Comment from Frazier, Keisha

“AI Policy Statement; Matter No. P264200” While preventing systemic biases from being produced within Artificial Intelligence (AI) systems is important, rather than focus on the current accuracy of AI systems, we should focus on safeguarding Americans from the negative impacts of AI. I implore the FTC to examine the output produced by Artificial Intelligence systems combined with the misuse of re-identified, aggregated, or de-anonymized user data as tools of highly advanced surveillance. While companies use highly advanced behavioral profiling and predictive analytics techniques to forecast consumer behaviors and market trends for AI advertising systems, we must ensure that highly accurate “digital twins” of consumers are not being used for unintended purposes such as surveillance, deep privacy violations, algorithmic bias, and metaphorical misrepresentation which would classify as deceptive acts or practices in section 5 of the Federal Trade Commission Act. AI advertising ecosystems, such as the Meta Accounts Center which combines Facebook, Instagram, Meta Horizon, and other Meta Platforms, Inc. applications to utilize cross-platform activity, pose a threat to personal autonomy, cognitive liberty, and mental privacy. Meta Horizon, which is a companion application to the Meta Quest 3 Virtual Reality (VR) device, transforms immersive spaces into highly personalized, data-driven ad networks. While Meta currently states that raw body and hand tracking data processed locally on headsets (like raw sensor images) is not used for targeted advertising, Meta uses abstracted, device-usage data from Meta Horizon for advertising and personalization. De-identified, aggregated, or anonymized spatial and behavioral usage data harnessed for Meta app development – such as gaze duration, reaction times, avatar proximity, and interaction frequencies in Meta Horizon – allows for deep behavioral analytics that raise significant privacy concerns upon re-identification or de-anonymization. Such usage moves beyond traditional web tracking and into behavioral profiling using “insights” derived from biometric data. Telemetry can be abstracted into highly valuable consumer intelligence that allows for subconscious profiling, sensitive cognitive state inference, re-identification, and de-anonymization risks. When this data is shared or sold to third parties, these immersive profiles can pose dangers to the safety of consumers by “using user data to perform, facilitate, or provide tools for surveillance” [https://developers.meta.com/horizon/policy/data-use/]. Consumer risk multiplies when immersive profiles are aggregated with data from data brokers and websites that have Meta Pixel embedded as sensitive health, financial, and educational data can be exposed and exploited by sophisticated tracking, predatory advertising networks, and identity theft. In support of the Management of Individuals’ Neural Data (MIND) Act of 2025 (S.2925), please conduct a study to investigate deceptive or misleading claims in new and evolving technologies, such as AI-powered immersive technological devices, to include the misuse of consumer profiles for cognitive biometric inference attacks and other unidentified purposes. These unidentified purposes are the result of unexpected objectives, such as the creation of highly invasive behavioral profiles that allow for unauthorized or covert surveillance, which are in direct non-compliance with section 5 of the FTC Act.