tl;dr: prefer using phrase “manipulative design” instead of “harmful patterns” as a replacement for “dark patterns”.
Also adding thanks to https://GitHub.com/LeaVerou, and agreed with the reasoning in https://www.ccianet.org/wp-content/uploads/2021/06/2021-05-28-CCIA-Comments-on-FTC-Dark-Patterns-Workshop.pdf (since this issue was filed!) particularly from an inclusiveness perspective, “[avoiding] connection of “dark-light dualism” to judgments about morality”.
And as https://GitHub.com/harrybr is quoted: “during the Workshop by Professor Harry Brignull, while the term “dark pattern” (originated and popularized in part by Brignull) has been useful for marketing and raising awareness, it would be both “vague and sloppy” if used as a legal term or standard.”
That being said, “harmful patterns” is vague and dilutes the intent of this issue.
It’s also not strictly accurate from the perspective of a company implementing such patterns, from their (typically attention/growth/profit-maximizing) perspective, such patterns are helpful to them personally, their shareholders/investors if any, and not harmful.
Such patterns are also too easy for such companies to hide behind a vague "intent" of supposedly "helping" people connect (quiet importing of contacts, suggesting joining radicalizing groups), or "helping" people get products they want/"need" (deceptive marketing, creating fear/insecurity in people’s minds then selling them a product to cope), etc.
More precise (and preserving of intent, meaning, and literal effect) would be the phrase “manipulative design”, also used & recommended by that ccianet workshop (same link): “Rather than employ the terminology of “dark patterns,” these comments will refer to “manipulative design” practices or interfaces”.