Who Turned Out the Lights?: FTC Steps Up “Dark Patterns” Enforcement of Retailers
The Federal Trade Commission issued a new enforcement policy statement in October 2021 warning companies against deploying illegal dark patterns that trick or trap consumers into subscription services. The agency is ramping up its enforcement in response to a rising number of complaints about the financial harms caused by deceptive sign-up tactics, including unauthorized charges or ongoing billing that is impossible to cancel. The FTC’s policy statement puts companies on notice that they will face legal action if their sign-up process fails to provide clear, up-front information, obtain consumers’ informed consent, and make cancellation easy.
During this webinar, Sheppard Mullin attorneys will review legal requirements and best practices for compliance in light of the FTC’s increased scrutiny.