The Fear Monetization Playbook: Doom Profiteering and the Business of Permanent Crisis

Bill Gates, Al Gore, hedge funds, AI labs and the economics of turning public anxiety into private advantage

Fear has an income statement.

It can sell a protective product, attract investment capital, loosen a government procurement process, or persuade the public that an industry needs extraordinary protection from competition. For people who own the proposed solution, a frightening future can become a valuable commercial asset long before that future arrives.

The public experiences uncertainty. The well-positioned investor sees an opportunity. The influential philanthropist gains a larger role in deciding what governments should do. The incumbent company becomes the institution we are told to trust with our survival.

This is the political economy of doom profiteering: the conversion of catastrophic expectations into financial returns, commercial advantages, and authority over public decisions.

The strongest version of this argument does not require a fabricated pandemic, imaginary climate change, or a secret meeting of billionaires. It requires something more ordinary and far more durable: people with substantial interests helping to shape the public’s understanding of risks that directly affect those interests.

Bill Gates, Al Gore, and hedge fund managers belong in this discussion because their public interventions intersect with institutions, investments, and markets. Their cases differ. Some involve documented financial gains. Others involve overlapping roles and outsized influence. Treating them as identical would obscure how the system actually works.

Society has become too accommodating of powerful people who help define an emergency while retaining a stake in its resolution. A disclosure statement does not settle that problem. Neither does a philanthropic mission. Being right about a danger does not confer the right to organize the response around one’s own institutions.

How fear becomes an economic asset

Start with a household deciding whether to buy protection against a possible loss. Its willingness to pay depends partly on the perceived probability of harm, the size of that harm, and how much protection the product appears to offer.

Take a deliberately simple example. A $1 million loss with a perceived probability of 1 percent represents an expected loss of $10,000. Raise the perceived probability to 10 percent and the expected loss becomes $100,000. The underlying danger need not change for the apparent value of protection to rise tenfold.

Real decisions also depend on risk aversion, affordability, timing, and uncertainty. Still, the commercial incentive is plain. A seller who can influence perceived danger can influence demand for the remedy.

At the institutional level, the same mechanism shapes budgets. An ordinary investment proposal has to compete with other uses of money. A proposal framed as necessary to prevent catastrophe can make comparison itself seem irresponsible. Questions about price, effectiveness, alternatives, and conflicts become politically harder to ask.

The media market adds its own incentive. A 2023 study in Nature Human Behavior analyzed randomized headline experiments from the Upworthy Research Archive, covering roughly 105,000 headline variations and more than 370 million impressions. For a headline of average length, each additional negative word raised the click-through rate by about 2.3 percent. That is a relative increase, not 2.3 percentage points, and the study measured negativity rather than proving that fear always sells. But it shows how presentation can change attention without changing the underlying story. [1]

Attention is only the first transaction. The more consequential ones involve contracts, investment flows, regulatory authority, and ownership.

There is also a difference between earning a return by reducing danger and collecting an economic rent by controlling access to the response. A company that develops an effective treatment creates value. A company that secures privileged contracts, or rules that shut out equally capable competitors, captures value well beyond what it contributed.

The economics of regulatory capture offers a useful warning. George Stigler challenged the assumption that regulation necessarily serves the public. Sam Peltzman’s later reassessment adds a qualification: industries do not always seek new regulation, but their interests can carry disproportionate weight once the rules change. [2]

An emergency is an immediate opportunity to change the rules.

Bill Gates and the authority to define the next emergency

Gates’s public role has expanded from software to global health, pandemic preparedness, climate, and artificial intelligence. The recurring issue is the combination of money, access, technical prestige, and influence over which problems receive public attention.

His 2015 TED talk warned that the world was poorly prepared for a major outbreak. COVID-19 showed that concern was legitimate. Calling every such warning an invented scare would weaken the economic critique rather than strengthen it. [3]

His AI commentary also has a history. In July 2023 he published an essay titled “The risks of AI are real but manageable,” arguing that societies could address the technology’s dangers while capturing its benefits. His recent warnings are an escalation within a familiar subject, not the sudden discovery of a replacement crisis. [4]

In an August 26, 2026 essay, Gates made a sharper case about AI’s potential to eliminate jobs and concentrate economic gains. He compared the risk to Great Depression unemployment while allowing that AI might not reach that level, and argued that its effects would not fade with an ordinary economic cycle. He called for new national bodies and international institutions to manage AI risk. He acknowledged that he still has financial ties to the technology industry, and the essay discussed substantial benefits alongside the dangers. [5] The Gates Foundation, meanwhile, works directly with Microsoft and other AI companies.

Disclosure does not neutralize the overlap. It is the reason scrutiny is appropriate.

An influential technology investor can help shape expectations about AI, propose the institutions that should govern its disruption, and remain connected to the industry whose products sit at the center of that transformation. Each role may be defensible on its own. Concentrated in one person, they create a real accountability problem.

The relevant questions are concrete. Which forecasts justify the proposed intervention? Who evaluates them independently? Which companies gain customers or policy advantages? Who would staff and advise the new institutions? Which alternatives get less attention because they fall outside the preferred technological approach?

The health portfolio shows how philanthropy can operate through corporate finance. In September 2019, BioNTech announced a collaboration with the Gates Foundation that included an initial $55 million equity investment for HIV and tuberculosis programs. The agreement filed with the SEC tied the investment to global access commitments. [6][7]

Those records describe a foundation investment, not a personal stock purchase by Gates. They do not show that he manufactured pandemic fears for trading profits. What they show is an institutional model in which charitable goals, equity ownership, technology development, and decisions about access coexist inside the same arrangement.

That model deserves examination on its own terms. When private funding helps determine which solutions get developed, the donor shapes the menu of future public choices. Successful philanthropy can deliver valuable goods while concentrating considerable agenda-setting power.

Gates’s place in the doom economy is best documented through overlapping interests and private authority. A claim that his warnings produced personal profits would require entirely different evidence.

The political objection stands on its own. Exceptional wealth should not become a standing qualification to define society’s emergencies or choose their remedies. The public can benefit from someone’s expertise without handing that person disproportionate control over its priorities.

Al Gore and the commercial value of an approaching deadline

Gore presents a different combination: catastrophic rhetoric, a prominent forecast that did not materialize within its stated window, and a business built around sustainable investment.

At the Copenhagen climate conference in December 2009, Gore cited research suggesting a 75 percent chance that the Arctic could be completely ice-free during some summer months within five to seven years. PolitiFact’s reporting shows that the scientist he cited, Wieslaw Maslowski, questioned how that figure was derived and said he would not have offered a probability that precise. [8]

The projected outcome did not arrive within the stated window. In September 2016, Arctic sea ice still covered about 4.14 million square kilometers at its seasonal minimum, according to the National Snow and Ice Data Center. That tied for the second-lowest extent on record, but it was a long way from an ice-free Arctic. [9]

A probabilistic forecast is not a guarantee, and one unrealized outcome cannot by itself disprove a probability. The criticism here is narrower. Gore publicized a striking numerical probability whose scientific attribution was contested, attached it to a short horizon, and presented it to a global audience.

The underlying climate science does not depend on that statement. The IPCC’s 2023 synthesis report concludes that human activities have caused global warming. A campaigner’s overstatement and the physical evidence of warming are separate matters. [10]

Keeping them separate is what makes accountability possible. Advocates should answer for the precision and deadlines they choose, even when the broader cause is sound.

Gore is also a founding partner and chairman of Generation Investment Management. In 2021, Generation launched Just Climate to direct capital toward decarbonization while seeking investment returns. Gore chairs its Climate Impact Advisory Group. [11][12]

That is a direct overlap between advocacy and commercial activity. It does not show that any particular speech attracted any particular investment or increased Gore’s personal wealth. It does mean his role extends well beyond commentary. He participates in businesses operating inside the economic transition he promotes.

There is nothing improper about investing in a problem you believe needs solving. The conflict arises when audiences are invited to treat the advocate’s urgency as separate from the advocate’s commercial position.

Consider the general incentive. An investment manager benefits when a category becomes a priority for capital allocation. A public campaign can make that category urgent, respectable, and institutionally attractive. When advocacy and asset management overlap, the investment thesis gains a powerful promotional channel.

The test is whether the proposed investments and policies remain justified under a sober presentation of probabilities, timelines, costs, and alternatives. If a strategy needs an approaching apocalypse to make its economics persuasive, the public should ask for better economics.

Hedge funds can own both the warning and the rebound

Bill Ackman’s pandemic trade shows the financial machinery more directly.

During a March 18, 2020 CNBC appearance, Ackman warned that “hell is coming.” [13]

Pershing Square later reported $2.6 billion in proceeds from credit hedges that cost about $27 million in premiums and commissions. The positions gained as credit conditions deteriorated. The firm said the hedges offset losses in its stock portfolio and that it used the proceeds to add to holdings and buy investments at depressed prices. These were fund proceeds, not $2.6 billion of personal income for Ackman. [14]

The timing matters. In its March 26 letter, Pershing Square said it had begun unwinding the hedge on March 12. By the time of Ackman’s television appearance, it had already realized more than $1.3 billion, with roughly another $1.3 billion in remaining value. The firm said the hedge did not rise in value during or after the interview, and Ackman said on air that he was buying stocks. [15]

That record does not support the easy accusation that the interview created the hedge profits. Proving market manipulation would require far more than an alarming broadcast followed by a profitable disclosure.

What it does reveal is the asymmetry in how people experience a crisis.

A household can face unemployment, shrinking retirement savings, and bills that come due regardless. A sophisticated fund can hold instruments that gain when credit conditions worsen, sell them, and use the proceeds to buy discounted assets. The same disruption produces financial distress for one participant and purchasing power for another.

This is lawful risk management, and hedging serves legitimate economic functions. The broader question concerns the combination of market position and public influence. A financier speaking to a frightened audience may hold a portfolio whose response to events is far more complicated than viewers can infer from the warning.

Public commentary should be evaluated alongside positions, timing, and exposure. A bearish statement does not mean the speaker is selling. A catastrophic scenario does not mean the speaker expects permanent collapse. Investors can protect themselves against the downturn and position for the recovery at the same time.

The distributional concern is larger than any single trade. People who enter a crisis with liquidity and access to sophisticated markets can emerge with a larger claim on future income. People forced to sell assets or borrow to get through it emerge with less.

Fear becomes especially valuable when you have the capital to wait out everyone else’s urgency.

AI doom can become a barrier to entry

Artificial intelligence adds another mechanism: warnings about an industry’s products can help entrench the industry’s largest producers.

In May 2023, the Center for AI Safety published a statement placing the risk of extinction from AI alongside pandemics and nuclear war as a global priority. Signatories included senior figures from major AI laboratories as well as academic researchers. [16]

Earlier that month, Sam Altman’s written Senate testimony proposed considering licensing or registration requirements for developing and releasing AI models above a capability threshold, along with safety testing and external evaluation. [17]

Proposals like these can have genuine safety goals. They also call for a serious competition analysis.

Imagine a compliance obligation costing $10 million a year. For a company with $10 billion in revenue, that is 0.1 percent of revenue. For a company with $20 million in revenue, it is 50 percent. Identical rules can produce very different competitive effects.

A rule can reduce risk and strengthen incumbents at the same time. Whether that tradeoff is worth it depends on measurable benefits, alternative designs, and the burden placed on smaller players.

The danger of capture grows when the firms warning about catastrophe are also treated as the main authorities on which competitors should be allowed to operate. Their expertise deserves a hearing. Their commercial preferences deserve independent scrutiny.

Concentration is already a practical concern. A January 2025 FTC staff report examined partnerships involving Microsoft, Amazon, Alphabet, OpenAI, and Anthropic. It identified potential competition issues around access to key inputs, contractual and technical switching costs, and access to sensitive business information. It also documented investment arrangements that came with significant spending commitments on the investor’s cloud services. [18]

The report did not find that catastrophe rhetoric caused these arrangements. It does describe the market structure into which any new restrictions would be introduced.

The core concern is that existential framing can hand concentrated corporate power a protective rationale. The industry becomes indispensable because of what it promises and hard to challenge because of what it warns might happen.

A credible safety regime has to constrain the largest firms at least as effectively as it constrains their would-be competitors. Otherwise the public ends up financing protection for the incumbents rather than protection from the technology.

Emergency spending opens another route to private gain

Pandemics show how quickly legitimate urgency can strip away the safeguards around public money.

The UK’s National Audit Office reported that by July 31, 2020, contracts worth £18 billion had been awarded in connection with the pandemic response. Of £17.3 billion in new contracts, £10.5 billion was awarded directly without competitive tender. Suppliers referred through a high-priority lane won contracts at a much higher rate than those using the ordinary route: about one in ten, compared with fewer than one in a hundred. The audit also found significant gaps in documentation and transparency. [19]

The referral routes included officials and health professionals as well as political offices. The different success rates alone do not prove corruption, and the government faced real shortages. But the audit shows why urgency calls for stronger accountability, not an exemption from it.

Once access to decision makers affects who gets considered first, relationships acquire immediate economic value. A crisis converts that value into a signed contract long before normal scrutiny catches up.

Public investment also shifts who bears the risk. A 2023 BMJ study estimated that the United States committed at least $31.9 billion to developing, producing, and purchasing mRNA COVID-19 vaccines through March 2022. About $29.2 billion of that went to vaccine purchases, so describing the whole sum as a research subsidy would be misleading. [20]

Government purchases secured useful products. They also guaranteed demand on a scale that changes commercial risk entirely. That fact should shape how policymakers negotiate prices, access, supply commitments, and returns to the public.

When taxpayers absorb uncertainty, the contract should spell out what they receive in return. Emergency rhetoric is no substitute for that negotiation.

Sometimes the fear itself is the product

In some cases, the link between alarming claims and sales is explicit.

In 2019, Office Depot and Support.com agreed to pay a combined $35 million to settle FTC allegations involving deceptive computer diagnostics. According to the FTC, a program presented as a malware scan produced its results from customers’ answers to preliminary questions rather than from any actual scan. Those results were then used to sell paid repair services. [21]

That was a consumer protection case, not a finding about Gates, Gore, or the AI industry. Its relevance is the mechanism: control the diagnosis, raise the alarm, sell the remedy.

At larger scales the same mechanism is harder to identify, because the danger may be real, the remedy partly effective, and the financial benefit indirect. Those complications make careful investigation more important. They do not make conflicts disappear.

The analytical task is to establish which link in the chain the evidence actually supports: misleading claims, increased demand, preferential access, excess returns, or concentrated authority. A documented conflict warrants scrutiny. An accusation of deliberate deception requires evidence of deception.

Why disclosure is not enough

Disclosure tells the public that an incentive exists. It does not change the incentive.

An executive can acknowledge an investment and still advocate policies that benefit it. An asset manager can describe a financial interest while continuing to shape the expectations that determine its value. A foundation can publish its portfolio while retaining enormous influence over global funding priorities.

The appropriate response is institutional. A democracy should reduce its dependence on the judgment of people whose interests are affected by the decisions being made.

That starts with independent evaluation of major public forecasts. Claims should specify an outcome, a time horizon, key assumptions, and the evidence that would lead the forecaster to revise the assessment. Probabilities should be judged across a track record of predictions, not treated as infallible when convenient or dismissed entirely after a single miss.

It also requires honesty about prevention. A disaster that fails to occur may have been prevented by an effective response, or it may have been overstated. Telling those apart requires evidence about what the intervention actually changed. The absence of catastrophe does not automatically vindicate either the campaigner or the critic.

Procurement should come with prompt publication of contracts, ownership information, referral routes, and the specific reasons competition was bypassed. Emergency exceptions need firm expiration dates and retrospective audits with real consequences.

Regulation should be assessed for safety and competition together. Policymakers should ask whether a less exclusionary measure could achieve comparable protection, whether evaluations can be independently reproduced, and whether incumbents bear responsibility for harms their own products cause.

Public funding should secure public benefits in the text of the agreement. Depending on the investment, that might mean access guarantees, pricing conditions, repayment terms, royalties, or equity participation. The terms should reflect what the public contributed and which risks it absorbed.

Media organizations should treat portfolio exposure as part of the story when investors issue market-sensitive warnings. A generic disclosure of holdings tells an audience little about whether the speaker benefits from a fall, a rebound, volatility, or a particular policy response.

Finally, institutional authority must remain contestable. Workers, consumers, independent researchers, smaller businesses, and affected communities need meaningful roles in deciding which risks matter and how limited resources are spent. Wealth buys access in many settings. It should never buy the final word on collective priorities.

Who owns the response?

The cases examined here establish different things. Gore’s Arctic statement raises questions about overstated precision and forecast accountability, alongside a documented investment role. Gates’s record shows financial ties, philanthropy, and agenda-setting authority converging in one person. Ackman’s trade shows how a fund can gain enormous financial capacity during a public emergency, without proving that his public warnings caused the gain. The procurement and consumer protection cases show direct pathways through which urgency and alarming claims produce commercial advantage.

Taken together, they justify a higher standard for the business of warning the public.

Doom profiteering thrives when audiences are asked to accept a complete package: the diagnosis, the deadline, the preferred solution, and the unquestioned authority of the people offering it. Each piece deserves its own examination.

The public owes serious risks serious attention. It owes the owners of the proposed remedies no presumption of disinterest.

When a billionaire, fund manager, or corporate executive tells us catastrophe is approaching, the inquiry should extend all the way to the contract, the portfolio, and the proposed rule. We should ask what the evidence actually supports, whose bargaining power shifts, and who will own more of the economy once the emergency response is complete.

The warning may be entirely justified. The arrangement still has to earn public consent.

About the Author

Brian Curry is a Kansas City-based machine learning and AI strategist, marketing economist, and applied researcher. He leads Vector1, an independent research studio working on cognitive AI, causal inference, marketing economics, and knowledge engineering, with a focus on simulation-driven intelligence systems.

Over more than twenty years, Brian has led data science and analytics initiatives at enterprises ranging from $4B to $125B in revenue, including Koch Industries, Tractor Supply, Vail Resorts, Hallmark, Garmin, and AT&T. His work applies economics and causal inference to connect marketing investment to structural outcomes, operational decisions to economic value, and AI adoption to durable competitive advantage.

He is also the founder of KC AI Lab, a 1,500-member AI and ML education community in the Midwest. He lives in Kansas City and is an active part of the Kansas City community.

Research and Open-Source Projects

The modeling approach in this paper draws on PyCausalSim and Papilon.

Causal Inference and Economics

• PyCausalSim: Simulation-driven causal discovery and evaluation, using counterfactual scenarios to isolate structural drivers.
• Papilon: Complex-system simulation and optimization, with applications in media mix modeling and adaptive architectures.
• Daedalus: Causal analytics for money-flow mapping and macroeconomic tracking.
• The Autonomy Economy: A macroeconomic framework for the combined effects of rapid productivity growth and structural price deflation in an AI-automated economy.

Forecasting and Applied Modeling

• Regimecast: Time-series regime detection, structural breaks, and economic forecasting.
• CarryNet: Financial modeling for commodity carry trade analysis.
• Foodmesh-ml: Machine learning, optimization, and simulation for distributed food systems.

Cognitive AI and Semantic Architecture

• Memory-Node Encapsulation (MNE): A cognitive AI architecture and data structure for artificial episodic memory (NeoCortex-M).
• MeaningFlow: Semantic content modeling, embeddings, clustering, and coverage gap analysis.

Contact: brian@vector1.ai | GitHub @Bodhi8 | Substack

The text of this article may be shared with attribution under Creative Commons Attribution 4.0 International (CC BY 4.0). Code and models referenced here are available separately to paid subscribers.

References

[1] Robertson, C. E., et al. “Negativity drives online news consumption.” Nature Human Behaviour 7, 812–822 (2023). Randomized headline evidence; the finding concerns negative language and click-through rates, not all forms of fear or media engagement. https://www.nature.com/articles/s41562-023-01538-4

[2] Peltzman, S. “Stigler’s Theory of Economic Regulation After Fifty Years.” University of Chicago working paper (2021). Retrospective analysis of capture theory, including qualifications to the original account. https://chicagounbound.uchicago.edu/law_and_economics/944/

[3] Gates, B. “The next outbreak? We’re not ready.” TED, March 2015. https://www.ted.com/talks/bill_gates_the_next_outbreak_we_re_not_ready

[4] Gates, B. “The risks of AI are real but manageable.” Gates Notes, July 11, 2023. https://www.gatesnotes.com/meet_bill/tech_thinking/reader/the_risks_of_ai_are_real_but_manageable

[5] Gates, B. “The choices we make about AI now are critical.” Gates Notes, August 26, 2026. Source for his employment warnings, proposed institutions, financial interest disclosure, and discussion of benefits. https://www.gatesnotes.com/a-turbulent-ai-era-and-critical-choices-to-make

[6] BioNTech. “BioNTech Announces New Collaboration to Develop HIV and Tuberculosis Programs.” September 4, 2019. https://investors.biontech.de/news-releases/news-release-details/biontech-announces-new-collaboration-develop-hiv-and/

[7] BioNTech and Bill & Melinda Gates Foundation. Strategic relationship letter agreement, August 29, 2019. SEC Exhibit 10.37. Identifies the foundation investment and global access commitments. https://www.sec.gov/Archives/edgar/data/1776985/000119312519241112/d635330dex1037.htm

[8] PolitiFact. “Fact-checking claims that Al Gore said all Arctic ice will be gone in the summer by 2013.” March 2, 2021. Reproduces Gore’s December 2009 statement and traces the dispute over its scientific attribution. https://politifact.com/factchecks/2021/mar/02/facebook-posts/fact-checking-claims-al-gore-said-all-arctic-ice-w/

[9] National Snow and Ice Data Center. “2016 ties with 2007 for second lowest Arctic sea ice minimum.” September 15, 2016. https://nsidc.org/news-analyses/news-stories/2016-ties-2007-second-lowest-arctic-sea-ice-minimum

[10] IPCC. Climate Change 2023: Synthesis Report, headline statements, section A.1. https://report.ipcc.ch/ar6syr/headline.html

[11] Generation Investment Management. “Our Leadership.” Al Gore’s role as founding partner and chairman. Accessed September 26, 2026. https://www.generationim.com/our-firm/our-leadership/

[12] Generation Investment Management. “Generation Investment Management LLP Launches Just Climate to Seek to Address the Global Net Zero Emissions Challenge.” October 27, 2021. https://www.generationim.com/our-thinking/news/generation-investment-management-llp-launches-just-climate-to-seek-to-address-the-global-net-zero-emissions-challenge/

[13] Gandel, S. CBS News, March 27, 2020. Reporting on Ackman’s CNBC appearance. https://www.cbsnews.com/news/bill-ackman-billionaire-made-2-6-billion-coronavirus-meltdown/

[14] Pershing Square Capital Management. Letter to investors, March 25, 2020. Source for hedge proceeds, premiums and commissions, portfolio offsets, and reinvestment. https://pershingsquareholdings.com/https-pershingsquareholdings-com-pershing-square-capital-management-l-p-releases-letter-to-investors/

[15] Pershing Square Capital Management. Letter to investors, March 26, 2020. The firm’s account of the hedge’s timing and Ackman’s television appearance. Statements about the absence of interview-related gains are attributed to the firm. https://pershingsquareholdings.com/wp-content/uploads/2020/03/Pershing-Square-Capital-Management-L.P.-Releases-Letter-to-Investors-March-26-2020.pdf

[16] Center for AI Safety. “AI Extinction Statement Press Release.” May 30, 2023. https://safe.ai/work/press-release-ai-risk

[17] Altman, S. Written testimony to the U.S. Senate Judiciary Subcommittee on Privacy, Technology, and the Law, May 16, 2023. Licensing and registration proposals appear on page 12 of the PDF. https://www.judiciary.senate.gov/imo/media/doc/2023-05-16%20-%20Bio%20%26%20Testimony%20-%20Altman.pdf

[18] Federal Trade Commission. “FTC Issues Staff Report on AI Partnerships & Investments Study.” January 17, 2025. Reports potential competition implications, not findings that particular partnerships or risk statements were unlawful. https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-issues-staff-report-ai-partnerships-investments-study

[19] National Audit Office. Investigation into government procurement during the COVID-19 pandemic. November 2020. Findings cover procurement through July 31, 2020. https://www.nao.org.uk/press-releases/government-procurement-during-the-covid-19-pandemic/

[20] Lalani, H. S., et al. “US public investment in development of mRNA covid-19 vaccines: retrospective cohort study.” BMJ 380:e073747, March 1, 2023. https://pmc.ncbi.nlm.nih.gov/articles/PMC9975718/

[21] Federal Trade Commission. “Office Depot and Tech Support Firm Will Pay $35 Million to Settle FTC Allegations That They Tricked Consumers into Buying Costly Computer Repair Services.” March 27, 2019. https://www.ftc.gov/news-events/news/press-releases/2019/03/office-depot-tech-support-firm-will-pay-35-million-settle-ftc-allegations-th