Comment from Lemonada Labs, LLC
Lemonada Labs, LLCSupportBusiness
Summary: Lemonada Labs, a technology company, proposes a two-stage, risk-based verification architecture to combat consumer product recall fraud. They argue that the Commission should move away from universal documentation requirements toward a system that uses automated fraud signal screening and "live capture" technology to verify physical possession of products.
During the Takata airbag recall, we learned that records tell you what was registered. They cannot tell you where something is today, or who actually has it. We answered that question for vehicles by finding them in the real world using technology.
Recall fraud on the consumer product side exploits the same blind spot: there is no reliable way to confirm at claim time whether a claimant physically possesses the recalled product. This comment proposes a two-stage verification architecture that closes that gap directly, invisibly for legitimate consumers. We welcome the opportunity to discuss further.