TLDR
LG has spent years insisting that consumers have choices about Smart TV tracking. Technically, that is true. The more important question is whether those choices were presented in a way normal people could reasonably understand and exercise.
Texas said no.
In its 2025 lawsuit against LG, the state alleged that LG buried privacy controls behind multiple menus, presented consumers with six different agreements during initial setup, offered a convenient Select All option, used vague labels such as Viewing Information Agreement, and then required approximately 40-plus clicks across several menus to fully unwind the privacy permissions later. Texas explicitly called parts of LG’s design “Privacy Zuckering” and a “Roach Motel.”
The most revealing part is that LG never had to literally remove the privacy choice. It only had to make saying yes easy and understanding how to say no exhausting.
That is the difference between technical consent and meaningful consent.
And LG’s old privacy interface is a nearly perfect case study in how corporations can turn a legal right into a scavenger hunt.
LG Could Always Point to the Checkbox
This is the corporate defense that makes privacy debates so frustrating.
There was a setting.
There was an agreement.
There was an opt-out.
The customer clicked something.
Case closed.
Except user interfaces do not work that way.
A choice can exist and still be manipulated. A button can be available while remaining difficult to find. A disclosure can technically contain the right words while being written in language most buyers will never understand. A company can make accepting six agreements nearly effortless while making the reverse process an afternoon project.
The Federal Trade Commission has spent years warning about exactly this problem. Its 2022 dark-pattern report describes privacy interfaces that obscure choices, bury settings, use confusing toggles, push users toward greater data collection, or make privacy-preserving choices needlessly difficult.
LG’s historical Smart TV consent flow reads like someone used that report as a checklist and misunderstood which side they were supposed to be on.
Read the FTC’s Bringing Dark Patterns to Light report
The Privacy Decision Arrived When Customers Were Trying to Finish Setting Up a TV
Texas’s complaint gives us a useful picture of the actual experience.
A customer turns on a new LG television and moves through a multi-page onboarding process. Eventually they reach a Terms & Conditions screen containing six different agreements. These included LG’s terms and privacy policy, the Viewing Information Agreement, Voice Information Agreement, Interest-Based and Cross-Device Advertising Agreement, Marketing Communications Agreement, and Who.Where.What? Agreement.
And sitting underneath the choices was an extremely convenient option:
Select All.
That matters because context matters.
The customer did not wake up that morning hoping to conduct a privacy audit. They probably spent an hour unpacking a giant television, attaching the stand or mounting it on a wall, connecting HDMI cables, joining Wi-Fi, installing updates, and figuring out why the soundbar was not behaving.
Now LG hands them six agreements.
The person wants to watch the television.
LG gives them one button capable of making the paperwork disappear.
Texas’s allegation was blunt: the state said LG designed the consent architecture to put these decisions in front of consumers when they were least likely to carefully read and evaluate them because they were eager to finish setup.
That is not a trivial UX detail. It is the environment in which supposed consent was obtained.
Six Agreements Is Not Necessarily Six Meaningful Choices
Giving people more checkboxes can create the appearance of greater control.
Sometimes it does the opposite.
Texas explicitly invoked the paradox of choice, arguing that the pile of agreements increased the difficulty of figuring out which choices mattered and what each one actually meant. The boxes themselves could all be unchecked, but the consumer had to know why they might want that state and what functionality or data processing each agreement controlled.
That is where LG’s terminology becomes important.
A person who sees Interest-Based and Cross-Device Advertising Agreement can probably make a reasonable guess about what it does.
Viewing Information Agreement is much softer.
LG’s current privacy statement now explicitly explains that its optional ACR system can identify supported content and that ACR information may be used for audience segmentation and viewing-trend analysis. With separate advertising consent, information can also support interest-based and cross-device advertising.
That is much clearer than the phrase Viewing Information by itself.
Texas argued that the old terminology and disclosures did not adequately communicate what consumers were actually authorizing.
And that is the central consent problem: a user cannot meaningfully agree to something they do not meaningfully understand.
LG Understood One-Click Convenience Perfectly
The most damning part of the Texas complaint is not that opting out was literally impossible.
It is the asymmetry.
During setup, LG provided a one-click route to broad enrollment.
Later, according to Texas, fully opting out of ACR and related advertising tracking required consumers to navigate different parts of the settings interface and deal with approximately 40-plus clicks. Texas said the relevant rights and agreements were scattered across four or more separate menus.
Texas called the contrast between one-click enrollment and the 40-plus-click withdrawal process a quintessential example of dark patterns.
That should infuriate people.
LG clearly understood the value of reducing friction. It built a button that could accept everything at once.
Then, when the consumer wanted maximum privacy, suddenly nobody at LG could think of a button that said:
Reject All Optional Tracking.
Apparently that technological breakthrough was beyond the company that makes OLED televisions.
The Opt-Out Path Became a Treasure Hunt
Texas documented one path through LG’s interface as moving through Home, Settings, Accessibility, Support, and finally Privacy & Terms before consumers could even reach the relevant privacy choices. Additional agreement and Do Not Sell controls existed from there.
Whether every LG model and webOS version used the identical path is not the important part. The complaint concerns the system Texas examined.
The important part is the design philosophy.
Why should privacy controls live somewhere a normal television owner has to hunt for?
Privacy is not an obscure developer preference.
It is not a calibration setting for professional installers.
It is not an accessibility option somebody should have to stumble through before eventually reaching Support.
If a company genuinely considers privacy a fundamental user right, the controls should be one of the easiest parts of the device to find.
Settings > Privacy.
There. I fixed it.
Changing Your Mind Could Trigger Another Warning Screen
The Texas complaint also includes an image of the warning consumers encountered when changing preferences.
The screen warned that withdrawing agreement from a legal document could make dependent Smart TV functions unavailable and that the television would restart to apply the changes.
Some warning may be technically justified. If a feature genuinely depends on a data agreement, the user should know that disabling the agreement may disable the feature.
But look again at the overall user journey.
Accepting agreements is presented during onboarding, with a Select All shortcut.
Undoing them later requires hunting through settings, changing multiple preferences, and then encountering a warning that Smart TV functions could stop working and the television will restart.
This is the exact point at which many normal people say:
“Forget it.”
That is why interface friction matters.
Every extra menu, warning, restart, confirmation, ambiguous label, and buried control changes behavior.
Consent does not happen in a vacuum.
“Do Not Sell” Somehow Needed Its Own Logic
Then LG added one of the most absurd privacy controls imaginable.
Consumer Reports’ current guide tells LG owners that under Privacy & Terms they can find Do Not Sell My Personal Information and must activate that toggle if they want LG to limit third parties from commercializing their information.
So the privacy-conscious consumer is navigating a system where optional collection and advertising agreements are things they decline or leave off, while Do Not Sell My Personal Information is a protection they turn on.
That is exactly the kind of interface ambiguity the FTC has specifically warned about.
The FTC’s dark-pattern report actually uses the generic example of a Do Not Sell My Information option followed by an off toggle. The agency notes that this creates a double negative capable of making it unclear whether the consumer should turn the switch on or off to prohibit a sale.
LG managed to implement an interface pattern close enough to the FTC’s hypothetical warning that privacy guides need to explain how the button works.
That is pathetic design for something this important.
Technical Availability Is Not the Same as Meaningful Choice
This is the point corporations conveniently blur.
Suppose an LG lawyer can prove that every necessary setting existed somewhere.
That is not the same as proving the system respected consumers.
A privacy right hidden five menus deep is legally available and practically weakened.
A disclosure written in technically accurate but opaque language is available and still poorly understood.
A one-click opt-in paired with a 40-click opt-out preserves choice while engineering the choice asymmetrically.
A double-negative privacy toggle technically works while predictably confusing people.
This is why the FTC says companies should make privacy choices easy to find and understand, avoid ambiguous toggles, and avoid requiring consumers to navigate multiple screens to locate privacy settings.
Those principles are not complicated.
A company either wants the consumer to make an informed decision or it wants the consumer to successfully navigate a compliance obstacle course.
Those are different goals.
The Markup Found the Same Basic Problem Before Texas Sued
Texas was not the first organization to notice how cumbersome Smart TV privacy controls could become.
In 2023, The Markup published a practical guide to disabling ACR on major Smart TV platforms. On the LG television it tested, the publication counted 27 clicks to disable LG’s Live Plus ACR functionality and documented separate menu paths for home promotions, content recommendations, ad tracking, and third-party data-sharing controls.
That detail is important because it shows what “choice” feels like in practice.
A company can tell consumers they are free to disable tracking.
A journalist then has to publish a step-by-step manual explaining how to actually do it.
If privacy requires a tutorial, the product has already failed a basic usability test.
Read The Markup’s Smart TV privacy guide
LG’s Advertising Business Makes the Interface Choices More Serious
Bad UX around a harmless setting is annoying.
Bad UX around a setting that affects commercially valuable data is different.
LG Ad Solutions openly markets ACR-derived viewing behavior to advertisers. LG says that, depending on user consent and market, ACR-related information may support audience segmentation, trend analysis, interest-based advertising, and cross-device advertising. LG also says some uses may legally count as a sale or sharing of personal information in certain jurisdictions.
That gives LG an obvious commercial interest in the outcome of privacy decisions.
This does not by itself prove that a particular designer intentionally made a particular setting confusing.
It does mean we should stop pretending privacy UX is economically neutral.
When one choice enables commercially useful information and another restricts it, the design of the choice matters.
A lot.
Texas Eventually Forced the Issue
The dispute did not end with LG successfully arguing that the settings technically existed.
In May 2026, Texas announced a settlement under which LG agreed not to collect ACR viewing information without informed consent. LG also agreed to provide a pop-up explaining how viewing data may be collected and used and to provide a clear and simple way to opt out.
Those are telling requirements.
Informed.
Clear.
Simple.
That is what privacy controls should have been all along.
The settlement does not mean every factual allegation in Texas’s lawsuit was adjudicated and proven in court. But the practical result is undeniable: after Texas challenged LG’s privacy architecture, LG agreed to improve disclosure and the opt-out experience.
Read the Texas-LG privacy settlement announcement
LG’s Current System Is Better. That Does Not Rewrite the History.
LG now says optional ACR, voice recognition, and interest-based advertising are off by default and require separate agreements. It says consumers can withdraw consent through TV settings without losing core Smart TV functionality such as streaming apps, HDMI use, live television, and software updates.
Those changes are worth recognizing.
Current buyers should know that the privacy picture is not frozen in 2023 or 2025.
But improvements after criticism do not make the criticism disappear.
The historical lesson remains important because it shows how easily companies can turn the legal language of consent into something much less meaningful in practice.
LG gave people settings.
Texas argued that LG simultaneously made the settings confusing, fragmented, inconvenient, and poorly timed.
Both things can be true.
Consent Should Not Be a Puzzle
The correct standard is simple.
If LG wants to analyze what is being watched, ask plainly.
If LG wants to use the information for advertising, ask separately.
If LG wants to link behavior across devices, say exactly that.
If the user wants everything off, give them one button.
If the user changes their mind, make withdrawing permission as easy as granting it.
Do not hide the setting.
Do not reverse the logic.
Do not force people through 40 clicks.
Do not frighten them with vague warnings unless functionality genuinely requires it, and then explain exactly what will stop working.
This is not an impossible privacy regime.
It is simply one that treats the customer’s decision as something to respect rather than something to optimize around.
LG Turned Consent Into Interface Work
The ugly genius of dark patterns is that corporations can preserve the appearance of freedom.
Nobody forced you.
The setting was there.
You could have opted out.
You could have read the agreement.
You could have found the right menu.
You could have understood the double negative.
You could have clicked through everything.
That is not meaningful consumer empowerment.
That is a company handing you homework and calling the existence of the homework freedom.
Privacy rights should not depend on whether somebody is stubborn enough to beat the interface.
And that is why the LG story matters beyond televisions.
When corporations turn privacy into a game of find the right setting, they have already made the wrong choice about whose interests the interface is supposed to serve.
References
State of Texas v. LG Electronics U.S.A., Inc., Original Verified Petition, December 2025. Texas’s complaint documents the initial consent screen, six agreements, Select All option, buried privacy settings, withdrawal warning, alleged 40-plus-click opt-out process, and dark-pattern allegations.
Read Texas’s complaint against LG
Texas Office of the Attorney General, May 11, 2026. The settlement requires informed consent for ACR viewing-data collection, clearer disclosure, and a clear and simple opt-out.
Read the Texas-LG privacy agreement
Federal Trade Commission, Bringing Dark Patterns to Light, September 2022. The FTC discusses buried privacy choices, confusing toggles, difficult cancellation and opt-outs, and interfaces that steer users toward greater collection. Its report specifically warns about the confusing double negative created by an off toggle next to a Do Not Sell setting.
Read the FTC dark-pattern report
Consumer Reports, How to Turn Off Smart TV Snooping Features. Current instructions for LG webOS privacy controls, including Viewing Information, advertising agreements, and activating Do Not Sell My Personal Information.
Read Consumer Reports’ Smart TV privacy guide
The Markup, Your Smart TV Knows What You’re Watching, December 2023. The Markup documented the practical number of interactions involved in disabling LG Live Plus and other advertising/privacy controls on the television it tested.
Read The Markup’s investigation and opt-out guide
LG Electronics, Understanding Privacy on LG Smart TVs, September 12, 2026. LG’s current description of its opt-in model, optional ACR and advertising agreements, withdrawal controls, and current privacy commitments.
Read LG’s current Smart TV privacy statement