A federal judge has ruled that Amazon’s Prime subscription sign-up process violated the Restore Online Shoppers’ Confidence Act (ROSCA) by collecting payment information before fully disclosing terms. The ruling also opened the door for two Amazon executives to be held personally liable. The case now moves to trial on Sept. 26, with the FTC pressing its claims that Amazon’s “Iliad” cancellation flow obstructed users from ending subscriptions.

On September 17, 2025, U.S. District Judge John H. Chun issued a Summary Judgment Order (Doc. 490) in FTC v. Amazon.

In the order, the court concluded:

• Prime qualifies as a negative option service under ROSCA. The judge wrote: “Prime is subject to [ROSCA] because it is a service ‘sold in a transaction effected on the Internet through a negative option feature.’”

• Amazon violated ROSCA in its sign-up process. The court found that “Amazon [failed] to disclose all terms of Prime before collecting consumers’ payment information.”

• Executives could face personal liability. The order allows the FTC to pursue claims against two senior Amazon leaders if evidence shows they participated in or had authority over the practices.

• Cancellation flows remain at issue for trial. Judge Chun noted there is “competing evidence as to the simplicity of Amazon’s cancellation process — which Amazon refers to internally as ‘Iliad’ — and what qualifies as ‘simple’ under the act.”

The ruling also bars Amazon from arguing that ROSCA does not apply to Prime enrollment and limits certain defenses going into trial.

Case Timeline

• June 2023 → FTC files complaint alleging deceptive Prime sign-up and cancellation flows.

• 2023–2024 → Motions and discovery; Amazon fails to get case dismissed.

• July 2025 → Judge admonishes Amazon over disclosures; FTC unsuccessfully sought trial delay.

• Sept. 17, 2025 → Judge Chun issues summary judgment order: FTC wins key claims; cancellation process question left for jury.

• Sept. 26, 2025 → Trial scheduled to begin in Seattle federal court.

INSIDER TAKE

For subscription executives, this ruling carries immediate lessons:

• Disclose before billing. Courts are scrutinizing the sequence of your sign-up flow. All terms — costs, renewal frequency, cancellation policy — must be clear before payment details are collected.

• Simplify cancellation. Amazon’s “Iliad” process highlights risk in multi-step offboarding. Even reaffirmation prompts may be questioned in court.

• Accountability at the top. The possibility of executive liability shows regulators are willing to pursue individuals, not just companies.

• Compliance is strategy. As regulatory standards tighten, transparency in billing and cancellation is not only a legal shield but a competitive advantage in building subscriber trust.

Bottom line: The FTC’s case against Amazon is a bellwether for the entire subscription economy. Every business with recurring billing should review enrollment and cancellation flows now — before regulators or consumers do it for them.