
A coalition of 15 public-interest organizations is urging the U.S. Federal Trade Commission (FTC) to reject X Corp.'s request to terminate or weaken a 2022 privacy order requiring the company to undergo regular compliance reviews after it repeatedly violated users' privacy.
The groups argue that X has failed to meet the legal standard for modifying the order and that its recent handling of user data demonstrates the need for continued oversight.
The comments, submitted by the Electronic Frontier Foundation (EFF), Electronic Privacy Information Center (EPIC), Demand Progress Education Fund, National Consumers League, Public Citizen, and 10 other organizations, respond to a petition X filed with the FTC in May seeking to set aside or modify the consent order that has governed the company since 2022.
In 2011, the FTC reached a settlement with the company after finding it had failed to adequately protect users' personal information. That agreement required Twitter to establish a comprehensive privacy and security program and submit regular reports to the FTC for 20 years.
The FTC renewed and expanded those obligations in 2022 after determining that Twitter had deceptively used phone numbers and email addresses that users provided for account security to serve targeted advertisements. The agency said the misconduct affected more than 140 million users and imposed a $150 million penalty, along with stricter compliance requirements extending through 2042.
X now argues that the company has fundamentally changed under Elon Musk's ownership, citing new leadership, new privacy personnel, and a redesigned security program. It also claims the consent order diverts engineering resources away from artificial intelligence development, arguing that ending the order would support American AI leadership.
The organizations dispute both claims.
According to the letter, FTC consent orders bind the corporate entity rather than individual executives or employees, meaning leadership changes do not eliminate legal obligations. The groups also note that X's current privacy program exists because the 2022 order required the company to implement it, making it difficult to argue that the same program justifies ending the oversight that created it.
The coalition further argues that X's expansion into AI increases rather than reduces the need for regulatory scrutiny. It points to X's use of platform data to train its Grok AI models without obtaining meaningful user consent, saying the growing demand for training data creates additional incentives to collect and reuse personal information beyond its original purpose.
The letter also references several recent incidents that, according to the organizations, undermine X's argument that it no longer requires close oversight. These include a massive 2025 leak involving billions of records, ongoing investigations into Grok by European regulators, and scrutiny over AI-generated child sexual abuse material and non-consensual intimate imagery.
The organizations also reject X's claim that the order infringes on its First Amendment rights. They argue the consent decree regulates privacy, security, and consumer protection practices rather than speech or content moderation, and that the FTC's oversight has always focused on how X handles users' personal information rather than the content published on its platform.
Finally, the coalition dismisses X's argument that compliance costs justify ending the order. According to the filing, X reported spending roughly $16.6 million on compliance since 2022, an amount the organizations describe as insignificant compared to the company's reported $200 billion valuation following its merger with xAI. They argue those costs are an expected consequence of settling repeated privacy violations and are outweighed by the protections the order provides for millions of users.
The groups conclude that removing the consent decree would weaken one of the FTC's strongest mechanisms for ensuring X complies with its privacy obligations and could encourage other companies under FTC orders to seek early release from similar agreements. They urge the Commission to leave the 2022 order intact for its full term.







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