dark patterns always backfire" is not true.

**The long run.** Miller, Sahni and Strulov-Shlain ran a field experiment on the paywall of a large European newspaper, with 1.4 million readers randomly offered auto-renewing or auto-cancelling subscriptions. Auto-renewal helped the newspaper in the short term. Over 20 months, including the promotional period, it reduced subscription take-up by 35% and the total number of subscribers by 23%: many readers who expected to forget to cancel did not sign up. It is a January 2026 working paper and a newspaper, not SaaS, but it is the largest field test of the question we know of.

**Why the temptation is real.** Einav, Klopack and Mahoney estimate that consumer inattention raises seller revenue in subscription markets by between 14% and more than 200%. A team that relies on people forgetting is leaning on a large number.

> A dark pattern can win an A/B test read after a week. A short test may miss the refunds, disputes and complaints that come later.

**Our own tests.** These paywall A/B tests come from Masterly's practice, on a consumer subscription app. In each of the three below, the variant made the trial more transparent:

- A "Remind me before my trial ends" toggle, on by default and wired to a real reminder: **+14% trial starts**.
- A "How your trial works" timeline with the user's real dates for the start, the reminder and the first charge: **+28% trial starts**.
- A checkout summary card reading "Due today: $0.00": **+24% trial starts**.

The caveats matter. This is one product, a consumer app rather than B2B, and the figures are relative lifts without published baselines or sample sizes. Each test added transparency to a control. None was a head-to-head against a dark pattern. What they show is that being honest about billing did not cost trial starts in these tests; it raised them.

The working rule: put guardrail metrics next to conversion. Refunds, disputes, completed cancellations and renewal rate tell you what a billing change did. Read more on [A/B testing](https://www.themasterly.com/glossary/ab-testing), [churn](https://www.themasterly.com/glossary/churn), [retention](https://www.themasterly.com/glossary/retention) and [growth design](https://www.themasterly.com/blog/what-is-growth-design).

## Where the law stands (October 2026)

This is a dated summary, not legal advice. The [dark patterns glossary entry](https://www.themasterly.com/glossary/dark-patterns) has the detail and the statutes.

- **US, click-to-cancel:** the FTC's 2024 rule was vacated by the Eighth Circuit on 8 July 2025, before it took effect. The FTC published an advance notice of proposed rulemaking on [11 March 2026](https://www.ftc.gov/news-events/news/press-releases/2026/03/ftc-seeks-public-comment-response-advance-notice-proposed-rulemaking-regarding-negative-option); as of October 2026 there is no proposed rule.
- **US, what still applies:** the Restore Online Shoppers' Confidence Act, about 30 state automatic-renewal laws, and individual orders such as Amazon's and Vonage's, which require cancellation by the same method as sign-up.
- **EU:** the Digital Services Act's Article 25 applies to online platforms, not every website. A withdrawal button for the 14-day right of withdrawal under the Consumer Rights Directive has applied since 19 June 2026 (it is not a general cancel button), and a Digital Fairness Act has been announced but not proposed.
- **UK:** since 6 April 2025 the CMA can fine companies directly, up to 10% of global turnover, for consumer law breaches. The AA and BSM fine was the first.

## How to spot a dark pattern in your own flow

To spot a dark pattern in your own product, walk through sign-up, checkout and cancellation as a customer and ask six questions:

1. **Can people cancel as easily as they signed up,** in the same channel and in a similar number of steps?
2. **Is the price on the pricing page the price at checkout,** including seat minimums and fees?
3. **Does anyone get a reminder before the first charge,** and can they see the charge date in the product?
4. **Is any paid option ticked by default?**
5. **Is the decline button neutral and visible,** or does it shame the person who picks it?
6. **Are your timers and "high demand" labels true** at the moment someone sees them?

One more question for the team: would you be comfortable seeing a screenshot of this screen in a complaint? In the Amazon and Epic cases, internal documents and test results ended up in the FTC's filings.

If you want a second pair of eyes on billing and cancellation, our [UX audit](https://www.themasterly.com/services/ux-audit) reviews those flows with the rest of the product, and the [UX audit checklist](https://www.themasterly.com/blog/ux-audit-checklist) lets you run a first pass yourself.

## FAQ

**What are three examples of dark patterns?**

Amazon Prime's cancellation flow, which the FTC said the company called the Iliad internally, is a roach motel; Amazon settled for $2.5 billion in 2025. Adobe's early termination fee, which the FTC said was shown in small print or behind hover icons, is a hidden cost; Adobe settled the alleged violations for $150 million in 2026. Fortnite's purchase buttons, which the FTC said charged players with a single press, are misdirection; Epic Games agreed to $245 million in refunds.

**What are examples of dark patterns in apps?**

The FTC said Fortnite's button layout charged players with a single press, including when waking the game from sleep mode; Epic Games agreed to $245 million in refunds. The FTC said the cash-advance app Cleo AI told users they could not cancel until they repaid an advance; Cleo agreed to pay $17 million. The FTC also alleges that cancelling Uber One could take up to 23 screens; that case is pending. A CHI 2020 study of 240 popular mobile apps found that 95% contained at least one dark pattern.

**Which company paid the most over dark patterns?**

Amazon. In September 2025 it agreed to pay $2.5 billion to settle the FTC's case over Prime enrolment and cancellation: a $1 billion civil penalty and $1.5 billion in refunds for an estimated 35 million affected customers. It was a settlement, not a court finding or an admission. The next largest in this list is Epic Games, with $245 million in refunds for unwanted Fortnite purchases.

**Do dark patterns increase conversion?**

Yes, in the short run. In Luguri and Strahilevitz's experiment with 1,963 US adults, acceptance of a paid plan rose from 11.3% to 25.8% with mild dark patterns and to 41.9% with aggressive ones. Over a longer horizon the picture changes: a 2026 working paper on 1.4 million newspaper readers found auto-renewal helped in the short term but cut take-up by 35% and total subscribers by 23% over 20 months.

**What happened to the FTC click-to-cancel rule?**

A US federal appeals court, the Eighth Circuit, vacated it on 8 July 2025, before it took effect. The FTC published an advance notice of proposed rulemaking on 11 March 2026, and as of October 2026 there is no proposed rule. Subscription businesses remain subject to ROSCA, applicable state automatic-renewal laws and any orders that bind them. Our dark patterns glossary entry covers which practices are illegal where.

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