On August 12, the Federal Trade Commission (FTC) ordered Match Group, owners and operators of online dating platforms such as Match.com, OkCupid, PlentyOfFish, The League, and others, to pay $14 million. This settlement resolves the FTC’s 2019 complaint accusing Match of misleading claims involving guarantees and onerous subscription cancellation processes, contrary to the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA).

Specifically, the FTC’s 2019 complaint alleged the following practices by Match Group as part of its subscription program:

  1. Misleading Guarantees: Match Group claimed to offer a free six-month subscription if users did not “meet someone special,” but failed to disclose the stringent requirements needed to qualify for such a guarantee.
  2. Complex Cancellation Process: Match Group complicated the subscription cancellation process, making it challenging for users to end the subscription.
  3. Account Suspensions: Consumers who attempted billing disputes had their accounts suspended, denying them access to services without refunding their money.

Under the terms of the settlement, Match Group will pay $14 million in restitution and is required to implement the following corrective measures:

  1. Disclose Guarantee Terms: Clearly and prominently disclose the conditions and limitations associated with any guarantees, alongside avoiding any misrepresentations, such as, maintaining an approved public profile with a primary photo to redeem the free six-month offer, interacting with at least five subscribers monthly, and utilizing the progress page to claim the free extension in the final week of the initial subscription period.
  2. Protect Against Retaliation: Abstain from punitive actions against users filing billing disputes and ensure such consumers continue to receive their paid-for services.
  3. Simplify Cancellations: Offer straightforward and accessible mechanisms for subscription cancellation.
  4. Submit Compliance Reports: Submit a compliance report to the FTC one year post-settlement, detailing its operational activities and compliance status with the order.

Why It Matters

Despite the change in federal administration, this settlement and other recent actions by the FTC underscore the FTC’s commitment to enforce against alleged unfair and deceptive marketing practices governed by the FTC Act and ROSCA to ensure transparency and fairness by companies offering subscription programs.

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Photo of Clayton Friedman Clayton Friedman

Clayton is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice, multidisciplinary teams with decades of experience crafting effective strategies to help deter or mitigate the risk of enforcement actions and…

Clayton is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice, multidisciplinary teams with decades of experience crafting effective strategies to help deter or mitigate the risk of enforcement actions and litigation.

Photo of Michael Yaghi Michael Yaghi

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile…

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile clients in regulatory enforcement investigations involving all facets of their business, including but not limited to, advertising and sales practices, monthly membership programs, auto renewal programs, telemarketing and telephone solicitations, door-to-door sales practices, and endorsements. Having begun his career as a commercial litigator, he also supports clients throughout litigation, should an investigation move in that direction.

Photo of Namrata Kang Namrata Kang

Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer…

Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.