Lessons from the FTC Settlement with Dating Sites Manager Match Group

How can you guarantee love? And how can you prove that a dating platform failed at its promise?

Match Group made some pretty big pledges to love-seeking customers but ultimately felt short, according to the Federal Trade Commission (FTC).

Taking a closer look at the charges and response provides guidance for other companies in the subscription service market, particularly those using promotional guarantees to attract and retain customers.

The case against Match Group asserted serious allegations concerning deceptive business practices that harmed consumers. Following a lengthy compliance and enforcement action against Match Group Inc., the FTC has recently announced a settlement that includes a $14 million payment and comprehensive changes to the company’s marketing, subscription management, and customer service protocols.

Match Group, Inc. and its subsidiary, Match Group, LLC, operate prominent online dating platforms, including Match.com, OkCupid, PlentyOfFish, and The League. The FTC settlement arose from a complaint filed by the FTC in September 2019. The final order will be enacted once it receives approval from the U.S. District Court for the Northern District of Texas.

Background of the FTC’s Allegations

The FTC’s complaint charged that Match Group engaged in a variety of misleading practices that unfairly disadvantaged customers. The key allegations included:

• Misrepresentation of Subscription Continuation Guarantees:
  • Match Group heavily promoted a “six-month guarantee” program that offered subscribers six additional months for free if they failed to find a romantic match during their paid subscription period.
  • The FTC’s original complaint highlighted that the company did not adequately disclose the multiple eligibility criteria that were associated with this guarantee. The FTC asserted that many consumers might find these requirements challenging or impossible to fulfill, which undermined the legitimacy of the promotion.
• Penalties for Disputing Charges:
  • The FTC claimed that Match Group imposed unfair penalties on customers who attempted to dispute billing errors.
  • Specifically, Match Group allegedly suspended the accounts of individuals who challenged unauthorized charges, depriving them of access to the services they had already paid for, regardless of the remaining subscription duration.
  • The FTC noted that this practice effectively barred consumers from utilizing the dating services to which they paid a subscription, even if they were actively seeking a resolution for billing inaccuracies or had time remaining on paid subscriptions.
• Complicated and Opaque Cancellation Processes:
  • Another serious allegation pointed to Match Group’s convoluted cancellation procedures. The FTC argued that the company created unnecessary barriers and delays for consumers trying to cancel their subscriptions, resulting in prolonged charges and discouraging timely cancellation.
  • This process not only caused frustration but also limited consumers’ ability to manage their subscriptions effectively.

Key Terms of the Settlement Agreement

The settlement, once court-approved, will enforce several critical changes designed to enhance transparency and improve the overall customer experience within Match Group’s business practices. The key provisions of the stipulated final order approving the settlement agreement include:

• Clear and Concise Disclosures:
  • Match Group is required to provide unambiguous descriptions of the terms, conditions, and eligibility requirements associated with its “six-month guarantee” and similar promotional offers.
  • The company must avoid vague or misleading language in any advertising or marketing communications to ensure that potential customers fully understand the terms, conditions and obligations associated with subscriptions.
• Prohibition on Misrepresentation:
  • Match Group is expressly forbidden from making any misleading statements regarding material terms or limitations related to guarantees or promotional offers.
  • This measure is intended to ensure that consumers receive accurate information before making financial commitments.
• No Retaliation for Billing Disputes:
  • The agreement stipulates that Match Group may not suspend or terminate a customer’s account merely for filing a billing dispute—regardless of whether the outcome of that dispute is favorable or not.
  • This is to guarantee that consumers can assert their rights without fear of losing access to services.
• Streamlined Cancellation Process:
  • Match Group must implement user-friendly and straightforward methods for canceling subscriptions, enabling consumers to end their services without facing complex hurdles or delays.
  • The goal is to prioritize customer autonomy and facilitate an easy exit if they choose to discontinue their service.

Consumer Redress and Enforcement

The $14 million payout will be distributed by the FTC to provide financial redress to consumers affected by the alleged practices. While this settlement resolves the FTC’s claims against Match Group, it does not imply an admission of wrongdoing on the company’s part. That said, any breach of this final order could result in hefty additional penalties, highlighting the importance of compliance for Match Group moving forward.

This case emphasizes the FTC’s broader scrutiny of subscription-based business models and the prevalence of “dark patterns” in online commerce—strategic design choices that can obscure important terms, extend billing cycles, or create barriers for consumers seeking to exit costly subscriptions.

Implications for Subscription-Based Businesses

There are lessons to be learned from this cautionary tale. There are best practices that can be put into place to avoid similar complaints from the FTC.

The FTC’s actions underscore crucial lessons for business practices, including:

Substantiate marketing claims

            Customers should know what they are purchasing. Marketing claims must be substantiated by clear, upfront, and transparent disclosures.

Provide equitable access to services

            Irrespective of disputes over charges or terms, ensure that consumers get what they paid for.

Create clear cancellation policies

            Customers need to be able to drop services without hassle. Cancellation processes should be simple, accessible, and user-friendly to ensure that they can disconnect from services without unnecessary complications.

For businesses, the implications are evident: deceptive or excessively burdensome practices can lead to significant legal, financial, and reputational repercussions. Companies must prioritize ethical marketing, transparent communications, and straightforward customer interactions to avoid regulatory scrutiny.