A federal judge has ruled that Amazon violated the Restore Online Shoppers’ Confidence Act (ROSCA) by using deceptive design methods related to its Prime subscription service. The ruling, issued in September 2025, precedes a trial scheduled between the company and the Federal Trade Commission (FTC). The FTC has accused Amazon of using manipulative tactics, often called “dark patterns,” to enroll customers into its Prime membership without their explicit consent.
The legal action originated with a lawsuit filed by the FTC against Amazon in 2023. The commission’s case alleges that the company employed these deceptive design strategies to enroll consumers in the paid subscription service without a clear agreement. According to the FTC, Amazon also engineered the Prime cancellation process to be intentionally difficult. The agency argues that the user interface utilizes confusing prompts designed to make customers second-guess their decision to unsubscribe, which it claims results in users remaining subscribed against their wishes.
In the September 2025 decision, the judge found that Amazon violated ROSCA by collecting billing information from Prime subscribers before the service’s complete terms were fully disclosed. The court’s ruling affirmed that users were misled and that the process for canceling a Prime membership was overly complicated. This development is considered a partial pre-trial victory for the FTC as the case moves forward.
The trial is set to commence on the Monday immediately following the judge’s ruling. A significant component of the case involves the potential for individual liability. Two of Amazon’s top executives may be held personally accountable if the FTC successfully proves its allegations during the trial proceedings. The case against these individuals hinges on the commission’s ability to demonstrate their direct involvement in or awareness of the alleged practices.
In response to the lawsuit and the recent ruling, Amazon has denied all claims made by the FTC. The company maintains that its procedures for both signing up for and canceling Amazon Prime are straightforward and fully compliant with the law. Amazon asserts that its processes are clear and not designed to mislead customers, a position that directly contradicts the commission’s allegations of deceptive and manipulative business practices.
Should the FTC win the case, the outcome could force significant changes to the Amazon Prime service. The company might be required to redesign its subscription interface to ensure all terms, especially those that are currently “half-hidden,” are fully transparent. The cancellation process would also likely need to be simplified. Such a result could have wider effects on the digital subscription industry, potentially establishing new standards that place a greater emphasis on user trust and transparency in service agreements.
