A "Pay $0 today" button sits at the bottom of a health intake form on the Hims and Hers site. A man fills in his symptoms, clicks the button, and gets charged eight hundred and ninety-seven dollars before a doctor ever speaks to him. The form was not a consultation. It was a billing trigger.
"Make it easy to buy." Every growth team in the country runs on some version of that line. It sounds right. It is not. The FTC, joined by Utah and California, filed a complaint against Hims and Hers earlier this summer. The charge at the center of it: when you collapse the research step and the purchase step into the same screen, the customer cannot tell they are buying. The form becomes the trap.
The Mechanism
The FTC's complaint lays out a specific flow. Hims ran ads that told consumers they could "connect" with a provider for a "free consult" to find a treatment "right for them." The site said users would "only be charged if prescribed." Then the intake form asked health questions. At the end of it, the screen read "Due Now, $0." A button said "Pay $0 today."
Most users never spoke to a provider. They filled out a form, clicked a button, and got billed for a subscription to drugs they had not reviewed at a price they had not agreed to. One customer cited in the complaint paid $897 before any provider contact. Another paid $147 for a three-month drug supply after saying on the form that they were "open to" medication.
The form was the transaction. The button was the receipt dressed up as an invite. Nothing about this case depends on a hacker or a breach. Every part of the flow was built on purpose, by the company, for the company.
Most people treat this as a bad-actor story. It is a system flaw. The same flaw shows up in a much bigger case.
The Pattern
Amazon built a cancellation process so hard to use that its own staff named it "Iliad," after the ten-year Trojan War. Internal documents called unwanted subscriptions "an unspoken cancer." One employee described the whole practice as "a bit of a shady world." In late 2025, Amazon paid $2.5 billion to settle the FTC's charges. One billion in fines. Another one and a half billion in refunds to consumers who never meant to subscribe.
Two companies. Two industries. The same mechanics underneath. When you erase the line between browsing and buying, the signup rate goes up. So does the refund rate, the complaint rate, and the federal filing that follows both.
The day the FTC filed against Hims, the market erased $970 million from the company's value in a single session. The market priced the risk the moment the mechanism had a name.
"Make it easy to buy" does not fail people. It fails the system they are trying to run.
The Structural Flaw
The problem is not intent. The problem is that the form replaced the conversation. When the research step and the purchase step share the same screen, the customer loses the ability to tell which one they are in. That is not a design choice. It is a billing trap with a clean interface on top of it.
The Replacement
Federal law already names what honest billing looks like. ROSCA, the Restore Online Shoppers' Confidence Act, requires three things for any auto-renewing subscription: clear disclosure of all terms, informed consent before the charge, and a simple way to cancel.
Those three rules map to three operational moves.
Move 1: Separate the form from the charge
The intake form collects information. The payment screen collects money. Those are two different actions. They belong on two different pages with a clear label on each. If a user can finish both steps in a single click, you have collapsed the gap between research and purchase.
This is the part most operators skip, because splitting the flow feels like adding friction to a process built for speed. It is friction. That friction is the proof your customer chose to buy.
Move 2: Name the commitment before the click
Before the payment button, state the price, the billing cycle, and the renewal date in plain words. Not in a terms-of-service link at the bottom. Not in gray text below the fold. On the button itself, or in a bold line right above it. The Hims intake flow told users "Due Now, $0" while the system queued a charge for hundreds of dollars. That is the gap between what the screen says and what the system does. Close it.
Move 3: Build the exit into the entrance
The cancel path should be as short as the sign-up path. Same number of clicks. Same number of screens. If it takes one click to subscribe and six screens to leave, you are not retaining customers. You are trapping them. Amazon's "Iliad" is where that road leads: a ten-year war metaphor coined by your own staff, followed by a $2.5 billion check to the federal government.
What the System Shows
Running these three steps for even one full billing cycle does something the old advice never did:
You see which customers chose to buy and which were carried through by default. You see where the real drop-off lives. It is not the payment screen. It is the disclosure screen, where you named the price out loud. You see your true conversion rate, stripped of the inflation from users who did not know they converted. And you see the refund requests go quiet, because the people who stayed meant to stay.
The Check
At the end of one full billing cycle, ask three things:
→ What moved the number: the disclosure, the consent step, or the cancel path?
→ What looked like growth but left no paying customer behind it?
→ What complaint showed up more than once?
That is the gap between advice that sounds right and a system that proves itself.
Where You Stand
The button is still on a thousand sites: "Pay $0 today," "Free consultation," "Get started now." The words shift, but the mechanics do not. If the customer cannot tell which step they are in, they are not buying. They are being billed.
