Wireframes to Witness Testimony: Lessons from an FTC Deposition

In 2022, I became the first Amazon employee formally interviewed by the FTC, not exactly the kind of UX case study I thought I’d be writing about. As a UX Designer working on Prime, I was deeply involved in optimizing worldwide customer experiences, including designing processes that affected how users engaged with a Prime membership. Two years later, in December 2024, I was called again?—?this time for a full days deposition.

While I won’t (and legally can’t) get into specifics about Amazon’s legal strategy or the FTC’s case, what I can share is what this experience has taught me about being a UX designer working at the intersection of product, business, regulatory scrutiny, and now?—?AI. My work has always been about making experiences clearer and more intuitive for customers. Beyond designing for customer joy includes designing flows that are legally compliant, friction-aware, and business-aligned?—?because good UX doesn’t just serve customers; it also aligns with broader company objectives.

I’m now designing in a world increasingly influenced by AI, which adds both opportunities and risks. The same ethical concerns that surfaced in my FTC experience?—?clarity, transparency, and consumer trust?—?are now amplified by AI-driven decision-making in UX.

The Reality of UX at?Scale

When working on a platform as large as Amazon, UX design isn’t just about making things pretty?—?it’s about systems thinking. Every tweak to an interface can impact millions of users, influence business KPIs, and, as I learned firsthand, become the subject of regulatory scrutiny. UX isn’t just a “nice-to-have” discipline; it’s a core business function that can determine whether a company’s practices are perceived as transparent and fair or misleading and manipulative.

If you’d told me in 2016 that my Figma files , emails, and chats would one day be scrutinized by regulators, I’d have laughed. And yet — here we are.

As a designer, you may not think your work will ever land you in the embrace of the Feds, but the reality is that regulators are paying closer attention to how digital products shape consumer behavior. The experiences we create don’t just impact user satisfaction?—?they can affect legal compliance, corporate ethics, and even antitrust discussions. This means UX designers need to ask harder questions, anticipate potential concerns, and ensure our work stands up to scrutiny.

With AI rapidly integrating into UX, we now face new ethical questions:

  • Are AI-driven personalization algorithms shaping user behavior responsibly?
  • Is AI automating friction in ways that subtly discourage users from making informed choices?
  • How do we ensure AI-generated interfaces remain accessible, inclusive, and user-friendly?

As designers, we have a responsibility to ensure that AI is used as a tool for enhancing user experiences, not manipulating them. Otherwise, we risk heading down the same path that led to scrutiny over deceptive design patterns and dark UX.

Regulations lag innovation?—?UX is a front line?defender

Technology moves fast. Regulations move slowly. This has always been the case. When dark patterns first started creeping into digital products, they were largely ignored?—?until regulatory bodies started catching up.

The FTC’s case against Amazon isn’t an isolated event. It’s part of a growing trend: regulators are playing catch-upon deceptive UX, nudging, AI-driven decision-making, and consent architectures that shape user behavior. But while government oversight takes years to materialize, UX designers are already on the front lines.

Like it or not, UX designers often end up acting as unofficial regulators in product design. We make calls on what’s fair, what’s clear, and what’s just a shady growth hack in disguise. This means UX designers have the autonomy and responsibility to:

  • Flag questionable design choices before they become liabilities.
  • Push for internal ethical guidelines in product development.
  • Ensure AI-powered experiences maintain user autonomy and trust.

In many ways, design teams are doing the regulatory work before regulators even show up. Because by the time laws are written, billions of users may already have been affected.

So, the question to me is: are we proactively designing for clarity and fairness, or are we waiting until the lawsuits arrive?

Regulatory Frameworks to Watch

  • European Union: Digital Services Act (DSA) (2024) The DSA establishes comprehensive rules for online platforms operating within the EU, emphasizing platform accountability and user experience fairness. It aims to create a safer digital space where users’ rights are protected, and platforms are held accountable for their services. Digital Services Act
  • United States: California Privacy Rights Act (CPRA) Effective from 2023, the CPRA enhances consumer privacy rights in California, introducing stricter data protection measures. It impacts UX design by requiring clear user consent mechanisms and providing users with more control over their personal information. California Privacy Rights Act
  • United States: Blueprint for an AI Bill of Rights (2023) This initiative outlines principles to protect individuals from potential harms related to AI systems, emphasizing user rights, data privacy, and algorithmic transparency. It serves as guidance for developing user-centric AI applications. Blueprint for an AI Bill of Rights
  • African Union: Continental Artificial Intelligence Strategy (2024), Endorsed in July 2024, this strategy promotes ethical, responsible, and equitable AI practices across African nations. It aligns with Africa’s Agenda 2063 goals, aiming to accelerate social and economic transformation through AI AI Watch: Global Regulatory Tracker?—?African Union
  • Australia: Australia has developed voluntary AI Ethics Principles to guide the responsible design, development, and implementation of AI. These principles aim to ensure AI systems are safe, secure, and reliable, promoting public trust in AI technologies. AI Watch: Global Regulatory Tracker?—?Australia
  • Asia-Pacific: Countries in the Asia-Pacific region are rapidly developing AI regulatory frameworks. Policymakers are reviewing existing regulations and proposing new AI-specific rules to address emerging risks and ensure ethical AI deployment. Overview of AI Regulatory Landscape in APAC
  • Global: In September 2024, the Council of Europe introduced the first international, legally binding treaty on AI. The convention emphasizes human rights, democracy, and the rule of law, requiring signatories to implement safeguards against AI misuse. UK Signs First International Treaty to Implement AI Safeguards

Lessons for UX?Design

  1. Clarity and Transparency Matter?—?Designing interfaces that clearly communicate options, whether for sign-ups, cancellations, or purchases, is both a user experience and a compliance concern. If customers feel misled or manipulated, it’s only a matter of time before someone?—?whether it’s the media, regulators, or advocacy groups?—?starts asking tough questions.
  2. Know Your Business Context?—?UX doesn’t happen in a vacuum. Understanding business objectives, marketing strategies, and even legal considerations helps designers create experiences that balance user needs with corporate goals. If you don’t know why a design decision is being made, you’re designing blind.
  3. UX Can Have Real-World Consequences?—?The fact that my work on Prime’s UX eventually became a subject of FTC inquiry reinforced a key lesson: what we create can have far-reaching implications. Whether you’re designing for e-commerce, fintech, healthcare, or any other industry, recognize that your work may one day be examined not just for usability, but for ethical implications.
  4. Regulators Care About UX?—?More than ever, government agencies are scrutinizing dark patterns, misleading UI elements, and design choices that impact consumer decision-making. UX professionals need to be aware of emerging policies, case studies, and ethical considerations in the field. This isn’t just a legal issue?—?it’s a design issue.

My Takeaway: UX is a new regulatory battleground

Being deposed by the FTC wasn’t something I ever expected as a UX designer, but it reinforced my belief that good design is about more than usability?—?it’s about responsibility. I’m sharing this because, as an industry, we need to have more conversations about the broader implications of our work. If my experience helps even one other designer think more critically about their designs, then it’s worth sharing.


Thanks for reading!

I’m just trying to make sense of a career filled with equal parts chaos and curiosity. If something here resonated, made you laugh, or even made you think, let me know?—?I’d love to hear your thoughts. Got feedback, a story to share, or just want to say hi? Drop a comment. If you enjoyed this, as they say “hit the like button or follow along” for more reflections, screw-ups, and occasional wisdom.

Lauren Martin

Director of Client Relations at Blink UX

1 个月

Thanks for sharing, C.R. Brown. What an experience for sure!

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