In a recent FTCWatch article, ZwillGen Senior Legal Director Zach Lerner shared insights on how the Federal Trade Commission is increasingly scrutinizing so-called “dark patterns,” design choices that regulators and plaintiffs may view as manipulative or misleading in the context of consumer subscriptions.
Zach explained that these tactics often involve interface designs or workflows that allegedly nudge users into enrolling in recurring services or make cancellation unnecessarily difficult, raising concerns under federal consumer protection laws. As enforcement activity continues, companies offering subscription-based products may face heightened legal and regulatory risk tied not just to what their products do, but how they are designed.
Please note that this article is paywalled.