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    Try reading the complaint you linked, all two pages of it, and surrounding material. Level 3 was among a dozen defendants across disparate industries. The FTC stated repeatedly -- on real government letterheads and real government websites -- that this was about lapsed certifications only. "The complaints do not allege", they also repeated, "that any Respondent committed any substantive violations of the privacy principles of the Safe Harbor framework."

    I remember reading some of this after the order was issued. This seemed to be about keeping the European Union happy more than anything. The EU takes information privacy with a deadly seriousness the US could learn from. That said, the FTC has previously sued MySpace, Google, and Facebook for "substantive noncompliance" with the same Safe Harbor provisions.

    I am waiting for the part where you run a half mile of yarn to connect this action to illegal telemarketing. Actually, I'm not, since I have real work to do and little time for "falling sky" arguments.
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