The FTC filed the lawsuit in April 2025 alongside 21 state attorneys general. The core dispute centers on how Uber's app integrates stored payment credentials into the enrollment process. Specifically, courts have established that ROSCA requires subscription disclosures to precede consumer authorization of stored payment information, not occur simultaneously. Uber's practice of allowing users to pre-store payment data for individual transactions, then using those credentials for subscription enrollment without adequate advance notice of material terms, appears to violate this timing requirement. The judge signaled that companies might satisfy ROSCA by giving consumers a "clear opportunity to affirmatively opt in" after reviewing required disclosures, but simultaneous presentation of terms and authorization falls short.
Attorneys should monitor this case as it establishes enforceable precedent for subscription practices affecting millions of consumers. The ruling reinforces that convenience features cannot override consumer protection law and signals the FTC's sustained focus on dark patterns in subscription cancellation. Companies leveraging stored payment data to reduce enrollment friction while making cancellation difficult face heightened regulatory risk. Similar enforcement actions are likely to follow.