The Federal Trade Commission has announced a $35 million settlement with Shutterstock over allegations that the company used deceptive subscription practices, including misleading consumers about billing terms and making cancellation unnecessarily difficult. The action is the latest in the FTC’s broader campaign against so-called “dark patterns” — interface designs or workflows that steer consumers into purchases, renewals, or ongoing charges they may not have knowingly agreed to.

At a high level, the case reflects a familiar enforcement theory: regulators are focusing not just on what companies disclose, but on how those disclosures are presented and whether consumers can realistically avoid or end recurring charges.