> First, according to the FTC, MoviePass’s operators invalidated subscriber passwords while falsely claiming to have detected “suspicious activity or potential fraud” on the accounts. MoviePass's operators did this even though some of its own executives raised questions about the scheme, according to the complaint.

I'm going to go out on a limb and say the only reason the FTC was able to establish intent was because someone complained via email or text.

I try not to think about how much illegal activity like this happens all the time that is not prosecutable just because everyone with a modicum of morals was smart enough not to say anything on record.