Washington Attorney General Nick Brown recently secured a consent decree with Homeaglow, Inc. (d/b/a Dazzling Cleaning) and its two founders over allegations that the on-demand cleaning platform deployed dark patterns, misleading subscription models, and fake reviews in violation of Washington’s Consumer Protection Act. The case delivers a clear message: Regulators are aggressively targeting deceptive digital practices. Here’s what happened and what your company can do to stay ahead.

What went wrong

Homeaglow attracted consumers with low introductory cleaning offers ($19 or $79) but buried the catch: Redeeming them auto-enrolled consumers in a $59/month “ForeverClean” membership for a minimum of six months – with no additional services included. Every cleaning also triggered a 5–15% transaction fee. Consumers who tried to cancel early faced fees of hundreds of dollars. One Washington consumer paid $600.75 for a single cleaning initially advertised at $79.

The company also deployed classic dark patterns – fake countdown clocks and fabricated “vouchers remaining” indicators designed to pressure quick purchases. Compounding the deception, Homeaglow advertised a five-star Trustpilot rating despite having an actual score of 1.3 stars. Trustpilot removed roughly 4,000 fake reviews and sent Homeaglow a cease-and-desist letter in 2025. The Better Business Bureau also logged over 3,300 complaints in three years.

Consent decree highlights

• Monetary relief. Defendants must pay $2.25 million to Washington and cooperate fully with consumer restitution.
• Advertising reforms. No more misrepresenting introductory offers. If an offer triggers a negative option feature (auto-renewal or subscription), all material terms – pricing, obligations, and cancellation – must be disclosed clearly and conspicuously in the same advertisement.
• Negative option reforms. All material terms must be disclosed before collecting billing information. Express informed consent is required – no pre-checked boxes, bundled consent, or opt-out mechanisms. Dark patterns (fake timers, scarcity indicators, or urgency cues) and visual de-emphasis of material terms (e.g., via formatting, placement, font size, or similar techniques) are also prohibited.
• Cancellation rights. Consumers must be able to cancel at any time through a mechanism at least as easy as enrollment – no dissuasion tactics. Homeaglow must notify existing members of their right to cancel without early termination fees and provide easy cancellation links and options for at least one year.
• Review integrity. No artificial reviews, misrepresented ratings, or selective suppression of negative feedback. Ongoing practices must comply with FTC regulations (16 CFR Parts 255 and 465).
• Compliance monitoring. Homeaglow must file sworn annual compliance reports for four years. The Attorney General retains audit rights, and violations carry penalties of up to $125,000 each, plus restitution and injunctive relief.

(Read the full consent decree here.)

Action steps for your business

Below are compliance measures for consideration by companies using subscription models, auto-renewals, or other negative option features: 

• Audit enrollment disclosures. Verify that all material terms (price, frequency, commitment length, termination fees) appear clearly before billing – not buried in expandable sections or fine print.
• Require express consent. Obtain separate, affirmative consent for any negative option feature. Eliminate pre-checked boxes and bundled consent.
• Simplify cancellation. Make cancellation at least as easy as sign-up. Evaluate “save” flows (discount offers in lieu of honoring cancellation requests) – the FTC has flagged these as a potential unfair practice.
• Eliminate dark patterns. Remove fake countdown timers, scarcity indicators, and urgency cues not tied to real availability.
• Verify review practices. Confirm compliance with FTC endorsement and testimonial rules. No fake reviews, no suppression of negative feedback.

Reed Smith’s advertising team is tracking enforcement trends in this space and is ready to help you strengthen your compliance posture. Reach out to stay ahead of the curve.