Correct, and indeed, this business model is nothing new or unusual in the EU in general, or in Germany in particular. Back in the early, pre-smartphone days of mobile, a lot of European companies made fortunes by selling ringtones through a misleading subscription model similar to JustFab's. Their success soon led to a lot of imitators in the US market.

Remember those "Text 53646 to this number to get your NSync ringtone!!!" ads that used to blanket the airwaves? Texting that number got you your ringtone; it also got you $20/month in recurring fees that you were unaware of, because you were a kid, and kids usually don't read their own bills.

There may be nothing technically "illegal" about this dark pattern in the US, but the pattern is pretty fucking dark. And it's usually self-defeating in the long run. Many of the fly-by-night ringtone peddlers of the early 2000s had to flee one country after the next, always on the hunt for new suckers in new territories, always getting chased out of town by an angry mob of pissed-off customers.

This model is not sustainable. Though it's not a pyramid scheme, it shares a similar need for a fresh supply of new victims at a rate fast enough to make up for churn. Churn starts to reach critical mass at some point, forcing the company to expand into a new country altogether.

Then again, sometimes the model just works. Look at GoDaddy. As far as I can tell, they make a shit-ton of money by making it as hard as humanly possible to break subscriptions and hidden upsells, and sadly, they're still around.