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We Requested an FTC Investigation of Amazon’s Manipulative Subscription Practices

You Can Log Out, But You Can Never Leave

By Kwame Newton

In a time of global public health restrictions on movement and travel, online services are a bigger part of daily life than ever before. The COVID-19 pandemic is forcing tens of millions of Americans to entrust their needs to digital platforms for the first time in their lives, leaving many vulnerable to sophisticated, manipulative design choices known as dark patterns.

Amazon looms large among platforms that deploy dark patterns to override and undermine users who attempt to unsubscribe from their services. The Norwegian Consumer Council [NCC] breaks down this practice in its recently released report: You Can Log Out, But You Can Never Leave: How Amazon Manipulates Consumers to Keep Them Subscribed to Amazon Prime.

Clicking the “cancel membership” button unambiguously shows a user’s intent to unsubscribe from a service, but Amazon doesn’t make matters that simple. Amazon Prime’s free trials are like the bait in a roach motel — consumers are put on the path to a recurring subscription with as little as one click, but they can only leave after successfully navigating a series of pages designed to challenge and cancel out their original choice.

This is the “roach motel” model in action: unsubscribing from Amazon Prime takes navigating a maze of buttons on nearly half a dozen pages, but undoing all that work only takes a single click.

This process is filled with manipulative techniques like statements that discourage users from going along with their intent to cancel by making them scroll through their “Exclusive Prime benefits” before re-affirming their choice to unsubscribe. But to even make this choice, users must be vigilant for misdirection by subtle user interface design choices like “continue to cancel” buttons hidden within a stack of identically-designed buttons, all of which navigate away from the cancellation path. These dark patterns even appear in the “confirmation” email Amazon sends after a successful cancellation, where users are warned that their benefits are ending and are presented a button that will immediately restore their subscription.

Amazon’s practices aren’t just unfair, they fly in the face of federal consumer protection laws and regulations. That’s why Public Citizen, along with six consumer-focused NGOs, have sent a letter to the FTC demanding an end to the use of these deceptive and unfair practices on the web. To protect consumers from this predatory business model, the federal government needs to step in and ensure that it is just as easy to unsubscribe from a service like Amazon Prime as it is to subscribe.

Read more about our action against Amazon’s use of dark patterns here.

Read our Full Letter to the FTC here.