{"data":{"actions":[{"id":"ftc-amazon-2025-prime","pattern":"roach-motel","taxonomy_id":"roach-motel","jurisdiction":"US-federal","instrument":"ROSCA, 15 U.S.C. 8403; FTC Act Section 5","in_force_date":"2010-12-29","prohibits":"Requires clear disclosure of material terms, informed consent before charging, and a simple mechanism to stop recurring charges.","authority":"FTC","target":"Amazon.com, Inc.","decision_date":"2025-09-25","outcome":"settled","penalty":2500000000,"currency":"USD","summary":"Enrollment interfaces where the decline option read 'No, I don't want Free Shipping' signed consumers up for Prime; cancellation ran through a multi-step flow internally nicknamed the 'Iliad Flow' filled with save-offers. $1B civil penalty plus $1.5B redress for an estimated 35 million consumers.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2025/09/ftc-secures-historic-25-billion-settlement-against-amazon","source_type":"regulator-release","boundary_marker":false,"notes":null},{"id":"ftc-epic-2022-coppa","pattern":"privacy-zuckering","taxonomy_id":null,"jurisdiction":"US-federal","instrument":"COPPA Rule, 16 C.F.R. Part 312","in_force_date":"2000-04-21","prohibits":"Requires verifiable parental consent before collecting personal information from children under 13.","authority":"FTC","target":"Epic Games (Fortnite)","decision_date":"2022-12-19","outcome":"settled","penalty":275000000,"currency":"USD","summary":"Epic collected personal data from children under 13 without parental consent and enabled voice and text chat by default. Largest civil penalty for an FTC rule violation at the time.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2022/12/fortnite-video-game-maker-epic-games-pay-more-half-billion-dollars-over-ftc-allegations","source_type":"regulator-release","boundary_marker":false,"notes":null},{"id":"ftc-epic-2022-purchase","pattern":"bait-and-switch","taxonomy_id":null,"jurisdiction":"US-federal","instrument":"FTC Act Section 5, 15 U.S.C. 45","in_force_date":"1938-03-21","prohibits":"Prohibits unfair or deceptive acts or practices in or affecting commerce.","authority":"FTC","target":"Epic Games (Fortnite)","decision_date":"2022-12-19","outcome":"settled","penalty":245000000,"currency":"USD","summary":"Fortnite used a counterintuitive, inconsistent button configuration so players incurred charges with a single press; the same button previewed items in one context and purchased them in another. Epic also locked the accounts of users who disputed charges.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2023/03/ftc-finalizes-order-requiring-fortnite-maker-epic-games-pay-245-million-tricking-users-making","source_type":"regulator-release","boundary_marker":false,"notes":"Settlement announced 2022-12-19; final order March 2023."},{"id":"doj-adobe-2026","pattern":"drip-pricing","taxonomy_id":"hidden-costs","jurisdiction":"US-federal","instrument":"ROSCA, 15 U.S.C. 8403","in_force_date":"2010-12-29","prohibits":"Requires clear disclosure of material terms, informed consent, and a simple cancellation mechanism.","authority":"DOJ on behalf of the FTC","target":"Adobe, Inc.","decision_date":"2026-03-13","outcome":"settled","penalty":150000000,"currency":"USD","summary":"Pre-selected the 'Annual, Paid Monthly' plan as default and buried the early-termination fee, worth 50% of the remaining year, until users tried to cancel; cancellation required navigating multiple pages. The complaint also named two executives.","source_url":"https://www.justice.gov/opa/pr/adobe-agrees-150-million-settlement-and-injunction-resolve-alleged-violations-restore-online","source_type":"regulator-release","boundary_marker":false,"notes":"Complaint filed 2024-06-17 in N.D. Cal. Proposed stipulated order of $150M total ($75M civil penalty, $75M in services) announced 2026-03-13."},{"id":"cnil-shein-2025","pattern":"preselected-consent","taxonomy_id":null,"jurisdiction":"France","instrument":"French Data Protection Act (Loi 78-17), Art. 82","in_force_date":"2019-07-18","prohibits":"Requires free, informed, prior consent before non-essential cookies are placed, with refusal as easy as acceptance.","authority":"CNIL","target":"SHEIN (Infinite Styles Services Co. Ltd)","decision_date":"2025-09-01","outcome":"fined","penalty":150000000,"currency":"EUR","summary":"Advertising cookies were placed the moment a user arrived, before any consent; and when a user clicked 'Refuse all' or withdrew consent, new cookies were still placed and existing ones kept being read. Fine reflected roughly 12 million French monthly visitors.","source_url":"https://www.cnil.fr/en/cookies-placed-without-consent-shein-fined-150-million-euros-cnil","source_type":"official-decision","boundary_marker":false,"notes":"Deliberation SAN-2025-005. SHEIN said it would appeal."},{"id":"ftc-vonage-2022","pattern":"roach-motel","taxonomy_id":"roach-motel","jurisdiction":"US-federal","instrument":"ROSCA, 15 U.S.C. 8403; FTC Act Section 5","in_force_date":"2010-12-29","prohibits":"Requires informed consent before charging and a simple cancellation mechanism.","authority":"FTC","target":"Vonage","decision_date":"2022-11-03","outcome":"settled","penalty":100000000,"currency":"USD","summary":"Consumers could enroll online instantly but could only cancel by phoning a retention agent on a hard-to-find number with limited hours; agents were incentivised to escalate rather than cancel, and porting a number required two separate cancellation procedures.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2022/11/ftc-action-against-vonage-results-100-million-customers-trapped-illegal-dark-patterns-junk-fees-when-trying-cancel-service","source_type":"regulator-release","boundary_marker":false,"notes":null},{"id":"ftc-pch-2023","pattern":"trick-question","taxonomy_id":"trick-wording","jurisdiction":"US-federal","instrument":"FTC Act Section 5; CAN-SPAM Act, 15 U.S.C. 7704","in_force_date":"1938-03-21","prohibits":"Prohibits deceptive acts and deceptive email subject lines.","authority":"FTC","target":"Publishers Clearing House","decision_date":"2023-06-27","outcome":"settled","penalty":18500000,"currency":"USD","summary":"Conflated 'ordering' products with 'entering' the sweepstakes through trick wording and visual interference, placed disclosures in small light font, used false urgency, and concealed shipping and handling fees adding roughly 40% to orders. Email subject lines mimicked tax and official documents.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2023/06/ftc-takes-action-against-publishers-clearing-house-misleading-consumers-about-sweepstakes-entries","source_type":"regulator-release","boundary_marker":false,"notes":null},{"id":"ca-ag-sephora-2022","pattern":"obstruction","taxonomy_id":null,"jurisdiction":"US-state (California)","instrument":"CCPA, Cal. Civ. Code 1798.120 and 1798.135","in_force_date":"2020-01-01","prohibits":"Requires businesses that sell personal information to disclose the sale and provide an opt-out, including honouring opt-out preference signals.","authority":"California Attorney General","target":"Sephora USA, Inc.","decision_date":"2022-08-24","outcome":"settled","penalty":1200000,"currency":"USD","summary":"Data went to third-party advertising and analytics providers, a 'sale' under CCPA, while the site told users it did not sell data, provided no 'Do Not Sell' link, and ignored Global Privacy Control signals.","source_url":"https://oag.ca.gov/news/press-releases/attorney-general-bonta-announces-settlement-sephora-part-ongoing-enforcement","source_type":"regulator-release","boundary_marker":false,"notes":"First public CCPA enforcement settlement."},{"id":"ccpa-in-physicswallah","pattern":"preselected-consent","taxonomy_id":null,"jurisdiction":"India","instrument":"Consumer Protection Act 2019; Guidelines for Prevention and Regulation of Dark Patterns 2023","in_force_date":"2023-11-30","prohibits":"Prohibits 13 specified dark patterns including false urgency, basket sneaking, subscription traps, and forced action, as unfair trade practices.","authority":"Central Consumer Protection Authority (CCPA)","target":"PhysicsWallah Limited","decision_date":null,"outcome":"fined","penalty":500000,"currency":"INR","summary":"Suo-motu action over pre-selected donations and misleading representations of courses as 'free'. Fined Rs 5 lakh and directed to remove the practices.","source_url":"https://www.pib.gov.in/PressReleasePage.aspx?PRID=2268302&reg=3&lang=1","source_type":"regulator-release","boundary_marker":false,"notes":"The primary release does not state a decision date."},{"id":"ccpa-in-mcafee","pattern":"fake-urgency","taxonomy_id":"fake-urgency","jurisdiction":"India","instrument":"Consumer Protection Act 2019; Guidelines for Prevention and Regulation of Dark Patterns 2023","in_force_date":"2023-11-30","prohibits":"Prohibits confirm-shaming and false-urgency design as unfair trade practices.","authority":"Central Consumer Protection Authority (CCPA)","target":"McAfee Software India Pvt. Ltd.","decision_date":null,"outcome":"fined","penalty":100000,"currency":"INR","summary":"The renewal interface used fear-based design that could pressure consumers. Fined Rs 1 lakh and directed to ensure no dark patterns on its platform.","source_url":"https://www.pib.gov.in/PressReleasePage.aspx?PRID=2268302&reg=3&lang=1","source_type":"regulator-release","boundary_marker":false,"notes":"The primary release does not state a decision date."},{"id":"cma-emma-2026","pattern":"fake-urgency","taxonomy_id":"fake-urgency","jurisdiction":"UK","instrument":"Consumer Protection from Unfair Trading Regulations 2008","in_force_date":"2008-05-26","prohibits":"Prohibits misleading urgency and discount claims.","authority":"High Court of England and Wales, on CMA application","target":"Emma Sleep (Emma Matratzen GmbH et al.)","decision_date":"2026-05-22","outcome":"settled","penalty":null,"currency":null,"summary":"Unlike Wowcher and Simba, Emma did not initially commit to changes and the CMA issued court proceedings. A High Court order confirmed the practices were unlawful and Emma gave binding undertakings to stop misleading countdown timers, false 'high demand' messages, and 'limited time' offers where substantially similar deals continue after the deadline.","source_url":"https://www.gov.uk/government/news/court-endorses-cma-action-as-emma-sleep-agrees-to-change-sales-practices","source_type":"regulator-release","boundary_marker":false,"notes":"Partially resolved. A separate 'was/now' pricing claim remained listed for trial in early June 2026 and is not covered by this order."},{"id":"ec-dsa-2025-tiktok-meta","pattern":"obstruction","taxonomy_id":null,"jurisdiction":"EU","instrument":"EU Digital Services Act, Art. 25","in_force_date":"2023-08-25","prohibits":"Prohibits designing online interfaces in a way that deceives or manipulates users or otherwise materially distorts their ability to make free and informed decisions.","authority":"European Commission","target":"TikTok and Meta (Facebook/Instagram)","decision_date":"2025-10-24","outcome":"ongoing","penalty":null,"currency":null,"summary":"Preliminary findings that tools for reporting illegal content and appealing moderation decisions use designs that confuse or discourage users from completing reports. Confirmed breaches could draw fines up to 6% of global turnover.","source_url":"https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2503","source_type":"regulator-release","boundary_marker":false,"notes":"Preliminary findings, not a final decision."},{"id":"ca8-click-to-cancel-2025","pattern":"forced-continuity","taxonomy_id":"forced-continuity","jurisdiction":"US-federal","instrument":"Negative Option Rule, 16 C.F.R. Part 425 ('Click-to-Cancel')","in_force_date":"2025-07-14","prohibits":"Would have required clear disclosure, express informed consent, and cancellation at least as easy as sign-up for negative-option plans.","authority":"U.S. Court of Appeals for the Eighth Circuit","target":"FTC (rule challenged by Custom Communications, Inc. et al.)","decision_date":"2025-07-08","outcome":"dismissed","penalty":null,"currency":null,"summary":"Vacated the FTC's entire Click-to-Cancel rule days before it took effect, holding the FTC failed to conduct the preliminary regulatory analysis required by Section 22 of the FTC Act. The court did not reach the merits. ROSCA and FTC Act Section 5 remain in force.","source_url":"https://ecf.ca8.uscourts.gov/opndir/25/07/243137P.pdf","source_type":"court-opinion","boundary_marker":true,"notes":"Custom Communications, Inc. v. FTC, Nos. 24-3137/24-3388. The rule never became enforceable; in_force_date is when it would have taken effect. Anyone relying on Click-to-Cancel as live US law is wrong."},{"id":"ftc-uber-2025","pattern":"forced-continuity","taxonomy_id":"forced-continuity","jurisdiction":"US-federal","instrument":"ROSCA, 15 U.S.C. 8403","in_force_date":"2010-12-29","prohibits":"Requires informed consent before charging and a simple cancellation mechanism.","authority":"FTC, later joined by 21 states and D.C.","target":"Uber Technologies","decision_date":"2025-04-21","outcome":"ongoing","penalty":null,"currency":null,"summary":"Alleged enrollment of more than 28 million consumers in Uber One without consent, including charging before free trials ended, overstating savings by ignoring the subscription cost, and requiring as many as 23 screens and 32 actions to cancel despite 'cancel anytime' marketing.","source_url":"https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-takes-action-against-uber-deceptive-billing-cancellation-practices","source_type":"regulator-release","boundary_marker":false,"notes":"Allegations, not findings. Amended complaint adding 21 states and D.C. filed 2025-12-15."},{"id":"cnil-banners-2024","pattern":"obstruction","taxonomy_id":null,"jurisdiction":"France","instrument":"French Data Protection Act (Loi 78-17), Art. 82","in_force_date":"2019-07-18","prohibits":"Requires refusal of cookies to be as easy as acceptance and consent to be freely given.","authority":"CNIL","target":"Multiple unnamed website publishers","decision_date":"2024-12-12","outcome":"injunction","penalty":null,"currency":null,"summary":"Formal notices over cookie-banner design: prominent 'Accept' buttons against 'Reject' presented only as a plain-text link, ambiguous wording, repeated prompts, and rejection buried behind extra clicks. One month to comply or face fines.","source_url":"https://www.cnil.fr/en/dark-patterns-cookie-banners-cnil-issues-formal-notice-website-publishers","source_type":"regulator-release","boundary_marker":false,"notes":null},{"id":"cma-simba-2024","pattern":"fake-urgency","taxonomy_id":"fake-urgency","jurisdiction":"UK","instrument":"Consumer Protection from Unfair Trading Regulations 2008","in_force_date":"2008-05-26","prohibits":"Prohibits misleading actions such as false urgency and misleading price-comparison claims.","authority":"CMA","target":"Simba Sleep Limited","decision_date":"2024-07-25","outcome":"settled","penalty":null,"currency":null,"summary":"Countdown clocks implied consumers had to act quickly, and 'was' reference prices did not reflect genuine prior selling prices. Undertakings require any higher comparison price to have achieved real sales at that price, for a sufficient period and in sufficient volume, before it may be used.","source_url":"https://www.gov.uk/cma-cases/simba-sleep-limited-consumer-protection-case","source_type":"regulator-release","boundary_marker":false,"notes":"Undertakings signed 2024-07-25; compliance processes required by 2024-09-09. No fine possible pre-DMCCA."},{"id":"cma-wowcher-2024","pattern":"preselected-consent","taxonomy_id":null,"jurisdiction":"UK","instrument":"Consumer Protection from Unfair Trading Regulations 2008","in_force_date":"2008-05-26","prohibits":"Prohibits unfair commercial practices, including misleading actions and misleading omissions.","authority":"CMA","target":"Wowcher","decision_date":"2024-07-15","outcome":"settled","penalty":null,"currency":null,"summary":"Countdown, 'deals refresh' and checkout timers created false urgency, and a pre-ticked box signed customers up to a paid VIP membership. Undertakings accepted and roughly £4,271,000 credited in refunds to over 870,000 customers.","source_url":"https://www.gov.uk/cma-cases/wowcher-group-consumer-protection-case","source_type":"regulator-release","boundary_marker":false,"notes":"No fine was possible: this predates the CMA gaining direct penalty powers under the DMCCA 2024."},{"id":"accc-google-2022-dismissed","pattern":"trick-question","taxonomy_id":"trick-wording","jurisdiction":"Australia","instrument":"Australian Consumer Law, s.18 (Competition and Consumer Act 2010, Sch. 2)","in_force_date":"2011-01-01","prohibits":"Prohibits conduct in trade or commerce that is misleading or deceptive or likely to mislead or deceive.","authority":"Federal Court of Australia","target":"Google LLC","decision_date":"2022-12-09","outcome":"found-lawful","penalty":null,"currency":null,"summary":"The court dismissed the ACCC's case, finding Google did not mislead consumers with a 2016 on-screen 'I agree' notification and privacy-policy change that expanded combining personal data with browsing activity. A limit on consent-notification deception claims.","source_url":"https://www.accc.gov.au/media-release/court-dismisses-accc-case-against-google","source_type":"regulator-release","boundary_marker":true,"notes":"Judgment of Yates J, 2022-12-09."},{"id":"ftc-match-2022-dismissal","pattern":"roach-motel","taxonomy_id":"roach-motel","jurisdiction":"US-federal","instrument":"ROSCA, 15 U.S.C. 8403; FTC Act Section 5","in_force_date":"2010-12-29","prohibits":"Requires a simple mechanism to stop recurring charges.","authority":"U.S. District Court, N.D. Texas","target":"Match Group / Match.com","decision_date":"2022-03-24","outcome":"dismissed","penalty":null,"currency":null,"summary":"The court dismissed with prejudice the counts over fraudulent 'someone likes you' notifications and struck all monetary-damages requests on the guarantee-offer and chargeback counts, while letting the ROSCA hard-to-cancel count proceed. Courts will trim dark-pattern theories at the pleading stage.","source_url":"https://www.sec.gov/Archives/edgar/data/891103/000089110323000038/mtchars2023a.pdf","source_type":"company-filing","boundary_marker":true,"notes":"Weakest citation here. The source is Match Group's own SEC filing reproducing the docket history of FTC v. Match Group, No. 3:19-cv-02281-K, not the docket itself. Treated as company-filing rather than court-opinion for that reason. Reportedly settled for $14M in 2025; no primary source verified for that."}],"total":19,"boundary_markers":3,"largest_penalty":{"amount":2500000000,"currency":"USD","target":"Amazon.com, Inc."},"coverage":{"corpus_total":19,"matched":19,"pattern_recognised":true,"unenforced_anywhere":[{"pattern":"confirmshaming","note":"Named in FTC and CCPA guidance and listed in India’s 2023 Guidelines, but no primary decision isolating it as a standalone charge was found. It appears only bundled into broader cases."},{"pattern":"sneak-into-basket","note":"Named in India’s 2023 Guidelines and reportedly the subject of CCPA show-cause notices to 11 platforms, but no finalised decision naming a company and penalty was primary-sourced."},{"pattern":"nagging","note":"Appears inside the fact patterns of other cases but was not primary-sourced as a standalone charge anywhere."},{"pattern":"fake-scarcity","note":"Named in guidance and in the CMA’s online choice architecture taxonomy, but no decision isolating it from urgency and countdown claims was primary-sourced."}],"law_without_enforcement":[{"jurisdiction":"South Korea","instrument":"Act on Consumer Protection in Electronic Commerce, Art. 21-2","in_force_date":"2025-02-14","note":"Statute verified. A KFTC sanction of four platforms totalling KRW 10.5M was reported for 2025-10-15 but no primary KFTC decision URL was found."},{"jurisdiction":"Brazil","instrument":"Consumer Defence Code (CDC)","in_force_date":"1991-03-11","note":"No finalised Senacon or ANPD decision penalising dark patterns was primary-sourced; only an opened sanctioning proceeding against Meta."}],"excluded_for_no_primary_source":[{"target":"Honda","authority":"California Privacy Protection Agency","reported":"USD 632,500"},{"target":"Ediscom S.p.A.","authority":"Garante (Italy)","reported":"EUR 300,000"},{"target":"Google and Facebook","authority":"CNIL (France)","reported":"EUR 150M and EUR 60M, 2022 cookie decisions"},{"target":"Google","authority":"CNIL (France)","reported":"EUR 325M, 2025"},{"target":"Amazon","authority":"European Commission CPC network","reported":"Prime cancellation changes, 2022"},{"target":"Coupang, Contents Wave, NHN Bugs, Spotify","authority":"KFTC (South Korea)","reported":"KRW 10.5M total, 2025"},{"target":"X (Twitter)","authority":"European Commission","reported":"DSA preliminary findings on dark patterns, 2024"},{"target":"ATG and Warner Music Sweden","authority":"IMY (Sweden)","reported":"cookie-banner design"},{"target":"American Express","authority":"ICO (UK)","reported":"cookie-banner design"}],"note":"Every action returned cites a primary source. Reported cases that could not be tied to a regulator or court document are listed in excluded_for_no_primary_source and are not counted here."},"interpretation":"Enforcement history, not legal advice. An action against one company is evidence a regulator will act, not a ruling about your interface. Outcomes marked dismissed or found-lawful bound the rule and are as decision-relevant as the fines. Penalties are in the currency stated on each record and are not converted."},"_meta":{"request_id":"req_36167d8ed04a43dbb28c1378028babc0","product":"psych/enforcement","version":"1.0.0","receipt_id":null,"cost":{"quoted":0,"charged":0,"currency":"USD","display":"0.000000"},"cache":{"hit":true,"age_s":15454},"provenance":{"sourcing_class":"B","upstream":["internal:enforcement-corpus@2026-07"],"fetched_at":"2026-10-13T10:43:34.966Z","license":"proprietary"},"freshness":{"as_of":"2026-07-01","staleness_s":15454},"confidence":1}}