ICLE on Commercial Surveillance ANPR
American Action Forum – An International Center for Law & Economics paper was cited in comments submitted by the American Action Forum regarding the Federal Trade Commission’s advance notice of proposed rulemaking on commercial surveillance. You can read full comments here.
Even then, the Commission will need to show that specific data security practices will likely lead to significant harms to consumers. As the International Center for Law and Economics highlights, the FTC’s enforcement actions regarding data security often lack the economic analysis that would show harms to consumers.