TLDR
The State of Texas made one allegation about LG’s Smart TV privacy interface that should be impossible for anyone to forget:
one click to opt in, more than 40 clicks to fully opt out.
According to Texas’s 2025 lawsuit, LG presented customers with multiple privacy and advertising agreements during initial TV setup and provided a convenient Select All option. Texas alleged that fully reversing ACR and related advertising permissions later required navigating four or more separate menus and approximately 40-plus clicks. The state called the contrast a quintessential dark pattern and specifically accused LG of Privacy Zuckering and creating a Roach Motel: easy to enter, painfully difficult to leave.
LG later reached a settlement with Texas requiring informed consent before ACR viewing-data collection, clearer disclosure, and a clear and simple way to opt out.
The old process therefore deserves to be remembered for what it was.
LG understood how to make consent convenient.
Privacy was where the company suddenly became very bad at simplicity.
I do not believe that was an accident.
One Click Is Not an Accident of Interface Design
Take the privacy debate out of it for a moment.
A Select All button exists for one reason: convenience.
Designers use it when they understand that users may want to perform several actions at once and do not want to repeat the same interaction six times.
LG understood this perfectly during initial Smart TV setup.
The Texas complaint includes a photograph of an LG Terms & Conditions screen displaying several agreements, including a Viewing Information Agreement, Voice Information Agreement, Interest-Based & Cross-Device Advertising Agreement, and other terms. At the bottom is a Select All control.
The consumer can therefore simplify the entire decision.
Select everything.
Agree.
Continue.
That is efficient interface design.
Then try to get out.
According to Texas, the efficiency disappears.
Texas Said Full Withdrawal Took More Than 40 Clicks
The Texas complaint alleged that fully opting out of ACR and related advertising tracking required consumers to deal with privacy rights scattered across at least four separate menus and roughly 40-plus clicks.
The state listed six user agreements plus the Do Not Sell My Personal Information option and said the controls appeared in different parts of LG’s settings interface.
Texas’s complaint contains a screenshot of the withdrawal process accompanied by a warning that dependent Smart TV functions could become unavailable and that the television would restart after changes were applied. On that same page, Texas alleges that privacy choices were spread across multiple menus requiring approximately 40-plus clicks.
This is an astonishing contrast.
LG knew how to build a shortcut when a shortcut increased consent.
When the customer wanted to withdraw all of that consent, suddenly there was no equivalent:
Reject All Optional Tracking
button.
Apparently that breakthrough in user-interface design remained undiscovered.
The Numbers Tell the Story Better Than Corporate PR Ever Could
One.
Forty.
Those numbers are devastating because they cut through every corporate argument about choice.
LG can say the agreements were optional.
LG can say users could withdraw consent.
LG can say the settings existed.
LG can say people remained in control.
Texas’s response was essentially:
Look at how the control actually worked.
One direction was built like an express lane.
The other was built like a government office designed by Kafka.
That is why Texas called it a dark pattern.
A Choice Is Not Neutral When One Direction Is Forty Times Harder
Imagine two doors.
One opens automatically when you approach it.
The other requires you to find a key hidden on another floor, enter a code, sign a form, and restart the building.
Technically, both doors exist.
Nobody sensible would call them equally accessible.
Privacy interfaces work the same way.
Every extra click imposes friction. Every menu creates another opportunity to give up. Every unfamiliar label creates another moment of uncertainty. Every warning screen creates another chance that the user decides the privacy change is not worth potentially breaking something.
Companies understand friction extremely well.
Retailers obsess over reducing checkout clicks because fewer clicks increase conversion.
Apps streamline registration because every extra screen loses users.
Streaming companies know exactly how much cancellation friction changes churn.
Advertising companies measure engagement down to fractions of a percentage point.
Yet when privacy settings require dozens of interactions, corporations suddenly act as though interface friction is some abstract academic concept.
It is not.
Friction changes behavior.
That is why you add it.
Texas Said the Design Manipulated the Moment of Consent Too
The click disparity was only one part of the state’s argument.
Texas also attacked when LG presented the choices.
According to the complaint, consumers went through a multi-page initial setup flow before reaching the Terms & Conditions screen. There, Texas says, they were confronted with six agreements. Although the boxes were unchecked, LG offered the Select All shortcut.
Texas alleged that this occurred when consumers were eager to finish setting up the new television and start watching it.
That argument makes intuitive sense to anyone who has ever configured a new consumer-electronics product.
Nobody buys a 77-inch television because they are excited to spend Saturday night reading six legal agreements.
They want the screen to turn on.
They want Netflix.
They want the game.
They want to know whether all that money actually bought a good picture.
Consent obtained in that context should be designed to slow people down and make the meaning obvious, not offer a shortcut that makes all the pesky questions disappear.
“Select All” Was a Remarkably Convenient Answer to Choice Overload
Texas specifically accused LG of taking advantage of what it called the paradox of choice.
Give someone enough choices and decision-making becomes harder. Faced with a screen full of agreements, the easiest path becomes increasingly attractive.
LG had the solution sitting right there.
Select All.
That button is not evil in isolation.
It becomes much more interesting when paired with the later opt-out process Texas described.
LG solved choice overload in the direction that maximized acceptance.
It did not solve opt-out complexity with equal enthusiasm.
That asymmetry is what matters.
The Opt-Out Path Was Buried Behind Menus
Texas also alleged that the privacy controls were buried behind a non-intuitive menu path.
The complaint describes consumers navigating through the TV interface to reach Privacy & Terms and then going deeper into User Agreements and other privacy controls. Texas’s screenshots document the menu progression and the separate agreement screens.
Again, none of these steps is impossible.
That is precisely why dark patterns are effective.
Nobody needs to physically block the user.
You only need to make the desired action tiresome enough that a meaningful percentage of people never finish.
A company can then say every setting was available.
What it cannot honestly say is that availability automatically equals fairness.
The FTC Has a Name for This Kind of Garbage
The Federal Trade Commission defines dark patterns broadly as interface designs that can obscure, subvert, or impair consumer autonomy and decision-making.
Its 2022 report specifically warns companies against burying privacy choices, forcing consumers to navigate multiple screens, presenting confusing toggles, or otherwise making privacy choices difficult to access and understand.
The FTC’s advice is almost embarrassingly simple: privacy choices should be easy to find, understandable, and presented when consumers are actually making decisions about their information.
LG’s alleged 40-click privacy maze is practically the opposite philosophy.
Read the FTC’s dark-pattern report
“Roach Motel” Is an Ugly Name Because It Describes an Ugly Design
Texas explicitly called LG’s alleged interface a Roach Motel.
The phrase refers to experiences designed to make getting in easy and getting out difficult.
You can see why Texas chose it.
One-click enrollment.
Dozens of interactions to reverse everything.
That is almost comically on the nose.
Texas also accused LG of Privacy Zuckering, a term used for manipulating people into giving away more private information than they intended or would have knowingly agreed to.
These were allegations in the state’s complaint, not final findings after a trial.
But LG subsequently settled and agreed to changes addressing consent, disclosure, and ease of opting out.
That makes the old design difficult to dismiss as merely critics complaining about aesthetics.
Then Came the “Do Not Sell” Puzzle
Even after users made it into the privacy settings, the interface could throw another curveball.
The Do Not Sell My Personal Information setting required users to turn the protection on.
That wording is grammatically defensible. But it creates the exact double-negative problem the FTC warns about when a Do Not Sell control is paired with an off toggle. The FTC says such design can leave consumers uncertain which position actually stops the sale.
So the privacy-conscious customer had to learn another rule.
Some optional tracking and advertising features are things you decline or leave off.
The Do Not Sell protection is something you turn on.
The user is no longer exercising a right.
They are solving LG’s interface puzzle.
Withdrawal Came With a Warning
Then there was the warning screen.
Texas’s complaint shows LG warning that withdrawing agreement from a legal document could make dependent Smart TV functions unavailable and that the television would restart to apply the change.
There can be legitimate reasons for such a message.
If a function genuinely depends on an agreement, the manufacturer should explain that.
But context matters again.
Imagine the user’s experience.
They have finally found the privacy menu.
They have navigated the individual agreements.
They are trying to withdraw consent.
Now the television warns them that Smart TV functionality may disappear and the device is going to restart.
A technically accurate warning can still create friction.
And friction is exactly what this interface already had in abundance.
LG Is Too Sophisticated for Me to Believe This Was All Accidental
This is the point where I stop extending endless benefit of the doubt.
LG is not a five-person startup building its first app.
It is a multinational electronics company capable of manufacturing advanced OLED panels, maintaining a global Smart TV operating system, operating cloud infrastructure, processing ACR information, and supporting an advertising business built around understanding viewing behavior.
LG Ad Solutions openly analyzes consumer trends and viewing habits. Its ACR materials divide audiences according to subscriptions, purchases, ad exposure, games, viewing intensity, and location.
This organization understands user behavior.
It understands conversion.
It understands engagement.
It understands how much individual steps influence outcomes.
So no, I do not believe LG simply stumbled into a design where broad consent was one click and maximum privacy took more than forty.
Texas explicitly alleged intentional manipulation in its complaint. That allegation was never fully adjudicated at trial because the matter settled.
My opinion is simpler.
The outcome was far too consistently favorable to LG to shrug off as innocent incompetence.
Texas Eventually Forced a Simpler Standard
In May 2026, Texas announced its agreement with LG.
LG agreed that ACR viewing information would not be collected without informed consent. It agreed to provide a pop-up disclosure explaining how viewing information may be collected and used. Most relevant here, Texas said consumers would receive a clear and simple way to opt out of viewing-data collection agreements.
Clear and simple.
Those words are devastating in context.
Because if the old system had already been clear and simple, there would be nothing to fix.
The settlement was not an admission of every allegation Texas made.
It was, however, an agreement to make the privacy experience substantially more consumer-friendly.
Read the Texas Attorney General’s LG privacy settlement announcement
Current LG TVs Are Not Frozen in the Old System
It is important not to pretend nothing changed.
LG’s September 2026 privacy statement says ACR, voice recognition, and interest-based advertising are now optional and off by default. It says the features require separate agreements and can be managed or withdrawn through TV settings. Declining them does not prevent use of core Smart TV functionality such as apps, live television, HDMI devices, and updates.
Those are meaningful improvements.
They do not erase the old interface.
They demonstrate that better design was possible.
Which raises the obvious question: why did consumers need a lawsuit and settlement to get there?
One Click Versus Forty Is a Philosophy, Not Just a UX Metric
This story matters because it reveals how companies can think about consent.
If the company thinks consent is merely something it needs legally, it optimizes for obtaining it.
Make the prompt smooth.
Reduce friction.
Bundle decisions.
Finish setup quickly.
If the company thinks privacy is a genuine consumer right, it optimizes withdrawal with equal enthusiasm.
One click in.
One click out.
That symmetry is what respect looks like.
LG’s alleged architecture had the first half.
The second half somehow disappeared.
That tells me more about the company’s historical privacy philosophy than a thousand sentences about user choice.
Privacy Should Be Exactly as Easy to Withdraw as It Is to Give
This should become a universal rule.
If one button can accept every optional privacy agreement, one button should reject every optional privacy agreement.
If consent takes ten seconds, withdrawal should take ten seconds.
If the company knows where all the data permissions are because it designed the software, it should not make the customer hunt through four menus to find them.
Anything less creates the obvious suspicion that the friction is doing useful work for the business.
LG’s old system was a spectacular example.
One click to say yes.
Forty-plus clicks to say no.
Texas called it a dark pattern.
I call it contempt for the customer dressed up as choice.
References
State of Texas v. LG Electronics U.S.A., Inc., Original Verified Petition, December 2025. Texas alleged that LG’s setup provided one-click enrollment while full withdrawal required roughly 40-plus clicks through multiple menus, characterizing the disparity as Privacy Zuckering and a Roach Motel.
Read Texas’s original complaint against LG
Texas Office of the Attorney General, May 11, 2026. The settlement requires informed consent before ACR viewing-data collection, clearer disclosure, and a clear and simple opt-out.
Read the Texas-LG privacy agreement announcement
Federal Trade Commission, Bringing Dark Patterns to Light, September 2022. The FTC warns against buried privacy choices, confusing toggles, multi-screen privacy processes, and designs that subvert consumers’ decision-making.
Read the FTC’s dark-pattern report
LG Electronics, Understanding Privacy on LG Smart TVs, September 12, 2026. LG’s current privacy statement says optional ACR, voice recognition, and interest-based advertising are off by default and can be managed or withdrawn through TV settings.
Read LG’s current Smart TV privacy statement
LG Ad Solutions, Trusted ACR Technology. LG’s advertiser-facing materials show the commercial value of behavioral audience categories tied to viewing, purchases, ad exposure, gaming, and location.
Read LG Ad Solutions’ ACR technology page