Photo of Alyssa Paddock

Alyssa Paddock is an associate in the Finance and Bankruptcy Practice Group in the firm's New York office.

On October 18, the CFPB sued a software company for utilizing their online payment platform to enroll unknowing consumers into annual subscriptions through deceptive acts and “dark pattern” techniques in violation of the CFPA and EFTA. Among other things, the complaint alleges that the company encouraged consumers to unknowingly enroll in free trials and converted the free trials into annual subscriptions through a “negative option” renewal policy (our sister blog covered “negative option” marketing in a previous post here). During this process, the company allegedly collected consumers’ registration information and consumer payments data (e.g., credit or debit card number) so that it could transmit the consumer payments data through its payments systems. Continue Reading CFPB Sues Payment Platform Over Dark Patterns