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 illegal surveillance practices of 1010 Digital. They urge the FTC to strengthen the order by prohibiting the company's surveillance products, broadening the definition of "voice data," requiring affirmative consent and data deletion, and mandating algorithmic disgorgement and governance programs.