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CA SB 478 / FTC Junk Fees Rule / UCL / NY GBL §349

Junk Fees / Drip-Pricing Cases

Drip pricing — advertising one price, then adding mandatory "service," "processing," "convenience," or "resort" fees only at checkout — became squarely unlawful in California under SB 478 (effective July 2024) and is the target of the FTC's new Unfair-or-Deceptive-Fees rule. The violation is provable from the cart-to-checkout flow itself: we capture the advertised price and every fee added at each step.

Elements & controlling authority

  1. Defendant advertised a price that excluded mandatory fees
    Cal. B&P §17501.1 / SB 478; FAL §17500; FTC 16 CFR Part 464.
  2. Mandatory fees were disclosed only at a later checkout step
    SB 478 (all-in pricing); FTC §464.2 (total price up front).
  3. The fees are not government taxes or bona fide shipping
    SB 478 carve-outs; FTC §464.3 — defendant bears that burden.
  4. Likely to deceive a reasonable consumer / material
    Williams v. Gerber Prods., 552 F.3d 934 (9th Cir. 2008).
  5. Plaintiff paid more than the advertised price (injury)
    Kwikset, 51 Cal.4th 310; CLRA § 1780 (restitution + damages).

The evidence you need — and what we capture

Every capture is sealed at collection: SHA-256 hash-chained artifacts with RFC 3161 trusted timestamps, a methodology block, and a documented scope of audit. If the defendant changes the site tomorrow, the record of today survives.

Damages framework

UCL/FAL restitution of the undisclosed fees, CLRA § 1780 statutory damages, and injunctive relief; class = purchasers charged the mandatory fee during the period, with per-purchase damages equal to the captured drift.

Frequently asked

What does California SB 478 require for pricing?

Effective July 2024, the advertised price must include all mandatory charges except government taxes and reasonable shipping. A "service fee" or "processing fee" added only at checkout violates the all-in-pricing requirement.

How do you prove a drip-pricing / junk-fee case?

By capturing the cart-to-checkout sequence: the advertised price, then each mandatory fee added at later steps, with the total drift computed and sealed — the fee that only appears at checkout is the dispositive fact.

Pre-vetted defendants in this lane are live on the marketplace. Each listing clears arbitration-posture review, a prior-litigation screen against the federal docket, and a human editorial gate before it appears. First buyer takes the defendant exclusively.

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