Comment from International Partners for Ethical Care

Dear Commissioners: Partners for Ethical Care is an organization of parents and professionals concerned about the effects of the gender industry on children and mentally vulnerable adults. Many of us have close family members who identify, or once identified, as transgender, and our concern is rooted in love, experience, and a desire to protect vulnerable people from harm. Partners for Ethical Care also runs the Transition Justice project, which assists detransitioners harmed by unethical medical providers. We rely on platforms like X to share information, connect families, support whistleblowers and detransitioners, and alert the public to practices that too often occur behind institutional walls. Our ability to speak freely online is essential because our message is often mischaracterized by those who want to silence it. Posts raising concerns about minors, autism, mental-health vulnerability, medical ethics, informed consent, detransition, and regret are frequently reported or removed on the theory that our mission is “hateful” or “transphobic.” Nothing could be further from the truth. We are speaking because we care deeply about children, families, and vulnerable people. But when platforms suppress discussion of what happens to those who “transition,” or punish parents and professionals for questioning powerful medical and ideological institutions, the public loses access to information it urgently needs. For that reason, we applaud the Commission’s recent attention to deceptive claims in the gender-medicine industry, including its lawsuit against the World Professional Association for Transgender Health. That action reflects an important principle: Consumer protection should expose false, misleading, or unsubstantiated claims that place children and families at risk. Granting X Corp.’s petition would advance the same principle from another direction. The public cannot be protected from deceptive or harmful practices if the people with firsthand knowledge—parents, clinicians, whistleblowers, and detransitioners—are unable to speak freely on the platforms where public debate now occurs. That is why X Corp.’s petition matters to us. A federal agency should not be able to use an old consent decree as leverage over one of the few major platforms where contested views can still reach the public. The danger is not limited to X as a company. It extends to every speaker who depends on X to challenge a dominant narrative. If government pressure, regulatory demands, or fear of agency retaliation causes a platform to restrict lawful speech about gender medicine, detransition, parental rights, or the treatment of vulnerable adults, then the public square becomes less honest and less safe. The FTC’s authority exists to protect consumers, not to influence which viewpoints may be heard online. A consent decree directed at privacy and security concerns should not become a tool for scrutinizing speech policies or encouraging censorship of unpopular speakers. In our experience, accusations of “misinformation,” “hate,” and “harm” are often used to shut down discussion before families ever have the chance to hear from detransitioners, clinicians, parents, and others with firsthand knowledge. Government should not add its weight to that imbalance. The Commission has an opportunity in this proceeding to reaffirm a simple principle: Federal enforcement power must not be weaponized against lawful speech. Consent orders should be limited, remedial, and tied to concrete consumer-protection concerns. They should not become open-ended supervision regimes that allow regulators to exert influence over platforms where Americans discuss the most consequential issues of the day. Partners for Ethical Care respectfully urges the Commission to grant X Corp.’s petition, or at minimum to reopen and substantially modify the order, so that any continuing obligations are narrowly tailored to legitimate consumer-protection purposes and cannot be used to silence those who speak for children, families, and vulnerable adults. Respectfully submitted, Partners for Ethical Care