The Non-Financial Ledger

The people hit here were independent creators, freelancers, and small businesses: the everyday person buying a few images for a project. They trusted plain words like “one-time,” “no commitment,” and “free.” Then they watched money leave their accounts for things they never knowingly agreed to buy.

One customer described downloading two images from what they believed was a two-image pack, then finding a fresh $20 charge they did not recognize and did not authorize. Another told the Better Business Bureau the company “secretly billed my credit card $29/mo for 34 months without any email invoice or notification.” Staff suggested sending a reminder before charging. The company chose not to.

When people tried to leave, the company made them fight for it. They hit dead phone numbers, long holds, and an eight-screen maze that hid the exit fee until the very end. In the company’s own internal words, the cancellation fee was a “constant source of confusion/frustration for customers,” and it kept the fee anyway.

Legal Receipts

“[H]opefully we can get away with it.”

• This came right after employees shared news that the government had sued competitor Adobe for nearly identical subscription tactics.
• It shows the company saw the legal risk clearly and chose to keep going instead of fixing the disclosures.
• The speaker was a Senior Product Manager who has since become Director of Product.

“the only way to get the most money out of the guy that only buys a 1 time [on demand 2 pack] is to get him to use it so that I charge him again to refill him on that [pack] (turning $30 into $60 and so on).”

• This is the auto-refill scheme stated as strategy: the “one-time” pack was built to bill the buyer again.
• A senior leader, the Head of Growth and Strategy, pushed for auto-refill to be the default specifically to double the charge.
• It directly contradicts the public promise of “No commitment.”

The higher cancellation fee increases retention, which is “a win” over the longer term.

• The Chief Marketing Officer framed locking people in with a bigger exit fee as a victory in an internal email.
• The company raised the fee in May 2024 and applied it retroactively, without telling existing customers.
• Early cancellations dropped 70% in the first week.

“For packs, an order refill will also be triggered by your use of all assets in the pack (e.g., when you download all 5 assets in a 5-pack). To cancel, please visit the Plans page.”

• This was the only refill disclosure, and it sat in the last sentence of a document over 6,000 words long.
• It used a third term, “assets,” after the site elsewhere said “downloads” and “licenses,” adding to the confusion.
• It told users to “cancel,” when the feature they actually needed to switch off was auto-refill, giving wrong instructions.

Public Deception

Shutterstock’s marketing promised simplicity. Its own pages and internal records show the opposite was built in.

• It branded the auto-renewing annual plan “Best Value” and “a sweet deal,” while hiding that it renews yearly and charges a fee to leave early.
• It sold packs as “Best for a one-time project” with “No commitment,” then charged the card again the moment the last download was used.
• It advertised “Get 10 free images,” then converted that free trial into a paying annual plan carrying the same exit fee.
• The only on-screen hint was a faint gray line, “Cancellation fee applies. See terms & conditions,” placed below the bright “Buy now” button.
• An internal survey of unhappy free-trial users named one recurring theme outright: “[u]nclear/dishonest advertising.”

Profit-Maximization At All Costs

The harm was a design choice. Internal messages show leaders picking revenue over honest disclosure.

• The early-cancellation fee is currently 50% of the consumer’s remaining contract, which the company treats as a retention tool.
• In May 2024 it raised that fee and applied it retroactively to existing customers without notice; early cancellations fell 70% in week one.
• A Director of Growth and Strategy wrote in January 2024 that the fee “might be ugly but we need to find a way to drive this business up.”
• A Senior Director of Product Management admitted auto-refill “does not feel good at all from a [user experience] perspective,” then added “it’s gotta be done.”
• When employees suggested reminder emails before a free trial converted to paid billing, the company declined to send them.

Legal Minimalism: The Letter But Not The Spirit

Shutterstock often put the truth in writing, then placed it where almost no one would find it. ROSCA requires clear disclosure and a simple way to cancel; the company satisfied the words while defeating the purpose.

• The plan page hid renewal and fee terms inside ten separate FAQs at the very bottom that buyers were never required to open.
• The pack auto-refill term lived in the final sentence of a contract longer than 6,000 words.
• The fine print that did appear sat below the “Complete checkout” button, in small gray type buyers could finish paying without ever seeing.
• ROSCA’s Section 8403 requires a simple way to stop charges; the company instead built an exit of at least eight screens and ten clicks.
• The customer service number for cancellations was wrong and out of service, listed incorrectly seven times in the Terms of Service.

This Is The System Working As Intended

Add up the documented facts and a pattern appears: the conduct paid, the company knew, and the penalty arrived years late with no admission of guilt.

• The deceptive model ran since at least 2020, through thousands of consumer complaints the company monitored.
• Staff watched the government sue Adobe in June 2024 for the same practices, predicted Shutterstock would “be next,” and kept going.
• A manager’s stated hope was simply to “get away with it.”
• The case ended in a $35,000,000 settlement in which Shutterstock “neither admits nor denies” the allegations.
• The company is still allowed to sell the same kind of auto-renewing products.

Societal Impact Mapping

The cost landed on the people least able to absorb a surprise charge: independent creators, freelancers, and small businesses.

The Settlement Isn’t Justice

A $35 million check closes the case. It does not undo years of charges, and it lets the company sidestep responsibility.

• Shutterstock “neither admits nor denies” the allegations, so there is no legal finding of wrongdoing on the record.
• The $35,000,000 is a single fixed sum set against conduct that ran for years and drew thousands of complaints.
• The FTC will distribute that fund as consumer redress, spread across a nationwide base of sign-ups built up over years.
• The action names only the corporation; no individual executive is a defendant or personally penalized.
• By the FTC’s own example, leaving one plan could cost $159.50, and one trial user reported roughly $986 in charges over 34 months (calculated from source figures: $29 x 34).

What A Legitimate Fix Looks Like

The core failure this case exposes: a company can hide the most important terms until after it has your card, then make leaving expensive and slow.

Regulatory Track

• The FTC should require that auto-renewal, the existence and dollar amount of any early-exit fee, and any auto-refill appear on the same screen as the price, before any card details are entered.
• Enforce ROSCA’s simple-cancellation rule with a hard symmetry standard: leaving must take no more steps than signing up did.
• Ban retroactive fee increases imposed on customers who agreed to different terms.

Legislative Track

• Strengthen ROSCA (the 2010 law at the center of this case) so a term buried in a 6,000-word contract no longer counts as adequate disclosure.
• Require dated, plain-language reminders before any free trial converts to paid billing.
• Mandate a working, monitored cancellation channel, with penalties for publishing dead contact numbers.

Corporate Governance Track

• Strip “retention” metrics that reward friction and exit fees out of executive and product-team compensation.
• Require board-level sign-off and an independent audit of every checkout and cancellation flow for hidden terms.
• Build a duty to document and act on internal warnings; staff here flagged the harm for years and were overruled.

What Now?

Direct your attention to the company behind this case and the agency that brought it.

• Hold accountable the roles that drove this: Shutterstock’s Chief Marketing Officer, Chief Product Officer, Director of Product, and Head of Growth and Strategy, all referenced in the filing.
• Watchlist: the Federal Trade Commission (Case No. 1:26-cv-03955) is the lead enforcer and filed this case.
• Watchlist: your state Attorney General and the Better Business Bureau both received complaints here and accept consumer reports.
• Check your statements now for recurring Shutterstock charges, “refill” packs, or trials that converted, and file at reportfraud.ftc.gov if you find them.
• Organize: pool experiences with other affected creators, share the cancellation steps, and back consumer groups pushing click-to-cancel rules.