Proposed Consent Agreement In the Matter of Atlanta Falcons Football Club, LLC. #00002

Submission Number:
00002
Commenter:
Chris Connolly
State:
Outside the United States
Initiative Name:
Proposed Consent Agreement In the Matter of Atlanta Falcons Football Club, LLC.
Matter Number:

142-3018

[For privacy reasons, please do not display my postal code. UK postal codes identify the actual house]. Dear FTC enforcement team, I welcome the action you have taken regarding the false claim of Safe Harbor membership by the Atlanta Falcons. While I support the overall direction of the draft consent order, I query whether the Atlanta Falcons were previously the subject of any warnings or action by the FTC or the Department of Commerce in relation to this same issue in either 2008 or 2009. If so, then this could be treated as a second or ongoing offence, and the sanctions could be strengthened. I also recommend that the FTC considers appropriate action in relation to TRUSTe, as the Atlantic Falcons were a verified member of one or more TRUSTe programs, including the TRUSTe EU Safe Harbor program, during the lengthy period when the false claim was being made. TRUSTe purports to conduct an annual re-certification, so their decision to re-certify the Atlanta Falcons in their EU specific program should be investigated. As you know, TRUSTe has been on notice regarding false claims of this type since 2008.