In the Matter of Turn, Inc., File No. 1523099 #3

Submission Number:
A Noe
Initiative Name:
In the Matter of Turn, Inc., File No. 1523099
Thank you for addressing this issue, but it concerns me that the only "punishment" that is included is the requirement that the company quit violating people's privacy. The message sent, in that case, is quite simple: "You can behave like this until we catch you." Essentially, there's is no incentive for such companies to worry about people's privacy until they are caught violating it. Inasmuch as everyone involved here understands that you cannot catch every instance of such behavior at every company, there should be a significant deterrent and a fair amount of fear that's associated with knowingly violating the privacy of consumers. I don't see any of that in this proposed resolution, and would, therefore object to its consummation. Moreover, while your release ( did provide a link to the "proposed FTC consent order", there was no such reference to the "draft Complaint" referred to in the proposed consent order. This type of key omission undermines the ability of the public to intelligently assess the context of the situation. And coupled with the agency's willingness to agree to allow companies to "neither admit nor denies any of the allegations in the Complaint" it reflects poorly on the agency's willingness to implement the law, eroding the public's already diminished confidence in your agency - and more widely the government. Remember, your fiduciary responsibility is to the consumer - not the companies that use sophisticated processes to take advantage of them.