Everalbum, Inc.; Analysis of Proposed Consent Order To Aid Public Comment, 6888-6891 [2021-01430]
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Federal Register / Vol. 86, No. 14 / Monday, January 25, 2021 / Notices
K. Coordination with State Regulatory
Authorities
In the event that a material
supervisory determination subject to a
request for review is the joint product of
the FDIC and a State regulatory
authority, the Director, DCP, the
Director, RMS, or the Director, CISR, as
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Any application or request for
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Director, Office of the Ombudsman,
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Proposed consent agreement;
request for comment.
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair or
deceptive acts or practices. The attached
Analysis of Proposed Consent Order to
Aid Public Comment describes both the
allegations in the draft complaint and
the terms of the consent order—
embodied in the consent agreement—
that would settle these allegations.
Federal Deposit Insurance Corporation.
DATES: Comments must be received on
By order of the Board of Directors.
or before February 24, 2021.
Dated at Washington, DC, on January 19,
ADDRESSES: Interested parties may file
2021.
comments online or on paper by
James P. Sheesley,
following the instructions in the
Assistant Executive Secretary.
Request for Comment part of the
[FR Doc. 2021–01547 Filed 1–22–21; 8:45 am]
SUPPLEMENTARY INFORMATION section
BILLING CODE 6714–01–P
below. Please write ‘‘Everalbum, Inc.;
File No. 192 3172’’ on your comment,
and file your comment online at https://
www.regulations.gov by following the
FEDERAL ELECTION COMMISSION
instructions on the web-based form. If
you prefer to file your comment on
Sunshine Act Meeting
paper, mail your comment to the
TIME AND DATE: Thursday, January 28,
following address: Federal Trade
2021 at 10:00 a.m.
Commission, Office of the Secretary,
PLACE: Virtual meeting. Note: Because of 600 Pennsylvania Avenue NW, Suite
CC–5610 (Annex D), Washington, DC
the covid–19 pandemic, we will
20580, or deliver your comment to the
conduct the open meeting virtually. If
following address: Federal Trade
you would like to access the meeting,
Commission, Office of the Secretary,
see the instructions below.
STATUS: This meeting will be open to the Constitution Center, 400 7th Street SW,
5th Floor, Suite 5610 (Annex D),
public. to access the virtual meeting, go
Washington, DC 20024.
to the commission’s website
FOR FURTHER INFORMATION CONTACT:
www.fec.gov and click on the banner to
James Trilling (202–326–3497), Bureau
be taken to the meeting page.
of Consumer Protection, Federal Trade
MATTERS TO BE CONSIDERED:
Commission, 600 Pennsylvania Avenue
Draft Advisory Opinion 2020–06:
NW, Washington, DC 20580.
Escobar
SUPPLEMENTARY INFORMATION: Pursuant
Audit Division Recommendation
to Section 6(f) of the Federal Trade
Memorandum on the Mississippi
Commission Act, 15 U.S.C. 46(f), and
Republican Party (A17–15)
FTC Rule 2.34, 16 CFR 2.34, notice is
Management and Administrative
hereby given that the above-captioned
Matters
consent agreement containing a consent
CONTACT PERSON FOR MORE INFORMATION:
Judith Ingram, Press Officer; Telephone: order to cease and desist, having been
filed with and accepted, subject to final
(202) 694–1220.
approval, by the Commission, has been
Authority: Government in the Sunshine
placed on the public record for a period
Act, 5 U.S.C. 552b.
of thirty (30) days. The following
Analysis to Aid Public Comment
Laura E. Sinram,
describes the terms of the consent
Acting Secretary and Clerk of the
agreement and the allegations in the
Commission.
complaint. An electronic copy of the
[FR Doc. 2021–01594 Filed 1–21–21; 11:15 am]
full text of the consent agreement
BILLING CODE 6715–01–P
package can be obtained at https://
www.ftc.gov/news-events/commissionactions.
FEDERAL TRADE COMMISSION
You can file a comment online or on
paper. For the Commission to consider
[File No. 192 3172]
your comment, we must receive it on or
Everalbum, Inc.; Analysis of Proposed before February 24, 2021. Write
Consent Order To Aid Public Comment ‘‘Everalbum, Inc.; File No. 192 3172’’ on
your comment. Your comment—
including your name and your state—
AGENCY: Federal Trade Commission.
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SUMMARY:
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Federal Register / Vol. 86, No. 14 / Monday, January 25, 2021 / Notices
will be placed on the public record of
this proceeding, including, to the extent
practicable, on the https://
www.regulations.gov website.
Due to the COVID–19 pandemic and
the agency’s heightened security
screening, postal mail addressed to the
Commission will be subject to delay. We
strongly encourage you to submit your
comments online through the https://
www.regulations.gov website.
If you prefer to file your comment on
paper, write ‘‘Everalbum, Inc.; File No.
192 3172’’ on your comment and on the
envelope, and mail your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
600 Pennsylvania Avenue NW, Suite
CC–5610 (Annex D), Washington, DC
20580; or deliver your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
Constitution Center, 400 7th Street SW,
5th Floor, Suite 5610 (Annex D),
Washington, DC 20024. If possible,
submit your paper comment to the
Commission by courier or overnight
service.
Because your comment will be placed
on the publicly accessible website at
https://www.regulations.gov, you are
solely responsible for making sure your
comment does not include any sensitive
or confidential information. In
particular, your comment should not
include sensitive personal information,
such as your or anyone else’s Social
Security number; date of birth; driver’s
license number or other state
identification number, or foreign
country equivalent; passport number;
financial account number; or credit or
debit card number. You are also solely
responsible for making sure your
comment does not include sensitive
health information, such as medical
records or other individually
identifiable health information. In
addition, your comment should not
include any ‘‘trade secret or any
commercial or financial information
which . . . is privileged or
confidential’’—as provided by Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and
FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2)—
including in particular competitively
sensitive information such as costs,
sales statistics, inventories, formulas,
patterns, devices, manufacturing
processes, or customer names.
Comments containing material for
which confidential treatment is
requested must be filed in paper form,
must be clearly labeled ‘‘Confidential,’’
and must comply with FTC Rule 4.9(c).
In particular, the written request for
confidential treatment that accompanies
the comment must include the factual
and legal basis for the request, and must
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identify the specific portions of the
comment to be withheld from the public
record. See FTC Rule 4.9(c). Your
comment will be kept confidential only
if the General Counsel grants your
request in accordance with the law and
the public interest. Once your comment
has been posted on the https://
www.regulations.gov website—as legally
required by FTC Rule 4.9(b)—we cannot
redact or remove your comment from
that website, unless you submit a
confidentiality request that meets the
requirements for such treatment under
FTC Rule 4.9(c), and the General
Counsel grants that request.
Visit the FTC website at https://
www.ftc.gov to read this Notice and the
news release describing the proposed
settlement. The FTC Act and other laws
that the Commission administers permit
the collection of public comments to
consider and use in this proceeding, as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before February 24, 2021. For
information on the Commission’s
privacy policy, including routine uses
permitted by the Privacy Act, see
https://www.ftc.gov/site-information/
privacy-policy.
Analysis of Proposed Consent Order To
Aid Public Comment
The Federal Trade Commission
(‘‘Commission’’ or ‘‘FTC’’) has accepted,
subject to final approval, an agreement
containing a consent order from
Everalbum, Inc., also doing business as
Ever and Paravision (‘‘Everalbum’’ or
‘‘Respondent’’). The proposed consent
order (‘‘proposed order’’) has been
placed on the public record for thirty
(30) days for receipt of comments from
interested persons. Comments received
during this period will become part of
the public record. After thirty (30) days,
the Commission again will review the
agreement and the comments received,
and will decide whether it should
withdraw from the agreement or make
final the agreement’s proposed order.
Since 2015, Everalbum has operated
‘‘Ever,’’ a photo storage and organization
application available as an iOS or
Android mobile application (‘‘app’’) and
in web and desktop formats. Ever allows
consumers to upload photos and videos
(collectively, ‘‘content’’) from mobile
devices, computers, or social media or
cloud-based storage service accounts to
Ever’s cloud servers. In February 2017,
Everalbum launched a new feature of
the Ever mobile app, called ‘‘Friends.’’
The Friends feature uses face
recognition to organize users’ photos by
faces of the people who appear in them.
When Everalbum launched the Friends
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feature, it enabled face recognition by
default for all users of the Ever mobile
app.
Everalbum’s application of face
recognition to Ever app users’ content
has not been limited to providing the
Friends feature. The Commission’s
proposed complaint alleges that, in four
instances, Everalbum used images it
extracted from Ever users’ photos in the
development of face recognition
technology. In one such instance,
Everalbum used the resulting face
recognition technology both in the Ever
app and to build the face recognition
services offered by its enterprise brand,
Paravision (formerly Ever AI).
The proposed two-count complaint
alleges that Everalbum violated Section
5(a) of the FTC Act by misrepresenting
the company’s practices with respect to
Ever users’ content.
Proposed complaint Count I alleges
that Everalbum misrepresented the
circumstances under which the
company would apply face recognition
to Ever users’ content. According to the
proposed complaint, Everalbum
published a help article entitled ‘‘What
is Face Recognition?’’ on its website in
July 2018. The proposed complaint
alleges that the help article represented
that the Ever app’s ‘‘Friends’’ feature
was not active—and, therefore, that
Everalbum would not apply face
recognition technology to users’
content—unless users affirmatively
enabled the feature. The proposed
complaint further alleges that the help
article was false or misleading, because,
until April 2019, for users in most
geographic locations, Everalbum
applied face recognition to users’
content by default and users could not
use an app setting to turn off face
recognition.
Proposed complaint Count II alleges
that Everalbum misrepresented that the
company would delete the content of
Ever users who chose to deactivate their
Ever accounts. According to the
proposed complaint, when Ever users
sought to deactivate their accounts,
Everalbum presented them with pop-up
messages that represented that account
deactivation would result in Everalbum
deleting their content. The proposed
complaint alleges that Everalbum also
made a similar representation in
response to consumer inquiries and in
its privacy policy. Despite its
representations, Everalbum allegedly
did not delete any users’ content upon
account deactivation and instead stored
the content indefinitely.
The proposed order contains
provisions to address Respondent’s
conduct and prevent it from engaging in
the same or similar acts or practices in
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Federal Register / Vol. 86, No. 14 / Monday, January 25, 2021 / Notices
the future. Provision I of the proposed
order prohibits Respondent from
making misrepresentations related to
the collection, use, disclosure,
maintenance, or deletion of Covered
Information (as defined in the order);
consumers’ ability to control any of
these actions; the extent to which
Everalbum accesses or permits access to
Covered Information; the extent,
purpose, and duration of Everalbum’s
retention of Covered Information after
consumers deactivate their accounts; or
the extent to which Everalbum
otherwise protects the privacy, security,
availability, confidentiality, or integrity
of any Covered Information.
Part II of the proposed order requires
Respondent to clearly and
conspicuously disclose, and obtain
consumers’ affirmative express consent
for, all purposes for which it will use or
share User’s Biometric Information
before using the information to create
data needed for face recognition
analysis or to develop face recognition
models or algorithms.
Part III of the proposed order requires
Respondent to delete (A) photos and
videos of Ever app Users who requested
deactivation of their accounts, (B) face
recognition data that it created without
obtaining Users’ affirmative express
consent, and (C) models and algorithms
it developed in whole or in part using
images from Users’ photos.
Parts IV through VII of the proposed
order are reporting and compliance
provisions, which include
recordkeeping requirements and
provisions requiring Respondent to
provide information or documents
necessary for the Commission to
monitor compliance. Part VIII of the
proposed order states that the order will
remain in effect for 20 years, with
certain exceptions.
The purpose of this analysis is to aid
public comment on the proposed order.
It is not intended to constitute an
official interpretation of the complaint
or proposed order, or to modify in any
way the proposed order’s terms.
By direction of the Commission.
April J. Tabor,
Acting Secretary.
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Statement of Commissioner Rohit
Chopra in the Matter of Everalbum, Inc.
Today’s facial recognition technology
is fundamentally flawed and reinforces
harmful biases. I support efforts to enact
moratoria or otherwise severely restrict
its use. Until such time, it is critical that
the FTC meaningfully enforce existing
law to deprive wrongdoers of
technologies they build through
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unlawful collection of Americans’ facial
images and likenesses.
The case of Everalbum is a troubling
illustration of just some of the problems
with facial recognition. Everalbum
operates a business line called
Paravision, which developed and
marketed facial recognition technology,
including to clients in the security and
air travel industries.1 The company
enhanced their facial recognition
technology by allegedly baiting
consumers into using Ever, a ‘‘free’’ app
that allowed users to store and modify
photos.2
As outlined in the complaint,
Everalbum made promises that users
could choose not to have facial
recognition technology applied to their
images, and that users could delete the
images and their account. In addition to
those promises, Everalbum had clear
evidence that many of the photo app’s
users did not want to be roped into
facial recognition. The company broke
its promises, which constitutes illegal
deception according to the FTC’s
complaint. This matter and the FTC’s
proposed resolution are noteworthy for
several reasons.
First, the FTC’s proposed order
requires Everalbum to forfeit the fruits
of its deception. Specifically, the
company must delete the facial
recognition technologies enhanced by
any improperly obtained photos.
Commissioners have previously voted to
allow data protection law violators to
retain algorithms and technologies that
derive much of their value from illgotten data.3 This is an important course
correction.
1 Paravision, https://www.paravision.ai/ (last
visited on Jan. 4, 2020).
2 Compl., In the Matter of Everalbum, Inc.,
Comm’n File No. 1923172. This is not the only
photo-sharing application that has drawn scrutiny
for its ties to facial recognition and surveillance
technology. Kashmir Hill & Aaron Krolik, How
Photos of Your Kids Are Powering Surveillance
Technology, N.Y. Times (Oct. 11, 2019), https://
www.nytimes.com/interactive/2019/10/11/
technology/flickr-facial-recognition.html.
3 The Commission voted 3–2 on a settlement with
Google and YouTube that allowed the companies to
retain algorithms and other technologies enhanced
by illegally obtained data on children. Based on my
analysis, the Commission also allowed Google and
YouTube to profit from their conduct, even after
paying a civil penalty. See Dissenting Statement of
Commissioner Rohit Chopra In the Matter of Google
LLC and YouTube, LLC, Comm’n File No. 1723083
(Sep. 4, 2019), https://www.ftc.gov/publicstatements/2019/09/statement-commissioner-rohitchopra-regarding-youtube. The Commission voted
3–2 on a settlement with Facebook to address
unlawful facial recognition practices that violated a
2012 Commission order. Like the Google/YouTube
settlement, Facebook was not required to forfeit any
facial recognition or other related technologies. The
settlement also provided an unusual immunity
clause for senior executives, including Mark
Zuckerberg and Sheryl Sandberg. See also
Dissenting Statement of Commissioner Rohit
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Second, the settlement does not
require the defendant to pay any
penalty. This is unfortunate. To avoid
this in the future, the FTC needs to take
further steps to trigger penalties,
damages, and other relief for facial
recognition and data protection abuses.
Commissioners have voted to enter into
scores of settlements that address
deceptive practices regarding the
collection, use, and sharing of personal
data. There does not appear to be any
meaningful dispute that these practices
are illegal. However, since
Commissioners have not restated this
precedent into a rule under Section 18
of the FTC Act, we are unable to seek
penalties and other relief for even the
most egregious offenses when we first
discover them.4
Finally, the Everalbum matter makes
it clear why it is important to maintain
states’ authority to protect personal
data. Because the people of Illinois,
Washington, and Texas passed laws
related to facial recognition and
biometric identifiers, Everalbum took
greater care when it came to individuals
in these states.5 The company’s
deception targeted Americans who live
in states with no specific state law
protections.
With the tsunami of data being
collected on individuals, we need all
hands on deck to keep these companies
in check. State and local governments
have rightfully taken steps to enact
bans, moratoria, and other restrictions
on the use of these technologies. While
special interests are actively lobbying
for federal legislation to delete state data
protection laws, it will be important for
Congress to resist these efforts. Broad
federal preemption would severely
undercut this multi-front approach and
leave more consumers less protected.
It will be critical for the Commission,
the states, and regulators around the
globe to pursue additional enforcement
actions to hold accountable providers of
facial recognition technology who make
Chopra In re Facebook, Inc., Comm’n File No.
1823109 (Jul. 24, 2019), https://www.ftc.gov/publicstatements/2019/07/dissenting-statementcommissioner-rohit-chopra-regarding-matterfacebook.
4 Statement of Commissioner Rohit Chopra
Regarding the Report to Congress on Protecting
Older Adults, Comm’n File No. P144400 (Oct. 19,
2020), https://www.ftc.gov/public-statements/2020/
10/statement-commissioner-rohit-chopra-regardingreport-congress-protecting; Rohit Chopra & Samuel
A.A. Levine, The Case for Resurrecting the FTC
Act’s Penalty Offense Authority (Oct. 29, 2020),
https://papers.ssrn.com/sol3/papers.cfm?abstract_
id=3721256.
5 Compl., supra note 2.
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Federal Register / Vol. 86, No. 14 / Monday, January 25, 2021 / Notices
false accuracy claims and engage in
unfair, discriminatory conduct.6
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
[FR Doc. 2021–01430 Filed 1–22–21; 8:45 am]
National Institutes of Health
BILLING CODE 6750–01–P
Government-Owned Inventions;
Availability for Licensing
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
AGENCY:
National Institutes of Health,
HHS.
National Institutes of Health
ACTION:
National Institute of Dental &
Craniofacial Research; Notice of
Closed Meeting
The invention listed below is
owned by an agency of the U.S.
Government and is available for
licensing to achieve expeditious
commercialization of results of
federally-funded research and
development. Foreign patent
applications are filed on selected
inventions to extend market coverage
for companies and may also be available
for licensing.
FOR FURTHER INFORMATION CONTACT:
Carol A. Salata at 240–627–3727;
csalata@niaid.nih.gov. Licensing
information and copies of the U.S.
patent application listed below may be
obtained by communicating with the
indicated licensing contact at the
Technology Transfer and Intellectual
Property Office, National Institute of
Allergy and Infectious Diseases, 5601
Fishers Lane, Rockville, MD 20852; tel.
301–496–2644. A signed Confidential
Disclosure Agreement will be required
to receive copies of unpublished patent
applications.
SUPPLEMENTARY INFORMATION:
Technology description follows:
SUMMARY:
Pursuant to section 10(d) of the
Federal Advisory Committee Act, as
amended, notice is hereby given of the
following meeting.
The meeting will be closed to the
public in accordance with the
provisions set forth in sections
552b(c)(4) and 552b(c)(6), Title 5 U.S.C.,
as amended. The grant applications and
the discussions could disclose
confidential trade secrets or commercial
property such as patentable material,
and personal information concerning
individuals associated with the grant
applications, the disclosure of which
would constitute a clearly unwarranted
invasion of personal privacy.
Name of Committee: NIDCR Special Grants
Review Committee.
Date: February 18–19, 2021.
Time: 8:00 a.m. to 5:00 p.m.
Agenda: To review and evaluate grant
applications.
Place: National Institute of Dental and
Craniofacial Research, National Institutes of
Health, 6701 Democracy Boulevard, Room
666, Bethesda, MD 20892 (Virtual Meeting).
Contact Person: Latarsha J. Carithers,
Scientific Review Officer, Scientific Review
Branch, National Institute of Dental and
Craniofacial Research, National Institutes of
Health, 6701 Democracy Boulevard, Room
666, Bethesda, MD 20892, 301–594–4859,
latarsha.carithers@nih.gov.
(Catalogue of Federal Domestic Assistance
Program Nos. 93.121, Oral Diseases and
Disorders Research, National Institutes of
Health, HHS)
Dated: January 19, 2021.
Melanie J. Pantoja,
Program Analyst, Office of Federal Advisory
Committee Policy.
[FR Doc. 2021–01486 Filed 1–22–21; 8:45 am]
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BILLING CODE 4140–01–P
6 Prepared Remarks of Commissioner Rohit
Chopra at Asia Pacific Privacy Authorities 54th
APPA Forum (Dec. 7, 2020), https://www.ftc.gov/
public-statements/2020/12/prepared-remarkscommissioner-rohit-chopra-asia-pacific-privacy.
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Notice.
Prefusion-Stabilized Fusion (F)
Glycoprotein Vaccine Immunogens for
Human Metapneumovirus
Description of Technology:
Human metapneumovirus (hMPV)
infections have been shown as a
common cause of upper and lower
respiratory diseases such as
bronchiolitis and pneumonia in young
children, the elderly, and other
immunocompromised individuals.
Studies show that infections by the nonsegmented negative strand RNA virus
begin with attachment and entry of viral
glycoproteins that mediate fusion with
host cellular membranes. Like for the
human respiratory syncytial virus
(hRSV), a viral entry is initiated by the
fusion (F) protein. Given its role in
hMPV entry, the F protein has thus been
a target for eliciting neutralizing
antibodies and development of novel
protein-based therapeutic vaccines.
Researchers at the Vaccine Research
Center (VRC) of the National Institute of
Allergy and Infectious Diseases (NIAID)
developed improved recombinant
human metapneumovirus (hMPV) F
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proteins stabilized in the prefusion
conformation that can elicit potent
neutralizing antibodies against
infection. Double and triple stabilized
candidates were designed with interand intraprotomer disulfide mutations
that increase protein production and
show improved antigenic recognition by
prefusion-specific antibodies. These
second-generation immunogens
constitute an improvement over the first
generation constructs and are
characterized by additional stabilization
that results in optimal neutralization
responses.
The second-generation stabilized
prefusion hMPV F immunogens may be
an ideal vaccine immunogen to elicit
broad potent neutralizing antibodies
against metapneumovirus infection,
particularly in children and
immunocompromised adults.
This technology is available for
licensing for commercial development
in accordance with 35 U.S.C. 209 and 37
CFR part 404.
Potential Commercial Applications:
• A promising vaccine immunogen to
elicit broad potent neutralizing
antibodies against metapneumovirus
infection, particularly in children and
immunocompromised adults.
Competitive Advantages:
• There are no approved vaccines or
therapeutics against the second leading
cause of pediatric viral lower respiratory
tract infection in infants and young
children.
• Second-generation hMPV F
immunogens induce higher titer
neutralizing responses than firstgeneration versions in mice.
Development Stage: Preclinical
Research.
Inventors: Peter D. Kwong (NIAID);
Guillaume Stewart-Jones (NIAID); John
R. Mascola (NIAID); Ursula J. Buchholz
(NIAID); Peter L. Collins (NIAID); Jason
Gorman (NIAID); Li Ou,(NIAID);
Tongquing Zhou (NIAID); Baoshan
Zhang (NIAID); Wing-Pui Kong (NIAID);
Yaroslav Tsybovsky (NCI).
Publications: Liu, P., et al (2013). A
live attenuated human
metapneumovirus vaccine strain
provides complete protection against
homologous viral infection and crossprotection against heterologous viral
infection in BALB/c mice. Clinical and
Vaccine Immunology, 20(8), 1246–1254.
Battles, M.B., et al, (2017). Structure
and immunogenicity of pre-fusionstabilized human metapneumovirus F
glycoprotein. Nature communications,
8(1), 1–11.
Intellectual Property: HHS Reference
Number E–131–2019 includes U.S.
Provisional Patent Application Number
63/017,581, filed on 04/29/2020.
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Agencies
[Federal Register Volume 86, Number 14 (Monday, January 25, 2021)]
[Notices]
[Pages 6888-6891]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-01430]
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FEDERAL TRADE COMMISSION
[File No. 192 3172]
Everalbum, Inc.; Analysis of Proposed Consent Order To Aid Public
Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement; request for comment.
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SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair or deceptive acts or
practices. The attached Analysis of Proposed Consent Order to Aid
Public Comment describes both the allegations in the draft complaint
and the terms of the consent order--embodied in the consent agreement--
that would settle these allegations.
DATES: Comments must be received on or before February 24, 2021.
ADDRESSES: Interested parties may file comments online or on paper by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Please write ``Everalbum,
Inc.; File No. 192 3172'' on your comment, and file your comment online
at https://www.regulations.gov by following the instructions on the
web-based form. If you prefer to file your comment on paper, mail your
comment to the following address: Federal Trade Commission, Office of
the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610 (Annex D),
Washington, DC 20580, or deliver your comment to the following address:
Federal Trade Commission, Office of the Secretary, Constitution Center,
400 7th Street SW, 5th Floor, Suite 5610 (Annex D), Washington, DC
20024.
FOR FURTHER INFORMATION CONTACT: James Trilling (202-326-3497), Bureau
of Consumer Protection, Federal Trade Commission, 600 Pennsylvania
Avenue NW, Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing a consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of thirty (30) days. The
following Analysis to Aid Public Comment describes the terms of the
consent agreement and the allegations in the complaint. An electronic
copy of the full text of the consent agreement package can be obtained
at https://www.ftc.gov/news-events/commission-actions.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before February 24,
2021. Write ``Everalbum, Inc.; File No. 192 3172'' on your comment.
Your comment--including your name and your state--
[[Page 6889]]
will be placed on the public record of this proceeding, including, to
the extent practicable, on the https://www.regulations.gov website.
Due to the COVID-19 pandemic and the agency's heightened security
screening, postal mail addressed to the Commission will be subject to
delay. We strongly encourage you to submit your comments online through
the https://www.regulations.gov website.
If you prefer to file your comment on paper, write ``Everalbum,
Inc.; File No. 192 3172'' on your comment and on the envelope, and mail
your comment to the following address: Federal Trade Commission, Office
of the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610 (Annex D),
Washington, DC 20580; or deliver your comment to the following address:
Federal Trade Commission, Office of the Secretary, Constitution Center,
400 7th Street SW, 5th Floor, Suite 5610 (Annex D), Washington, DC
20024. If possible, submit your paper comment to the Commission by
courier or overnight service.
Because your comment will be placed on the publicly accessible
website at https://www.regulations.gov, you are solely responsible for
making sure your comment does not include any sensitive or confidential
information. In particular, your comment should not include sensitive
personal information, such as your or anyone else's Social Security
number; date of birth; driver's license number or other state
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure your comment does not include
sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2),
16 CFR 4.10(a)(2)--including in particular competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule 4.9(c). In particular,
the written request for confidential treatment that accompanies the
comment must include the factual and legal basis for the request, and
must identify the specific portions of the comment to be withheld from
the public record. See FTC Rule 4.9(c). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted on the https://www.regulations.gov website--as legally
required by FTC Rule 4.9(b)--we cannot redact or remove your comment
from that website, unless you submit a confidentiality request that
meets the requirements for such treatment under FTC Rule 4.9(c), and
the General Counsel grants that request.
Visit the FTC website at https://www.ftc.gov to read this Notice and
the news release describing the proposed settlement. The FTC Act and
other laws that the Commission administers permit the collection of
public comments to consider and use in this proceeding, as appropriate.
The Commission will consider all timely and responsive public comments
that it receives on or before February 24, 2021. For information on the
Commission's privacy policy, including routine uses permitted by the
Privacy Act, see https://www.ftc.gov/site-information/privacy-policy.
Analysis of Proposed Consent Order To Aid Public Comment
The Federal Trade Commission (``Commission'' or ``FTC'') has
accepted, subject to final approval, an agreement containing a consent
order from Everalbum, Inc., also doing business as Ever and Paravision
(``Everalbum'' or ``Respondent''). The proposed consent order
(``proposed order'') has been placed on the public record for thirty
(30) days for receipt of comments from interested persons. Comments
received during this period will become part of the public record.
After thirty (30) days, the Commission again will review the agreement
and the comments received, and will decide whether it should withdraw
from the agreement or make final the agreement's proposed order.
Since 2015, Everalbum has operated ``Ever,'' a photo storage and
organization application available as an iOS or Android mobile
application (``app'') and in web and desktop formats. Ever allows
consumers to upload photos and videos (collectively, ``content'') from
mobile devices, computers, or social media or cloud-based storage
service accounts to Ever's cloud servers. In February 2017, Everalbum
launched a new feature of the Ever mobile app, called ``Friends.'' The
Friends feature uses face recognition to organize users' photos by
faces of the people who appear in them. When Everalbum launched the
Friends feature, it enabled face recognition by default for all users
of the Ever mobile app.
Everalbum's application of face recognition to Ever app users'
content has not been limited to providing the Friends feature. The
Commission's proposed complaint alleges that, in four instances,
Everalbum used images it extracted from Ever users' photos in the
development of face recognition technology. In one such instance,
Everalbum used the resulting face recognition technology both in the
Ever app and to build the face recognition services offered by its
enterprise brand, Paravision (formerly Ever AI).
The proposed two-count complaint alleges that Everalbum violated
Section 5(a) of the FTC Act by misrepresenting the company's practices
with respect to Ever users' content.
Proposed complaint Count I alleges that Everalbum misrepresented
the circumstances under which the company would apply face recognition
to Ever users' content. According to the proposed complaint, Everalbum
published a help article entitled ``What is Face Recognition?'' on its
website in July 2018. The proposed complaint alleges that the help
article represented that the Ever app's ``Friends'' feature was not
active--and, therefore, that Everalbum would not apply face recognition
technology to users' content--unless users affirmatively enabled the
feature. The proposed complaint further alleges that the help article
was false or misleading, because, until April 2019, for users in most
geographic locations, Everalbum applied face recognition to users'
content by default and users could not use an app setting to turn off
face recognition.
Proposed complaint Count II alleges that Everalbum misrepresented
that the company would delete the content of Ever users who chose to
deactivate their Ever accounts. According to the proposed complaint,
when Ever users sought to deactivate their accounts, Everalbum
presented them with pop-up messages that represented that account
deactivation would result in Everalbum deleting their content. The
proposed complaint alleges that Everalbum also made a similar
representation in response to consumer inquiries and in its privacy
policy. Despite its representations, Everalbum allegedly did not delete
any users' content upon account deactivation and instead stored the
content indefinitely.
The proposed order contains provisions to address Respondent's
conduct and prevent it from engaging in the same or similar acts or
practices in
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the future. Provision I of the proposed order prohibits Respondent from
making misrepresentations related to the collection, use, disclosure,
maintenance, or deletion of Covered Information (as defined in the
order); consumers' ability to control any of these actions; the extent
to which Everalbum accesses or permits access to Covered Information;
the extent, purpose, and duration of Everalbum's retention of Covered
Information after consumers deactivate their accounts; or the extent to
which Everalbum otherwise protects the privacy, security, availability,
confidentiality, or integrity of any Covered Information.
Part II of the proposed order requires Respondent to clearly and
conspicuously disclose, and obtain consumers' affirmative express
consent for, all purposes for which it will use or share User's
Biometric Information before using the information to create data
needed for face recognition analysis or to develop face recognition
models or algorithms.
Part III of the proposed order requires Respondent to delete (A)
photos and videos of Ever app Users who requested deactivation of their
accounts, (B) face recognition data that it created without obtaining
Users' affirmative express consent, and (C) models and algorithms it
developed in whole or in part using images from Users' photos.
Parts IV through VII of the proposed order are reporting and
compliance provisions, which include recordkeeping requirements and
provisions requiring Respondent to provide information or documents
necessary for the Commission to monitor compliance. Part VIII of the
proposed order states that the order will remain in effect for 20
years, with certain exceptions.
The purpose of this analysis is to aid public comment on the
proposed order. It is not intended to constitute an official
interpretation of the complaint or proposed order, or to modify in any
way the proposed order's terms.
By direction of the Commission.
April J. Tabor,
Acting Secretary.
Statement of Commissioner Rohit Chopra in the Matter of Everalbum, Inc.
Today's facial recognition technology is fundamentally flawed and
reinforces harmful biases. I support efforts to enact moratoria or
otherwise severely restrict its use. Until such time, it is critical
that the FTC meaningfully enforce existing law to deprive wrongdoers of
technologies they build through unlawful collection of Americans'
facial images and likenesses.
The case of Everalbum is a troubling illustration of just some of
the problems with facial recognition. Everalbum operates a business
line called Paravision, which developed and marketed facial recognition
technology, including to clients in the security and air travel
industries.\1\ The company enhanced their facial recognition technology
by allegedly baiting consumers into using Ever, a ``free'' app that
allowed users to store and modify photos.\2\
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\1\ Paravision, https://www.paravision.ai/ (last visited on Jan.
4, 2020).
\2\ Compl., In the Matter of Everalbum, Inc., Comm'n File No.
1923172. This is not the only photo-sharing application that has
drawn scrutiny for its ties to facial recognition and surveillance
technology. Kashmir Hill & Aaron Krolik, How Photos of Your Kids Are
Powering Surveillance Technology, N.Y. Times (Oct. 11, 2019),
https://www.nytimes.com/interactive/2019/10/11/technology/flickr-facial-recognition.html.
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As outlined in the complaint, Everalbum made promises that users
could choose not to have facial recognition technology applied to their
images, and that users could delete the images and their account. In
addition to those promises, Everalbum had clear evidence that many of
the photo app's users did not want to be roped into facial recognition.
The company broke its promises, which constitutes illegal deception
according to the FTC's complaint. This matter and the FTC's proposed
resolution are noteworthy for several reasons.
First, the FTC's proposed order requires Everalbum to forfeit the
fruits of its deception. Specifically, the company must delete the
facial recognition technologies enhanced by any improperly obtained
photos. Commissioners have previously voted to allow data protection
law violators to retain algorithms and technologies that derive much of
their value from ill-gotten data.\3\ This is an important course
correction.
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\3\ The Commission voted 3-2 on a settlement with Google and
YouTube that allowed the companies to retain algorithms and other
technologies enhanced by illegally obtained data on children. Based
on my analysis, the Commission also allowed Google and YouTube to
profit from their conduct, even after paying a civil penalty. See
Dissenting Statement of Commissioner Rohit Chopra In the Matter of
Google LLC and YouTube, LLC, Comm'n File No. 1723083 (Sep. 4, 2019),
https://www.ftc.gov/public-statements/2019/09/statement-commissioner-rohit-chopra-regarding-youtube. The Commission voted 3-
2 on a settlement with Facebook to address unlawful facial
recognition practices that violated a 2012 Commission order. Like
the Google/YouTube settlement, Facebook was not required to forfeit
any facial recognition or other related technologies. The settlement
also provided an unusual immunity clause for senior executives,
including Mark Zuckerberg and Sheryl Sandberg. See also Dissenting
Statement of Commissioner Rohit Chopra In re Facebook, Inc., Comm'n
File No. 1823109 (Jul. 24, 2019), https://www.ftc.gov/public-statements/2019/07/dissenting-statement-commissioner-rohit-chopra-regarding-matter-facebook.
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Second, the settlement does not require the defendant to pay any
penalty. This is unfortunate. To avoid this in the future, the FTC
needs to take further steps to trigger penalties, damages, and other
relief for facial recognition and data protection abuses. Commissioners
have voted to enter into scores of settlements that address deceptive
practices regarding the collection, use, and sharing of personal data.
There does not appear to be any meaningful dispute that these practices
are illegal. However, since Commissioners have not restated this
precedent into a rule under Section 18 of the FTC Act, we are unable to
seek penalties and other relief for even the most egregious offenses
when we first discover them.\4\
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\4\ Statement of Commissioner Rohit Chopra Regarding the Report
to Congress on Protecting Older Adults, Comm'n File No. P144400
(Oct. 19, 2020), https://www.ftc.gov/public-statements/2020/10/statement-commissioner-rohit-chopra-regarding-report-congress-protecting; Rohit Chopra & Samuel A.A. Levine, The Case for
Resurrecting the FTC Act's Penalty Offense Authority (Oct. 29,
2020), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3721256.
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Finally, the Everalbum matter makes it clear why it is important to
maintain states' authority to protect personal data. Because the people
of Illinois, Washington, and Texas passed laws related to facial
recognition and biometric identifiers, Everalbum took greater care when
it came to individuals in these states.\5\ The company's deception
targeted Americans who live in states with no specific state law
protections.
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\5\ Compl., supra note 2.
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With the tsunami of data being collected on individuals, we need
all hands on deck to keep these companies in check. State and local
governments have rightfully taken steps to enact bans, moratoria, and
other restrictions on the use of these technologies. While special
interests are actively lobbying for federal legislation to delete state
data protection laws, it will be important for Congress to resist these
efforts. Broad federal preemption would severely undercut this multi-
front approach and leave more consumers less protected.
It will be critical for the Commission, the states, and regulators
around the globe to pursue additional enforcement actions to hold
accountable providers of facial recognition technology who make
[[Page 6891]]
false accuracy claims and engage in unfair, discriminatory conduct.\6\
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\6\ Prepared Remarks of Commissioner Rohit Chopra at Asia
Pacific Privacy Authorities 54th APPA Forum (Dec. 7, 2020), https://www.ftc.gov/public-statements/2020/12/prepared-remarks-commissioner-rohit-chopra-asia-pacific-privacy.
[FR Doc. 2021-01430 Filed 1-22-21; 8:45 am]
BILLING CODE 6750-01-P