Comment from Receipt House LLC

Dear Members of the Commission: I'm the founder of ReceiptHouse, a consumer safety platform live today at receipthouse.ai. The idea is simple: a person photographs something they own, or saves a receipt, and we identify the product, keep a record of it for them, and watch the federal recall databases — CPSC, NHTSA, FDA, USDA FSIS — and class action filings on their behalf. If something they own is recalled, they're notified in real time. Our service SafetyHalo monitors recalls across the stores, brands, items a person owns, and their receipts. These comments respond to Section III.4, on actions the Commission could take to reduce recall fraud. We believe the most durable step is to help consumers build a record of what they own before a recall happens. The federal government has done something similar before, and it worked. A precedent: helping people hold their own records Fifteen years ago, most people couldn't easily get a copy of their own medical records. In 2010 the government launched Blue Button, which let veterans and Medicare beneficiaries download their own health records. It forced no one. The government set a simple standard, opened its own data, and invited hospitals, pharmacies, and insurers to take part. Hundreds of organizations signed a voluntary pledge to give patients that access. Blue Button later became an open API connecting Medicare's 60-plus million beneficiaries to apps they trust. A parallel effort, Green Button, was designed to do the same for energy-usage data. Today, managing your own records in a portal like MyChart is normal. It started because the government decided consumers should hold their own records, then let the private sector build around that idea. Product ownership is roughly where health records were in 2009. There is no single, consumer-held record of what a person buys and owns — and that gap is a large part of what makes recall fraud possible. Why a consumer-held purchase record is a fraud control The RFI describes fraud built on fabricated proof — altered or AI-generated images, claims for more units than someone could own, organized schemes. Almost all of it depends on manufacturing evidence after a recall is announced. A purchase record created before a recall breaks that. A receipt and product photo saved months earlier, tied to a real person and a real transaction, can't be faked in response to a recall that hadn't happened yet. If a claim can be checked against such a record, the obvious fraud — a claim with no purchase behind it, or a claim for fifty units from someone who bought one — gets caught and tracked instead of paid. The exact verification method is an implementation detail. The principle is what matters: when a consumer already holds a verified purchase record, a recall claim becomes something an administrator can check against reality rather than take on faith. ReceiptHouse does this on the consumer side today. A retailer can also load purchase history into the platform with the customer's consent, and a manufacturer can capture product, model, and serial information at purchase. The record can come from the consumer, the retailer, or the manufacturer. What the Commission could do Blue Button worked not because the government built the best app, but because it set a standard, opened its data, and made it easy and respectable for others to participate. A consumer purchase record reaches full value only if retailers participate broadly — just as Blue Button only worked once providers and insurers joined. No single company gets there alone. That is the natural federal role: convening retailers, manufacturers, and platforms; encouraging a consumer-controlled standard for ownership records; and signaling that participation is expected, as the Blue Button pledge did. The Commission wouldn't be picking a winner or building a product — just setting a direction the market fills in. ReceiptHouse is one working example, live today, but the value is in the standard, not any single platform. Adoption largely solves itself: photo-based registration, recall monitoring, receipt capture, and search across everything you own are useful on their own terms. The fraud-prevention benefit follows from giving consumers something they value. One caution A record like this should make claims easier to verify, not become a barrier to the remedy. A consumer who never registered should still be able to file a claim the normal way. The value is a higher-confidence signal on claims that do have a record behind them — not shutting out those who don't. As one layer among several, it strengthens recall integrity without raising the barrier the Commission is rightly concerned about. Thank you for the opportunity to comment. I'd welcome the chance to share more or to take part in further work on this. Respectfully, Perry Somers Founder, ReceiptHouse receipthouse.ai | receipthouse.ai/safetyhalo