Leafing through pages and pages of historical records on the FTC, one is frustrated by both its volume, and by what it is missing. For much of the FTC’s history the agency quietly settled matters with companies using assurances of voluntary compliance (“AVCs”). One result is that there are very interesting docket entries in the FTC history but almost no information about the alleged wrongdoing.
Here’s an example—a 1937 investigation against a company operating as “National Census Bureau.” We do not get to learn who the et al. were or the subject matter of the investigation. The respondent’s name is perfect for deceptive information collection—could this be the FTC’s first information privacy case? We’ll never know.