My question was more like this: There is some statutory basis for enforcement. If "dark patterns" is itself a basis for enforcement, there's some legal definition of it, and I'm curious to know how that's operationalized, since the definition given here doesn't seem precise enough to be legally actionable.
At the end of the FTC doc, there's this statement:
> Firms that nonetheless employ dark patterns, take notice: where these practices violate the FTC Act, ROSCA, the TSR, TILA, CAN-SPAM, COPPA, ECOA, or other statutes and regulations enforced by the FTC, we will continue to take action.
This implies that dark patterns themselves are not a cause for action and some other specific law or regulation needs to be violated in order for the FTC to act.