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ARTICLE · 02 OCTOBER 2025

FTC's Landmark $2.5 Billion Amazon Settlement Highlights Ongoing Focus On "Dark Patterns"

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Three days into trial, Amazon agreed to pay $2.5 billion to settle a Federal Trade Commission lawsuit alleging that the company misled millions of consumers into subscribing to Amazon Prime and then made it unreasonably difficult for them to cancel in alleged violation of the FTC Act.

United StatesConsumer Protection
Catherine E. O'Brien
Catherine E. O'Brien
Christopher A. Cole
Christopher A. Cole
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Three days into trial, Amazon agreed to pay $2.5 billion to settle a Federal Trade Commission lawsuit alleging that the company misled millions of consumers into subscribing to Amazon Prime and then made it unreasonably difficult for them to cancel in alleged violation of the FTC Act. The settlement is instructive for several reasons: (1) it represents the largest ever obtained by the Ferguson (GOP-led) FTC; (2) it serves as phase one of FTC litigation against Amazon, with a monopolization case to follow in the Western District of Washington; (3) it forms part of a broader litigation campaign against the online retail giant that includes state attorneys general and private class actions; (4) it offers insight into how the FTC will interpret and apply its jurisdiction over "difficult" cancellations, and it marks the first prominent enforcement action in the agency's ongoing campaign against so-called "dark patterns," allegedly manipulative design practices that steer

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