Here’s a link to the Federal Trade Commission comment I wrote which was jointly submitted to the FTC by the Cyber Civil Rights Initiative, Inc. and Without My Consent, Inc.

It relates to The Matter of Craig Brittain.  Brittain operated the now defunct revenge porn site IsAnybodyDown.com. The FTC accused him of engaging in false and deceptive business practices for tricking women into giving him nudes and for general operation of a business that peddled in nonconsensual pornography.

The gist:  FTC was right to bust this shitbag revenge porn operator for his false and deceptive biz practices, but it sucks that the proceeding has no real deterrent power on other sites.  After all, they’re still up and running.  Thus, Congress should give the FTC power to fine companies for this kind of thing.  Also, the FTC should take advantage of the seldomly used rulemaking power it does have to promulgate new privacy rules so that through litigation we can build some precedent.

Lots of elbow grease from Mary Anne Franks and terrific input from Colette Vogele, Danielle Citron, and Holly Jacobs. Thanks to the marvelous Woody Hartzog for letting us exploit his big brains.

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