In the Matter of Snapchat, Inc #00008

Submission Number:
David McGuire
Novustep LLC
Initiative Name:
In the Matter of Snapchat, Inc
Matter Number:

132 3078

As both a Consumer and an independent Security & Privacy Consultant I am dismayed to see this consent order proposed without any financial penalty, fine, or FTC cost recovery without future violations by the offending company. I am tired, professionally, of seeing bad corporate actors scoff and walk away from these types of material violations of consumer trust. While I applaud the 20 year review and monitoring requirements, if violations of this nature do not require the entity to write a sizable check to finalize these types of consent orders then they are simply much less effective than I, as an American Consumer, demand. The violations in this specific case are egregious, and should warrant an immediate commenssurate financial fine and case cost recovery. I've simply worked with too many executives who see this type of "penalty" as a minor inconvenience versus a catalyst that will bring a sincere change of corporate behavior. As a tax payer I object to the costs of these types of regulatory investigations not being born by the offender immediately. Again, while I applaud the increase in enforcement action being taken by the FTC in these types of cases more recently, I simply see Snapchat as getting off way to easy in this case, and would doubt this action will create much angst in their C-suite.