FTC Escalates Uber One Deceptive Billing Lawsuit: 21 States Join Fight Against Subscription Scams
The legal battle over “dark patterns” and hidden subscription costs has reached a boiling point. The Federal Trade Commission (FTC), joined by a bipartisan coalition of 21 states and the District of Columbia, filed an amended complaint Monday against transportation giant Uber Technologies, Inc. The suit alleges that Uber engaged in deceptive billing and cancellation practices regarding its Uber One subscription service, effectively “trapping” consumers in recurring charges.
For legal professionals and consumer advocates, this case highlights a growing trend in consumer protection litigation and the aggressive enforcement of the Restore Online Shoppers’ Confidence Act (ROSCA).
The Allegations: “23 Screens to Cancel”
Originally filed in April, the updated lawsuit provides staggering details of Uber’s alleged “cancellation labyrinth.” According to the complaint, some users were forced to navigate as many as 23 screens and perform 32 separate actions just to end their membership.
Key allegations include:
- Unauthorized Enrollment: Enrolling customers in Uber One without clear consent, particularly after free trials.
- Misleading Savings: Falsely promising up to $25 in monthly savings and “$0 delivery fees” that many users reportedly never received.
- The 48-Hour Block: Preventing users from canceling via the app if they were within 48 hours of their next billing cycle, forcing them to contact a “support” team that often failed to respond before the next charge hit.
Uber has vehemently denied these claims. In a company statement, Uber argued that its processes are transparent and warned that a victory for the FTC would “upend how virtually every modern subscription service operates.”
Why This Matters: The Rise of “Dark Patterns” Enforcement
The FTC’s aggressive stance signals a new era of digital regulation. “Companies should not be able to profit by tricking consumers into recurring charges,” said New York Attorney General Letitia James, one of the leaders of the state coalition.
The lawsuit seeks civil penalties and restitution for millions of affected users. If successful, it could force a massive shift in the user experience (UX) design of subscription-based apps, moving away from “negative option” features where silence is taken as consent for billing.
Legal & Business Impact Checklist:
- FTC Act Section 5: Broad authority over “unfair or deceptive acts.”
- ROSCA Violations: Failure to provide a “simple mechanism” to stop recurring charges.
- State Consumer Acts: 22 Attorneys General are now seeking state-level penalties.
A Sensitive Moment for Uber
This legal escalation comes at a critical time for Uber. As the company pushes for higher margins through recurring revenue, Uber One has been its primary tool for building customer loyalty. However, the “Cold Snap” of regulatory scrutiny may chill those growth plans.
As of December 16, 2025, the case remains pending in the U.S. District Court for the Northern District of California.
Frequently Asked Questions: The FTC vs. Uber Deceptive Practices Lawsuit
The expansion of the Federal Trade Commission’s (FTC) lawsuit against Uber marks a pivotal moment in digital consumer rights. With 21 states and the District of Columbia now involved, the case targets “dark patterns” in the Uber One subscription model. Below are the most frequent questions regarding the 1.7.0 era of this legal battle.
1. What are the core allegations in the amended FTC suit?
The lawsuit focuses on three primary deceptive practices:
- Unauthorized Enrollment: Alleging Uber enrolled users in Uber One without clear consent, often following “free trials” that transitioned into paid memberships without sufficient notice.
- Deceptive Savings Claims: Uber marketed Uber One with promises of “$0 delivery fees” and “$25 in monthly savings,” yet many users reported being charged fees regardless or failing to see any net benefit.
- The “Cancellation Labyrinth”: The FTC claims Uber utilized “dark patterns”—manipulative interface designs—to prevent cancellations. In some instances, users had to navigate 23 screens and perform 32 actions just to end a subscription.
2. Which states have joined the FTC in this lawsuit?
A bipartisan coalition of 21 states has joined the amended complaint, including New York, California, Illinois, New Jersey, Pennsylvania, and North Carolina. The involvement of these states allows the suit to seek civil penalties under local state consumer protection laws, which can significantly increase the total financial liability for Uber.
3. What is the “48-Hour Block” mentioned in the legal filings?
One of the most controversial allegations is that Uber made the “End Membership” button invisible if a user attempted to cancel within 48 hours of their next billing cycle. During this window, users were forced to contact “Support,” a process that was often delayed until after the next recurring charge had already been processed.
4. How has Uber responded to these claims?
Uber has formally denied the allegations, stating that their sign-up and cancellation processes are clear and legally compliant. The company argues that the majority of cancellations take less than 20 seconds. Crucially, Uber warned that an FTC victory could “upend how virtually every modern subscription service operates,” suggesting that the lawsuit challenges standard industry practices for “negative option” billing.
5. Can consumers get a refund or join a class action?
While the FTC suit seeks restitution for affected consumers, it is a government enforcement action rather than a private class action. However, private law firms are already filing individual arbitrations on behalf of Uber One users. Depending on your state (such as New York or California), successful claims could result in refunds or statutory damages ranging from $500 to $550.
6. What is the “Click-to-Cancel” rule?
This lawsuit is a major test of the FTC’s recently enacted “Click-to-Cancel” Rule. This regulation mandates that companies must make canceling a subscription as easy as it was to sign up. The Uber case serves as a warning to all SaaS and subscription-based platforms that “byzantine” cancellation flows are now a primary target for federal and state regulators.
