A proposed class action—Garcia v Hairmax International LLC, was filed in California federal court targeting the laser hair therapy brand Hairmax. The lawsuit asserts that Hairmax unlawfully failed to make clear and conspicuous auto-renewal disclosures as mandated by the California Automatic Renewal Law (ARL), California Unfair Competition Law, and California Consumers’ Legal Remedies Act.
Hairmax’s checkout page displayed critical auto-renewal language only in small, gray, 10.5-point font beneath a large, vivid PAY NOW button, making it easy to overlook. While a link was provided to the cancellation policy, the suit insists there was no explicit description of the complete instructions on how to cancel, a clear requirement of the ARL.
Dark Patterns and Consumer Impact
The complaint highlights that Hairmax’s checkout flow forces users to navigate multiple steps and confirmation screens to cancel subscriptions. Even locating the cancellation route requires clicking a link from an order confirmation email. These practices, the filing argues, exemplify dark patterns, deliberate UX designs that make canceling subscriptions frustrating and confusing.
The lead plaintiff, a California resident, said she purchased Hairmax conditioner for $32.93 in May 2025, but was auto-charged another $31.95 a month later, and had to take extra steps to cancel. The suit seeks monetary restitution and class certification for “all persons who, while in California, purchased a product or service from Hairmax.com in response to an automatic renewal offer” within the statute of limitations.
Regulatory and Industry Crackdown
Hairmax’s troubles mirror a broader crackdown on dark patterns and opaque subscription practices in the U.S. In 2025, California and federal authorities brought numerous cases, including a $7.5 million settlement against HelloFresh and a record-setting $2.5 billion FTC settlement against Amazon, both targeting unclear or manipulative subscription experiences and persistent obstacles to cancellation.
The FTC and multiple state Attorneys General have explicitly warned brands that auto-renewal terms must be bold, easily found, and totally transparent at the point of sale—not tucked away in links or small print. Recent lawsuits against streaming platforms like Peacock, DAZN, and Shapermint also center on hidden or confusing renewal disclosures, echoing the allegations now facing Hairmax.
Best Practices and Consumer Rights
Consumer law experts stress that subscription brands must show renewal and cancellation terms directly on the checkout page, in type and color that stands out. The process to cancel must be as easy as signing up, and consumers shouldn’t have to hunt through emails or navigate repetitive confirmation pages.
California’s ARL, along with new federal guidance, makes any use of friction, fine print, or confirmation-shaming a risk for class action and regulatory fines. Affected customers typically won’t need to take action at the outset of these cases, but should keep proof of purchase for later notification if refunds or credits are available.
Setting a New Bar for Subscription Transparency
If the Hairmax action is successful, it will further cement the shift toward total transparency in digital subscriptions. It follows dozens of recent cases settled by brands as diverse as Chegg, Coursera, and Lovevery, with patterns of hidden auto-renewal terms targeted repeatedly by both courts and regulators.
he ARL imposed a statutory duty upon Defendant to disclose such information to consumers who purchased subscriptions from Defendant or entered into continuous service agreements. With regulatory scrutiny, class action risk, and consumer awareness at an all-time high, brands that ignore these requirements face growing legal and reputational peril.
