June 26, 2019
By Email: press@google.com
&
First Class Mail
Jamie Rosenberg
VP, Business & Operations
Android & Google Play
Purnima Kochikar
Director
Google Play, Apps & Games
Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043
Re:

Removal of Political Social Media LLC’s Apps from Google Play

Dear Mr. Rosenberg and Ms. Kochikar:
Campaign for Accountability (“CfA”), a nonprofit watchdog organization, respectfully
requests that Google remove all apps developed by Political Social Media LLC from Google Play.
Political Social Media operates the brands, uCampaign, LLC and Jarbik, LLC, among others,
which operate approximately 12 nearly identical apps that appear to be violating the Google Play
Developer Distribution Agreement and Google’s Developer Program Policies.
Background
Political Social Media LLC was incorporated in Delaware on January 31, 2014. 1 The
company employs several brand names including uCampaign and Jarbik. 2 Through these brands,
the company operates several apps available for download in Google Play. 3 The company appears
to be violating the Google Play Developer Distribution Agreement and Google’s Developer
Program Policies by failing to provide adequate privacy policies, misusing users’ personal
1

Political Social Media LLC, Entity Details, Delaware Department of State, Division of Corporations, accessed at
https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx.
2
Laura Silver, The Apps For Ireland's Anti-Abortion Campaigns Allow User Data To Be Shared With The NRA,
BuzzFeed, May 22,2018, available at https://www.buzzfeed.com/laurasilver/ireland-anti-abortion-campaigns-appsprivacy-nra.
3
https://play.google.com/store/apps/developer?id=Jarbik;
https://play.google.com/store/apps/developer?id=uCampaign.

611 Pennsylvania Ave., S.E. #337  Washington, D.C. 20003  (202) 780-5750
campaignforaccountability.org

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 2
information, and building template apps and submitting them to Google Play on behalf its client
organizations.4
The apps operated by Political Social Media target political conservatives. 5 For instance,
through the uCampaign brand, the company runs the official app for the pro-gun organization, the
National Rifle Association (“NRA”), and the anti-abortion groups, Susan B. Anthony List (“SBA
List”) and Family Research Council (“FRC”).6 The company also operates the official app for
President Trump’s campaign committee and the app for the Great America PAC, a super PAC that
supports President Trump.7 Additionally, uCampaign runs an app the Conservative Party of
Canada and the Australian Christian Lobby. 8
Jarbik runs an app for the Generation Atomic, an advocacy organization that supports
nuclear energy, and has managed apps for several international political movements, including a
nationalist party in Malta and an anti-abortion group in Ireland. 9
Political Social Media’s apps for each of these organizations are virtually identical. 10 The
company sets up a boilerplate social media platform that is branded for each of its client
organizations.11 The apps draw in supporters of those organizations who use them to chat with
each other and post comments on in-app newsfeeds. The apps also offer games and challenges for
users to play and receive rewards. 12 The app descriptions suggest users can use the apps to stay
up to date on the latest news about each client organization or candidate. 13
The apps generate value for sponsoring organizations by leveraging the contacts of their
users.14 Political Social Media prods users to turn over their address books and other identifying
information to the app developers upon signing up.15 The company then encourages users to send

4

https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html;
https://play.google.com/about/developer-content-policy/.
5
https://play.google.com/store/apps/developer?id=uCampaign.
6
https://play.google.com/store/apps/details?id=com.ucampaignapp.nra;
https://play.google.com/store/apps/details?id=com.ucampaignapp.sba;
https://play.google.com/store/apps/details?id=co.ucampaign.frc.
7
https://play.google.com/store/apps/details?id=com.ucampaignapp.americafirst;
https://play.google.com/store/apps/details?id=com.ucampaignapp.gap.
8
https://play.google.com/store/apps/details?id=co.ucampaign.cpc;
https://play.google.com/store/apps/details?id=com.ucampaignapp.acl.
9
https://play.google.com/store/apps/details?id=com.ucampaignapp.gna; Silver, BuzzFeed, May 22, 2018;
https://appadvice.com/game/app/pn-malta/1232401367.
10
Emma Hinchliffe, A Four-person Company is Behind the Apps of Donald Trump, the NRA and Other Conservative
Groups, Mashable, October 7, 2016, available at https://mashable.com/2016/10/07/ucampaign-conservative-apps/.
11
Silver, BuzzFeed, May 22, 2018.
12
https://play.google.com/store/apps/developer?id=uCampaign.
13
Id.
14
James Vincent, Ted Cruz's app turns handing over your friends' contact info into a game, The Verge, November 11,
2015, available at https://www.theverge.com/2015/11/11/9711364/ted-cruz-campaign-app-gamification.
15
The NRA app, for instance, asks users to share their location when they register.

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 3
messages to everyone in their address books, which benefits the sponsors. 16 Even if users do not
turn over their address books when they register, the apps regularly incentivize users to share their
contacts. The NRA app, for instance, requires users to obtain 250 action points in order to post a
comment on the platform. Users can obtain points by sharing the app with their friends or allowing
the app to track their location, among other methods. BuzzFeed reported in May 2018 that some
of the Political Social Media’s apps previously required users to turn over their contact information
in order access the apps’ main features.17
Political Social Media founder Thomas Peters explained the app’s method in a blog post
discussing how his company helped Sen. Ted Cruz (R-TX) win the 2016 Iowa caucuses:
As a phone app it has authorized access to a supporter’s phone address book
contacts. That allows it to match those contacts to Cruz’s voter universes and
prompt existing supporters to reach out personally to identified potential supporters.
To date the feature has matched over a third of a million potential supporters
who are contacts of one or more of the app’s current supporters.
The second source of data are self, individual friend and neighborhood surveys.
App supporters have completed over 20,000 political ID surveys about themselves,
their friends and their neighbors, generating valuable cross-section data on the
supporters’ political views, activism affinities and personal network, essential
information for a modern, data-driven campaign. 18 (emphasis in original)
Political Social Media uses this information to send political messages to the friends and
family of an app’s users.19 uCampaign boasted about the success of this model in a description of
its apps on the NationBuilder website:
We follow the 80/20 rule - take your top 20% of supporters who will perform 80%
of the actions and give them a smartphone app that allows them to do 10X more
than what they would do on a website, while creating valuable data which is
automatically synced to your Nation. Our platform allows you to manage your app
once we have collaborated to build and launch it. We offer advanced features
such as matching your supporters’ phone address book contacts to voter files
and big data as well as crowdsourcing grassroots activities like text messaging and
fundraising to your supporters. Match your supporters to their state and federal
elected officials using geolocation to make lobbying seamless. Our clients include
16

Natasha Singer and Nicholas Confessore, Republicans Find a Facebook Workaround: Their Own Apps, The New
York Times, October 20, 2018, available at https://www.nytimes.com/2018/10/20/technology/politics-appsconservative-republican.html.
17
Older versions of the Android operating system required apps to seek these permissions from users when they
downloaded the app. The most recent version of Android allows apps to obtain users’ permission after installing the
app. See https://developer.android.com/guide/topics/permissions/overview?hl=en; Silver, BuzzFeed, May 22, 2018.
18
Thomas Peters, We Are the Stealth Startup that Helped Ted Cruz Win Iowa, Medium, February 4, 2016, available
at https://medium.com/@uCampaignCEO/meet-the-stealth-startup-that-helped-ted-cruz-win-iowa-fea6745b8a6d.
19
Singer and Confessore, The New York Times, Oct. 20, 2018.

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 4
local, state, federal, presidential, international, advocacy and referendums.20
(emphasis added)
The Nationbuilder description also reveals the scale of the privacy problem: for every
person that downloads the app, the app can identify 34 possible supporters of an organization. 21
Misusing Personal Information
While Political Social Media has received glowing media profiles for ingeniously
leveraging users’ contact data, the company’s political activities have been scrutinized by
government investigators.22 For instance, in 2016 uCampaign developed an app for the Vote
Leave campaign, which advocated for Great Britain to leave the European Union. 23 A
parliamentary committee tasked with investigating the campaign specifically cited the “data
privacy concerns raised” by uCampaign’s app.24
Additionally, Political Social Media drew widespread criticism for misusing its users’ data
during the 2016 presidential election. For instance, NBC News reported:
Immediately after installation, the app requests access to users’ address books; app
creator Thomas Peters, CEO of uCampaign, said this is to help users share the app
with their friends. But the app’s privacy policy says the campaign can use that data
— the names, emails, home addresses and more stored in a user’s address book —
however they’d like.
“Trump’s [app] is at a whole other level,” explained the American Civil Liberties’
Nicole Ozer. “It’s not just to pay with your privacy, but to sell out your friends and
colleagues who are in your contact list.”25
Indeed, Business Insider reported in November 2016:
If users download the app and agree to share their address books, including phone
numbers and emails, the app then shoots the data [sic] a third-party vendor, which
looks for matches to existing voter file information that could give clues as to what
may motivate that specific voter. Thomas Peters, whose company uCampaign
created Trump's app, said the app is “going absolutely granular,” and will — with
20

https://nationbuilder.com/ucampaignupdate.
Id.
22
Hinchliffe, Mashable, Oct. 7, 2016.
23
Mark Scott, Politicians Follow in Facebook’s Footsteps on Mass Data Collection, Politico, April 8, 2018, available
at https://www.politico.eu/article/facebook-cambridge-analytica-data-protection-privacy-brexit-trump-vote-leaveucampaign/.
24
Disinformation and ‘Fake News’: Interim Report, Digital, Culture, Media, and Sport Committee, United Kingdom
House
of
Commons,
July
29,
2018,
Chapter
3,
available
at
https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/363/36306.htm.
25
Jane C. Timm, Trump’s New App Wants You – And Your Data, NBC News, August 31, 2016, available at
https://www.nbcnews.com/politics/2016-election/trump-s-new-app-wants-you-your-data-n640236.
21

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 5
permission — send different, A/B tested messages to users' contacts based on
existing information.26
Alarmingly, though, a 2018 version of the company’s privacy policy stated that the
company “may share your personal information with other organizations, groups, causes,
campaigns, political organizations, and our clients that we believe have similar viewpoints,
principles or objectives as us.”27 As BuzzFeed reported:
This means data can be shared…with previous clients such as the NRA, the Trump
presidential campaign, the Republican National Committee, and the Susan B.
Anthony List, a major US anti-abortion group. In the UK, the network includes the
Conservative Party and main pro-Brexit campaign, Vote Leave. 28
Political Social Media’s Privacy Policies
Political Social Media’s apps can access users' precise location, camera, calendars, and
contacts if users give them permission.29 Of the 12 apps currently available for download from
Political Social Media, 10 of them, including the apps for the NRA, the SBA List, and FRC, have
identical privacy policies. Notably, the privacy policies listed in the app are not found on the
websites of the sponsoring organizations themselves. Instead, using Google Play, all of these apps
link to privacy policies on websites operated by Jarbik, uCampaign, or RumbleUp, another brand
that belongs to Political Social Media.30 The policy – common to all Political Social Media brands
– provides:
As noted above, we share your Personal Information with the uCampaign client
that administers the Client Application that you use. Except as otherwise set forth
in this Privacy Policy, we do not share your information with other third parties,
nor do we share information between uCampaign clients. 31
This policy gives the company wide latitude to share personal information of its users:
We may, with your permission, collect third party contact information (including,
without limitation, names, telephone numbers, emails and social media handles, if
available) from your mobile address book.

26

Maxwell Tani, Donald Trump’s Campaign is Using the Same Ap[p the ‘Leave’ Campaign Used During Brexit to
Spur Voter Turnout, Business Insider, November 7, 2016, available at https://www.businessinsider.com/donaldtrumps-phone-app-brexit-2016-11.
27
Silver, BuzzFeed, May 22, 2018.
28
Id.
29
https://reports.exodus-privacy.eu.org/en/reports/29364/.
30
The following apps provide their own privacy policies: Atomic Action, Australian Christian Lobby, Australian
Conservatives, Diabetes Patient Advocacy Coalition, and the Great America PAC.
31
http://letsw.in/privacy.html.

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 6
We may receive Personal Information about you from other users of the Platform.
This may happen if they connect their address books to our services, or if they invite
you to use our services via the Platform. Additionally, we may also receive Personal
Information about you from the uCampaign client administering the Client
Application. If you have received a text message through our services, your
information was uploaded to the Platform through the uCampaign client that
contacted you. We will treat all such Personal Information in accordance with this
privacy policy.
We may share your Personal Information with other entities affiliated with us for
internal reasons, primarily for business and operational purposes. uCampaign, or
any of its assets, including the Platform, may be sold, or other transactions may
occur in which your Personal Information is one of the business assets of the
transaction. In such case, your Personal Information may be transferred. 32
(emphasis added)
The privacy policy for Political Social Media’s apps allows the developer to collect the
personal information of individuals who received text messages from an app’s users, even if the
recipient did not download one of the company’s apps. Political Social Media does not provide
message recipients with an opportunity to consent to this data collection. 33
While the company has removed the alarming language that BuzzFeed highlighted, the
current policy still allows the company to share users’ information with anyone “affiliated with
us.” Presumably, the company can rely on this policy to share users’ data with any of the clients
that use its apps. The policy further states:
Information about your use of the Platform as an end-user will also be available to
the uCampaign client that is administering the Client Application. For more
information about this uCampaign client’s privacy practices, please refer to the
client’s privacy policy.34
The instruction to refer to “the client’s privacy policy” is futile. Ten of Political Social
Media’s apps, including those of FRC and SBA List, do not, in fact, provide a link to the client’s
privacy policy. Beyond the app, the SBA List’s own website does not even include a link to its
privacy policy.35 The only way to find the SBA List’s organizational privacy policy is through an
outside search engine. And even then, the available policy applies only to the organization’s
website; there is no reference to the Political Social Media app. 36 Similarly, FRC’s privacy policy
does not provide any information about its app.37
32

Id.
As noted below, this is a violation of Google’s Developer Program Policies which states that Google doesn’t allow
“unsolicited promotion via SMS services.” See https://play.google.com/about/storelisting-promotional/.
34
https://ucampaignapp.com/privacy.html.
35
https://www.sba-list.org/about-susan-b-anthony-list.
36
https://www.sba-list.org/privacy-policy.
37
https://www.frc.org/privacy-policy.
33

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 7
Google Play Developer Distribution Agreement
Privacy
Google provides developers with a wealth of information regarding how to build apps for
Android and Google Play. Repeatedly, Google emphasizes the requirement that app developers
protect users’ privacy. For instance, the Google Play Developer Distribution Agreement states:
You agree that if You make Your Products available through Google Play, You
will protect the privacy and legal rights of users. If the users provide You with, or
Your Product accesses or uses, usernames, passwords, or other login information
or personal information, You agree to make the users aware that the information
will be available to Your Product, and You agree to provide legally adequate
privacy notice and protection for those users. Further, Your Product may only
use that information for the limited purposes for which the user has given You
permission to do so.38 (emphasis added)
Despite the agreement, Political Social Media does not provide an “adequate privacy
notice” for its users. For 10 of the 12 apps offered by Political Social Media, the only privacy
policy included is that for Political Social Media’s companies.
Moreover, Political Social Media’s privacy policy states:
You have the right to access your Personal Information held by us and, if necessary,
have it amended or deleted. You can also request not to receive email
communications and/or other marketing information from us. 39
For most of the apps, though, the only contact information listed is for uCampaign or
Jarbik. There is no contact information for the client organizations benefitting from the apps
and, presumably, storing users’ information. As a result, users cannot have confidence that their
data will be deleted by all of the parties that obtain their personal information.
40

Personal Information
Beyond the privacy policy, the Google Play Developer Distribution Agreement explains
that developers must not misuse the personal information of their users. The Privacy, Security,
and Deception section of Google’s Developer Program Policies states:
You must be transparent in how you handle user data (e.g., information collected
from or about a user, including device information). That means disclosing the
collection, use, and sharing of the data, and limiting the use of the data to the
purposes disclosed, and the consent provided by the user. In addition, if your app
38

https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.
https://ucampaignapp.com/privacy.html.
40
Id.; https://jarbik.com/privacy.html.
39

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 8
handles personal or sensitive user data, please also refer to the additional
requirements in the “Personal and Sensitive Information” section below. 41
And:
Personal and sensitive user data includes, but isn't limited to, personally identifiable
information, financial and payment information, authentication information,
phonebook, contacts SMS and call related data, microphone and camera sensor
data, and sensitive device or usage data. If your app handles sensitive user data,
then you must:





Limit your collection and use of this data to purposes directly related to
providing and improving the features of the app (e.g. user anticipated
functionality that is documented and promoted in the app's description).
Post a privacy policy in both the designated field in the Play Console and
within the app itself. The privacy policy must, together with any in-app
disclosures, comprehensively disclose how your app collects, uses, and
shares user data. Your privacy policy must disclose the type of parties to
which any personal or sensitive user data is shared.
Handle all personal or sensitive user data securely, including transmitting it
using modern cryptography (for example, over HTTPS).42

An example of a “common violation” is:
An app that accesses a user's phone or contact book data and doesn't treat this data
as personal or sensitive data subject to the Privacy Policy, Secure Transmission,
and Prominent Disclosure requirements.43
The policy also provides that if an “app handles non-public phonebook or contact information,”
Google does not “allow unauthorized publishing or disclosure of people's non-public contacts.” 44
Additionally, Google’s Unwanted Software Policy states:
We’ve found that most unwanted software displays one or more of the same basic
characteristics: It collects or transmits private information without the user’s knowledge. 45
The Developer Program Policies also prohibit apps from using a person’s contacts to
promote an app. The Store Listing and Promotion section states:

41

https://play.google.com/about/privacy-security-deception/personal-sensitive/.
Id.
43
Id.
44
Id.
45
https://www.google.com/about/unwanted-software-policy.html.
42

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 9
We don’t allow apps that directly or indirectly engage in or benefit from promotion
practices that are deceptive or harmful to users or the developer ecosystem. This
includes apps that engage in the following behavior:
Unsolicited promotion via SMS services. 46
Despite the clear prohibitions, Political Social Media appears to be flagrantly violating the
Google Play Developer Distribution Agreement and Google’s Developer Program Policies by
failing to appropriately handle the personal information of its users. As Political Social Media has
stated publicly, the purpose of its apps is to collect contact information from its users in order to
deliver messages from its clients to their contacts at scale. 47 As Political Social Media
acknowledged on Nationbuilder, its apps “Identify on average 34 individuals per supporter who
downloads the app and generate up to 28 new ways to contact these individuals.” 48
Permissions
Previously, Political Social Media required users to turn over their phonebook and location,
among other things, in order to access most of an app’s features. 49 Previous versions of the
Android operating software required users to grant or deny permissions to an app before installing
it.50 The most recent version of Android, however, allows users to grant or deny permissions after
installing an app, providing users with more control over their personal information. 51 Still,
Google makes clear that developers may not abuse permissions granted by users. For instance,
the Google Play Developer Distribution Agreement states:
You are responsible for uploading Your Products to Google Play, providing
required Product information and support to users, and accurately disclosing the
permissions necessary for the Product to function on user Devices. 52
The permissions section of Google’s Developer Program Policies states:
Permission requests should make sense to users. You may only request permissions
that are necessary to implement critical current features or services in your
application. You may not use permissions that give access to user or device data
for undisclosed, unimplemented, or disallowed features or purposes. 53
And:

46

https://play.google.com/about/storelisting-promotional/.
https://nationbuilder.com/ucampaignupdate.
48
Id.
49
Silver, BuzzFeed, May 22, 2018.
50
https://developer.android.com/guide/topics/permissions/overview?hl=en.
51
Id.
52
https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.
53
https://play.google.com/about/privacy-security-deception/permissions/.
47

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 10
Apps may only use the permission (and any data derived from the permission) to
provide approved critical core app functionality (e.g. critical current features of the
app that are documented and promoted in the app's description). You may never
sell this data. The transfer, sharing, or licensed use of this data must only be for
providing critical core features or services within the app, and its use may not be
extended for any other purpose (e.g. improving other apps or services, advertising,
or marketing purposes). You may not use alternative methods (including other
permissions, APIs, or third-party sources) to derive data attributed to the above
permissions.54
The developer guide for Android states:
In some circumstances, you want to help the user understand why your app needs
a permission. For example, if a user launches a photography app, the user probably
won't be surprised that the app asks for permission to use the camera, but the user
might not understand why the app wants access to the user's location or contacts.
Before your app requests a permission, you should consider providing an
explanation to the user.55
The developer guide also states:
Only use the permissions necessary for your app to work. Depending on how you
are using the permissions, there may be another way to do what you need (system
intents, identifiers, backgrounding for phone calls) without relying on access to
sensitive information.
And:
Be transparent. When you make a permissions request, be clear about what you’re
accessing, and why, so users can make informed decisions. Make this information
available alongside the permission request including install, runtime, or update
permission dialogues.
The developer guide also states that apps will only be allowed on Android if:
The app requests only the absolute minimum permissions that it needs to support
core functionality.
And:

54
55

Id.
https://developer.android.com/training/permissions/requesting.html?hl=en.

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 11
The app does not request permissions to access sensitive data (such as Contacts or
the System Log) or services that can cost the user money (such as the Dialer or
SMS), unless related to a core capability of the app. 56
Political Social Media’s apps, however, do not abide by these standards. As the
company has made abundantly clear throughout its marketing materials, the purpose of its
apps is to convince users to turn over their contact information for the benefit of the
sponsoring organizations. Political Social Media entices users to enjoy its platform and
play the games in order to get access to the phonebooks of its users. Political Social
Media’s apps, therefore, are a prima facie violation of the Google Play Developer
Distribution Agreement.
Template Apps
Google’s Developer Program Policies also prohibit Political Social Media’s template
model. The guidelines regarding “repetitive content” state:
We don't allow apps that merely provide the same experience as other apps already on
Google Play. Apps should provide value to users through creation of unique content or
services.57
Google offers examples of common violations:
Copying content from other apps without adding any original content or value.
Creating multiple apps with highly similar content and user experience. If these apps are
each small in content volume, developers should consider creating a single app that
aggregates all the content.
Apps that are created by an automated tool, wizard service, or based on templates and
submitted to Google Play by the operator of that service on behalf of other persons are not
allowed. Such apps are only permissible if they are published by an individually registered
developer account belonging to the user of the automated tool, not the operator of the
service.58
Nevertheless, Political Social Media is publishing nearly identical template apps for each
of its clients and submitting them to Google Play using its own developer account, instead of each
client, including FRC and SBA List -- submitting its own app as Google requires. 59 As
TechCrunch reported, Google’s policy was rewritten to address this exact problem. 60
56

https://developer.android.com/docs/quality-guidelines/core-app-quality.
https://play.google.com/about/spam-min-functionality/spam/repetitive-content/.
58
Id.
59
Sarah Perez, Google Follows in Apple’s Footsteps by Cleaning Up Its Play Store, TechCrunch, July 27, 2018,
available at https://techcrunch.com/2018/07/27/google-follows-in-apples-footsteps-by-cleaning-up-its-play-store/.
60
Id.
57

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 12
Unfortunately, Google has yet to remove Political Social Media’s apps from Google Play
despite the company’s clear violation of this policy. The fact that the official apps for two
controversial advocacy organizations, FRC and SBA List, are nearly identical and published by
Political Social Media highlights the problem with failing to implement this rule.
Enforcement
The Google Play Developer Distribution Agreement states:
If Google becomes aware and determines in its sole discretion that a Product or any portion
thereof (a) violates any applicable law; (b) violates this Agreement, applicable policies, or
other terms of service, as may be updated by Google from time to time in its sole discretion;
(c) violates terms of distribution agreement with device manufacturers and Authorized
Providers; or (d) creates liability for or has an adverse impact on Google or Authorized
Providers; then Google may reject, remove, suspend, or reclassify the Product from Google
Play or from Devices. Google reserves the right, at its sole discretion, to suspend and/or
bar any Product and/or Developer from Google Play or from Devices. 61
Here, it is clear that Political Social Media’s apps violate the Google Play Developer Distribution
Agreement and should be removed from Google Play.

61

https://play.google.com/intl/ALL_us/about/developer-distribution-agreement.html.

 Mr. Rosenberg and Ms. Kochikar
June 26, 2019
Page 13
Conclusion
Previously, Google has revoked access to apps that violate the company’s rules. Yet here,
Google has failed to act despite clear evidence that Political Social Media and, to a lesser extent,
FRC and SBA List and others by failing to submit their own apps, are in violation of the Google
Play Developer Distribution Agreement. Further, beyond simply violating the rules, Political
Social Media’s apps have been investigated by United Kingdom government regulators and
criticized by privacy advocates. At a time when democracies are struggling to cope with and
confront the ever-increasing onslaught of misleading information filtered through social media,
Google should remove these apps from Google Play to ensure users have access to rule-abiding
apps that share legitimate information.
Sincerely,

Daniel E. Stevens
Executive Director

Alice C.C. Huling
Counsel