Comment from Center for AI and Digital Policy (CAIDP)

Summary: The Center for AI and Digital Policy (CAIDP) argues that the Proposed Consent Order is insufficient because it only addresses deceptive advertising rather than the underlying unfair practice of commercial surveillance. They urge the FTC to strengthen the order by prohibiting the sale of surveillance products, broadening the definition of "voice data," requiring algorithmic disgorgement, and implementing robust governance programs including independent audits and privacy-enhancing technologies.