In a significant escalation of regulatory pressure on the gig economy giant, Uber is now facing a coordinated legal assault from the Federal Trade Commission and nearly half of the United States. The core of the dispute centers on the company's Uber One subscription service, with authorities alleging a pattern of deceptive billing and intentionally obstructive cancellation processes designed to trap consumers. This lawsuit represents a major test of consumer protection laws in the era of app-based, recurring revenue models and could set a precedent for how tech companies obtain consent and handle cancellations.
The Coordinated Legal Onslaught Against Uber's Subscription Model
The legal landscape for Uber shifted dramatically this week. On December 15, 2025, the Federal Trade Commission (FTC) filed an amended complaint that was joined by an unprecedented coalition of 21 states and the District of Columbia. This move transforms the case from a federal action into a nationwide legal challenge, signaling a unified front among state attorneys general and federal regulators. The states involved span the country, from Alabama and Arizona to New York and California, indicating broad, bipartisan concern over the alleged practices. The amended complaint intensifies an original lawsuit filed by the FTC in April, adding significant legal firepower and a specific request for civil penalties under both federal and state laws.
States Joining the FTC Lawsuit (21 States + DC): Alabama, Arizona, California, Connecticut, Illinois, Maryland, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New York, North Carolina, Ohio, Oklahoma, Pennsylvania, Virginia, West Virginia, Wisconsin, and the District of Columbia.
Allegations of "Dark Patterns" and Deceptive Enrollment
Regulators have leveled serious accusations at Uber's business practices, focusing on how the Uber One subscription was marketed and managed. The complaint alleges that Uber charged consumers for the subscription without obtaining their clear, informed consent. In some instances, customers were reportedly billed before their advertised free trial periods had even expired, effectively nullifying the "free" offer. Furthermore, the lawsuit claims that Uber made misleading claims about the potential savings from the subscription, which promises members USD 0 in delivery fees and savings of up to USD 25 per month. Authorities contend that these advertised benefits were not consistently delivered, misleading consumers about the true value of the service.
Key Allegations from the Complaint:
- Deceptive Billing: Charging for Uber One without clear consent; billing before free trials ended.
- Misleading Savings Claims: Promoted savings (USD 0 delivery fees, up to USD 25/month) that were not consistently delivered.
- Obstructive Cancellation: Allegedly requiring users to navigate up to 23 screens and take 32 actions to cancel, violating "simple mechanism" requirements.
- Legal Violations: Cited violations of the Restore Online Shoppers’ Confidence Act (ROSCA) and various state laws.
The "Labyrinthine" Cancellation Process Under Scrutiny
Perhaps the most damning allegation centers on the difficulty of canceling the Uber One subscription. The FTC and states claim that Uber's design of the cancellation flow constitutes a "dark pattern"—a user interface crafted to confuse and frustrate users trying to end a service. The complaint details that some subscribers were forced to navigate a "lengthy and difficult process," which could involve tapping through as many as 23 different screens and taking 32 separate actions to cancel. This, regulators argue, directly contradicts Uber's public promise of an easy, "cancel-anytime" membership and violates the requirement for a simple cancellation mechanism under the Restore Online Shoppers’ Confidence Act (ROSCA).
Uber's Defense and the Stakes of the Lawsuit
In response to the allegations, Uber has firmly denied any wrongdoing. The company stated that its sign-up and cancellation workflows are clear and compliant with the law. In a pointed rebuttal, Uber claimed that cancellations "can now be done anytime in-app and take most people 20 seconds or less," a stark contrast to the regulators' description of a 23-screen labyrinth. Uber has also framed the lawsuit as an overreach that threatens the fundamental operations of the modern subscription economy, warning that a successful case could "disrupt how most subscription-based services function today." The company has vowed to contest the allegations in court, setting the stage for a high-stakes legal battle.
Uber's Public Response:
- Denies all allegations of deceptive practices.
- States cancellation "can now be done anytime in-app and take most people 20 seconds or less."
- Claims the lawsuit threatens standard subscription service operations.
- Plans to contest the allegations in court.
Potential Ramifications for the Tech Industry and Consumer Rights
The outcome of this lawsuit could have far-reaching consequences beyond Uber. It serves as a clear signal from regulators that "friction-heavy" cancellation interfaces and unclear consent flows for recurring payments are now a top enforcement priority. A ruling against Uber could lead to substantial civil penalties and force a widespread redesign of subscription models across the tech industry, particularly for apps that rely on automated renewals. For consumers, the case highlights the growing legal tools available to challenge opaque digital commerce practices. As of December 17, 2025, this coordinated action stands as one of the most significant regulatory challenges to a major technology platform's core business practices in recent years.