In comments submitted to the Federal Trade Commission (FTC), CFA, the Electronic Privacy Information Center, Center for Digital Democracy, and U.S. Public Interest Research Group explain why privacy is critical to the FTC’s mission of promoting competition. Over the past twenty years, the growing concentration among the dominant technology firms in the United States has eroded consumer privacy and stifled innovation. The FTC’s failure to protect privacy in its merger review process has contributed greatly to the decline in competition among the digital platforms in the US. The dominant digital platforms regularly abuse their access to consumer data to undermine competitors and hinder the development of innovative, privacy-enhancing technologies. Placing meaningful limits on the dominant firms’ data collection practices can level the playing field and allow new, innovative products to enter the market, benefiting consumers and the American economy.
