Exploitable by Design: Social Media and the AdTech Threat

One way to conduct an online influence operation is to recruit a team of professional propagandists and engineers, build a vast network of fake social media accounts, plant a series of false or inflammatory narratives, and continuously collect intelligence to adjust the operation in real time. Another way is to buy some online ads and let large social media platforms do each of these things for you.

Most Americans are not primed to think of advertising as a national security concern. Instead, online advertising is a business and a very large one at that. Nearly $330 billion dollars will be funneled into online ads in 2026. By 2031, the market will climb to more than $500 billion.1 More than a third of this spending is concentrated in North America.2 American firms dominate this market, and American eyes are by far its most lucrative target. A single Facebook ad delivered to an American consumer is worth roughly twice as much as the same ad delivered to someone in the United Kingdom or Germany; nearly seven times that of someone in India.3

With so much money at stake, it is little wonder that the technology and infrastructure responsible for delivering these ads (“adtech”) is stuck in a perpetual arms race for human attention. The world of social media advertising, with which this article is principally concerned, is dominated by Meta, Google, to a lesser extent, X, and the awkwardly bifurcated ByteDance and “TikTok USDS Joint Venture LLC. Each of these entities must constantly engineer new ways to keep users glued to their services, incentivize at least a subset of users to constantly generate new content, and entice advertisers by exposing their users’ data in the most maximally intrusive and minimally compliant way possible.

Ironically, this is where the word “advertising” sells the whole thing short. Yes, one can use the most powerful behavioral targeting apparatus ever built to move endless dropshipped t-shirts or particle board furniture. But from the perspective of hostile foreign states, who have spent more than a decade engaged in information warfare campaigns against U.S. citizens and interests, social media adtech is not a way to make money.4 Instead, it is an obvious and exceptionally attractive weapon.

The United States has never permitted foreign governments such unfettered access to American information infrastructure. Yet today, and in sharp contrast with the active U.S. regulation of radio and television, social media companies have no legal obligation to disclose who is purchasing ads aimed at American citizens, nor to flag foreign-funded ad buys in real time. Indeed, their only real obligation is to periodically show up to be yelled at by the Congress and to promise, next time, to do better.

This regulatory weakness has nothing to do with the “unique” properties of the internet and social media, which are now older and better established than either the radio or television at the time that they were given their own basic regulatory regimes. Instead, it is a matter of money and power. Large social media companies have spent more than $250 million dollars since 2020 alone to sustain this total regulatory vacuum.5 In some cases, social media companies have worked to perpetuate this U.S. vulnerability even as they waged a years-long campaign to portray TikTok as a dire national security threat.6

What follows is an exploration of the machinery of social media advertising, the century-old norms it has been permitted to evade, and the hostile foreign intelligence operations that have sought to turn this machinery toward their own ends. There are clear precedents and ready proposals to close it. What is missing, as it has been for nearly thirty years, is political will.

An Invisible and Insatiable Machine

One surreal aspect of social media advertising is that, although at least half the world’s population is intimately familiar with it, its business model remains essentially invisible. Most social media users will see social media ads as an annoyance layered onto a communications platform, the same way that commercials interrupt a TV show. In reality, the advertisements are the product. The communications platform—whether an X doomscroll, an inscrutable Facebook newsfeed, or a short-form video treadmill of TikTok or YouTube Shorts—is just an inducement for users to hand over the data that makes the advertising work.7

This machine is insatiable by design. Somewhere around the early 2010s, social media companies collectively realized that the user data they were gathering to improve their products could also be bundled and sold to third parties. This is what media scholar Shoshana Zuboff describes as “behavioral surplus”: the vast residue of user activity that can be safely packaged for sale.8 Once companies came to rely on this data harvesting for revenue, metrics like user satisfaction, security, or even growth became secondary concerns.

The targeting that this data enables can be breathtakingly precise. Although Facebook is not the only platform of concern, it is the platform about which the most is known, and therefore the easiest point of reference. Advertisers using the Meta Ads Manager can upload a spreadsheet of email addresses or phone numbers to build a “Custom Audience” matched against the platform’s roughly three billion users.9 It takes only a few more clicks to generate a “Lookalike Audience” of hundreds or millions, inferred from shared page likes, ad interactions, social proximity, and numerous other tiny indicators that remain one of Meta’s most closely guarded secrets.

These audience groupings are automatic and occasionally quite embarrassing. In 2017, ProPublica found that Facebook had packaged “Jew haters” as a targetable advertising category, because enough users had listed it as an interest.10 Although social media platforms have since taken steps to prohibit obviously harmful or illegal audience segmentation (one cannot explicitly advertise to “Jew haters” today, just as one cannot advertise housing to only persons of color), the vastness of available data invites new kinds of malicious use. By combining thousands of different “proxy attributes,” it remains possible and profitable to target Americans on the basis of race, sexual orientation, or religion.11

These finely sliced ads are essentially invisible to anyone outside of their target audience. The industry term is “dark posts”: ads that appear only in the feeds of selected users, leave no trace on the advertiser’s public pages, and vanish once the campaign ends.12  On Facebook and Instagram, they are called “Unpublished Page Post Ads.”13 X, TikTok, and YouTube offer equivalent capabilities through their respective ad managers. In practice, an advertiser can serve dozens (or hundreds) of different ads to different audience segments without publicly appearing to run any ads at all.

Social media platforms do not like opening these systems to public scrutiny. After the 2016 U.S. election, Meta and Twitter both launched ad transparency archives. The subsequent decade has seen their hollowing out or abandonment. After Elon Musk acquired Twitter in 2023, the newly renamed X quickly gave up on its transparency tools, especially advertising disclosures. Meanwhile, Meta’s ads library seems obsolete by design. The tool reveals only when an advertisement is running. It is not possible to view old data or past campaigns, to see how an audience was selected, or to understand how different ads running at the same time may be targeting different groups of people.

Although Meta discloses more information about ads regarding “social issues, elections, or politics,” this is still a voluntary commitment bounded by inconsistently applied definitions.14 A 2019 investigation by my own Digital Forensic Research Lab found that Facebook allowed multiple ad buys from Chinese state television, intended to demoralize Americans about a potential trade war while never classifying them as “political” at all.15 Even when debated in good faith, the question of what constitutes a “social” ad can also be tremendously tricky. An ad promoting reproductive health is liable to meet the “social” threshold; an ad selling prescription birth control is not.16

Nonetheless, Meta may still be the most transparent of the bunch. Google waited until 2018 to launch its own advertising archive, which remains altogether less reliable and useful, revealing obvious sponsored content but not what videos are targeting certain user demographics. TikTok conspicuously avoided launching a real U.S.-focused ads transparency center, even when U.S. criticism of the platform had reached fever pitch.17

In all cases, this sluggishness is deliberate. The elements that make social media advertising so immensely lucrative—the precise audience identification and segmentation, the invisibility and untraceability—are directly at odds with any level of public disclosure. In this industry, transparency is always bad for business.

Used as Intended

Lack of transparency is hardly an impediment to the foreign intelligence operatives and state media apparatchiks who today seek to manipulate U.S. public opinion online. Since roughly 2012, when Iranian propagandists first used pseudonymous pages to push cartoons boosting Ron Paul’s longshot Republican bid, these information operations have grown dramatically in both volume and sophistication.18 So has foreign propagandists’ interest in using social media advertising to automate parts of their job.

The most infamous example of this occurred between 2015 and 2017, when Russian contractors spent around $100,000 to purchase roughly three thousand microtargeted Facebook ads, intended to draw Americans into a mishmash of fake pages that alternately promoted black liberation, secessionism, or the campaign of then candidate Donald Trump.19 Maryland received the most such ads, focusing on Baltimore and surrounding areas. One campaign cost 3,700 rubles (roughly $58) to promote a “Demand Justice for Freddie Gray” event at the Baltimore City Circuit Courthouse, purchased less than two months after Gray’s death.20 Those few confused citizens who did turn out soon dissipated after discovering neither basic structure nor leadership at the gathering. The Russians who orchestrated this operation, an operation that ultimately reached 11.4 million Americans in paid ads, did so as Facebook customers, not hackers. They simply used Facebook, in the words of Evgeny Morozov, “as it was always intended to be used.”21

Although Iran and China have used their own clandestine advertising to target Americans, they have also sought to harness the U.S. social media ecosystem to do the work for them.22 When Facebook purged one such Iranian network in 2018, it removed more than eighty pages, groups, and accounts that had posed as American liberals, much of their content aimed squarely at the sitting president. Iran has used ad tools to steer audiences in more than two dozen countries toward its state media apparatus, dodging U.S. sanctions in the process.23

During the 2019 Hong Kong protests, Chinese state outlets Xinhua and China Daily paid Twitter to promote dozens of tweets portraying the pro-democracy demonstrators as “violent” thugs showing “signs of terrorism.”24 This content included a crude cartoon of a protestor holding a Molotov cocktail in one hand and an American flag in the other. Facebook identified similar campaigns from Chinese state media targeting audiences across Hong Kong and Southeast Asia.25 The campaign was brazen enough for Twitter and Facebook to announce sharp limits on state media advertising.26 For many more years, however, Chinese state media remained free to build and propagandize to an audience via organic discovery.

While foreign propagandists’ exploitation of social media adtech is both normatively troubling and academically interesting, it is reasonable to ask how much this all matters. After all, the sum of clandestine ad spending by Russia, China, and Iran over the past decade almost certainly does not exceed $1 million dollars—roughly what the Coca-Cola Corporation spends on digital advertising every three hours.27 Moreover, social media’s role in political opinion formation remains largely unsettled. It is certainly not the case, as was sometimes insinuated in the aftermath of the 2016 election, that each American exposed to Russian propaganda had their beliefs shifted in some meaningful way. The overwhelming majority neither noticed nor cared.

But just as with social media users’ tendency to think of ads as an annoying interruption (instead of the product itself), it is altogether too kind to these companies to measure their platforms’ exploitation by foreign actors through direct ad purchases alone. The $100,000 that Russia spent on Facebook advertising between 2015 and 2017, for instance, was just one small piece of a customer acquisition strategy that involved tens of thousands of fake social media assets and which, at the end of its 194-week run, had reached the Facebook feeds of 126 million Americans.28 Along the way, Facebook was not just collecting rubles to serve Russian propaganda to U.S. citizens. It was also charging American companies to advertise alongside this Russian-fabricated content and tracking Americans’ engagement with the material to commodify and sell their data later.

Indeed, social media platforms’ business model means that they materially benefit from all sorts of foreign state exploitation, just as they provide these propaganda efforts with essential enabling infrastructure. This is the common thread that binds together episodes like “Spamouflage,” a massive influence network of at least 8,500 Facebook assets, linked to Chinese law enforcement and identified in 2024; a sprawling thirteen thousand-account anti-Ukraine TikTok network orchestrated by Russia and discovered in late 2023; and an Iran-directed Instagram spam campaign that flooded the Trump family with death threats after the January 2020 assassination of Iranian general Qassem Soleimani.29

In some cases, the sheer amount of cash that one can earn from commodifying American attention has led purely profit-motivated actors to adopt the same tools and tactics of these political propagandists. This is why, during the 2016 U.S. election, so many young men in North Macedonia took to operating mostly pro-Trump content mills, and why so many highly partisan and apparently American accounts on X are operated from Africa and Southeast Asia today.30

In each of these real or quasi-propaganda campaigns, social media companies sit at the center, profiting from every side of the transaction. They sell ads to help grow fake pages and accounts, sell more ads against the engagement that these assets generate, and monetize all the valuable “behavioral surplus” that these operations leave behind. These companies may be sincere in wanting to block this activity from their services, but unsurprisingly, they are also united in the belief that they and only they can address the problems unleashed by their own business models.

Recent Ancient History

This is a remarkable conceit and a largely ahistorical one. For most of the twentieth century, the United States treated the question of foreign access to American communications infrastructure as essentially settled. The answer, supplied by the active oversight of the U.S. government, was “no.” This answer stood even as the United States pioneered a standard of media freedom and individual speech rights that would become the envy of the world.

Indeed, when Secretary of Commerce Herbert Hoover convened the first National Radio Conference in 1922, his concern was not foreign propaganda but the medium’s commercial capture. “It is inconceivable that we should allow so great a possibility for service to be drowned in advertising chatter,” he told the assembled broadcasters.31 By 1925, Hoover was less concerned by the dominion of the advertisers than by the collusion of the “speechmakers” to the exclusion of everyone else from the air.32 Congress acted on this logic with the Radio Act of 1927, which created the Federal Radio Commission and established that broadcasters must operate in “the public interest, convenience, and necessity.” The Act included a blanket ban on foreign ownership of broadcast licenses, a provision that attracted no recorded opposition and has never been repealed.33

This prohibition was further codified by Section 310 of the Communications Act of 1934. No alien, no foreign corporation, and no entity with more than 20 percent foreign ownership could hold a broadcast license. The newly established Federal Communications Commission (FCC) was explicit about its task to “thwart the airing of foreign propaganda” by broadcast licensees who otherwise “exercise[d] editorial discretion over the content of their transmissions.”34 The Foreign Agents Registration Act (FARA) of 1938 extended a parallel logic to political advocacy on American soil, compelling foreign agents to disclose their activities and label their propaganda materials so that Americans would always know when they were being addressed by a foreign power.35

These basic radio and television regulations remain in place today. As recently as January 2026, the FCC unanimously voted to strengthen this framework, requiring every broadcast licensee in the United States to follow stringent new disclosure requirements for firms owned just 10 percent by entities in China, Russia, Iran, North Korea, Cuba, or Venezuela.36

Meanwhile, the most powerful broadcasting tools in world history remain wholly exempted from this or any other sort of meaningful regulation. Social media companies do not owe this privileged position to principled arguments or technical necessity. Instead, they have simply excelled at preventing regulation from being discussed at all.

Anything is Too Much

How did the internet get off so easy? The short answer is familiar to readers of this journal: a bipartisan consensus, forged in the Clinton administration and defended by Bush, Obama, and Trump in turn, held that the internet was fundamentally different than prior communications technologies and that its extraordinary potential might be smothered by any amount of state intervention. Section 230 of the Communications Decency Act immunized platforms from liability for user-generated content, while concurrent legal decisions found that private platforms were exercising First Amendment editorial discretion in whatever manner they chose to restrict the speech of their users. The Telecommunications Act of 1996 deregulated the broader industry, while the Federal Trade Commission would spend many years studiously avoiding any meaningful exercise of jurisdiction over digital advertising.37

Yet even the most committed internet exceptionalist might have expected the United States to require foreign governments to disclose their purchase of political advertisements on U.S. social media, and for these American companies to limit their instrumentalization by hostile state propagandists. But that did not happen either.

This, in essence, was all the Honest Ads Act proposed. Introduced in 2017 by Senators Amy Klobuchar, Mark Warner, and John McCain, the bill would have compelled digital platforms to follow the same disclosure requirements that have governed radio and television advertising since 1971.38 Online platforms with more than 50 million monthly visitors would maintain a public file of political ad purchases exceeding $500, including the identity of the purchaser. Foreign nationals would be explicitly prohibited from buying political ads, as they have long been prohibited from buying broadcast time. The bill was endorsed, at least in public, by Meta, Twitter, and Google.

Yet even this mildest of corrective measures has never become law or even survived a vote on the House floor. The Honest Ads Act was introduced in every Congress between 2017 and 2024, either as standalone legislation or as a component of broader reform packages.39 It quietly died each time.

The most straightforward explanation for this failure is money. In 2024 alone, Meta spent $24.4 million on federal lobbying and employed eighty-five registered lobbyists, roughly one for every six members of Congress.40 Through this intensive lobbying effort, social media platforms essentially strangled the Honest Ads Act while never wavering in their public support. Testifying before Congress in April 2018, Mark Zuckerberg publicly endorsed the bill, calling foreign interference, “a problem that’s bigger than anyone one platform.”41 Simultaneously, Meta lobbyists were working the phones to make sure it never got a vote.42 Meanwhile, the voluntary ads transparency measures announced by Meta, Twitter, and Google (and discussed earlier in this essay) enabled sympathetic lawmakers to declare that legislation was unnecessary in the face of effective self-regulation.

But self-regulation lasts only as long as the pressure does. Following Trump’s 2024 re-election, in which the threat of formal regulation was replaced with an ever-shifting mix of coercion and cajolement, the mask came off quickly. In the United States, it is considerably harder to identify foreign state propaganda activity on social media than it was a decade ago, with researchers stymied by poor data and increasingly obsolete transparency tools. Beyond U.S. borders, the situation is even more fraught. In July 2025, Meta decided to withdraw entirely from the European political ads market rather than comply with the European Union’s new political advertising disclosure requirements.43 Google went further, quietly deleting a database that researchers and journalists had relied upon to track foreign spending in twenty-seven EU countries.44

Yet the U.S. Congress works in mysterious ways. Although it failed to seed any effective regulations for the global communications revolution, nor to account for even very basic remedies to limit the threat of foreign interference, it did manage, very confusedly, to ban TikTok.

Double Standards or None

In January 2025, the Supreme Court unanimously upheld a law compelling TikTok to divest from its Chinese parent company, ByteDance, or face a ban in the United States.45 The Court found the government’s interest in preventing “a foreign adversary from collecting vast swaths of sensitive data about the 170 million U.S. persons who use TikTok” as sufficiently compelling to survive First Amendment challenge.  Yet the resulting deal, finalized in January 2026 at approximately $14 billion dollars, revealed how narrowly the threat had been defined. Even as American investors assumed ownership of the U.S. TikTok (TikTok USDS Joint Venture LLC), ByteDance would still control “e-commerce, advertising, and marketing” on the new platform.46 In other words, the systems that enable and incentivize foreign interference in the first place were essentially carved out.

Just as the TikTok deal was closing, Reuters obtained internal Meta documents revealing that the company had earned $18 billion dollars in advertising revenue from Chinese clients in 2024: 11 percent of its global income, more than doubling in just two years.47 Nearly a fifth of this revenue came from advertisements for scams, illegal gambling, and other content that violated Meta’s own policies. When an internal anti-fraud team threatened to create too much friction for Chinese advertisers, Mark Zuckerberg ordered it disbanded.

The bipartisan argument for banning TikTok, an argument driven partly by Meta lobbyists, was that a Chinese-owned platform capable of microtargeting Americans posed an unacceptable national security risk. But even as Congress worked to neutralize the theoretical threat of a Chinese-owned platform, Meta was collecting billions from Chinese clients who were already known to be exploiting their advertising infrastructure, all while avoiding scrutinizing their activities too closely, much less disclosing them in a proactive and transparent way.

This is the glaring contradiction at the heart of American internet policy. Congress determined, on a bipartisan basis, that a foreign-owned platform’s capacity to collect data on and aggregate content for American citizens constituted an intolerable threat to national security. Yet throughout this period, the U.S.-owned infrastructure through which Russia, China, and Iran had sought to manipulate American citizens for over a decade went essentially unconsidered. The Honest Ads Act, which would have extended the mildest version of a century-old broadcast disclosures to social media, never survived a vote in the House, while the TikTok ban sailed through both chambers.  TikTok—routing the data of 170 million Americans through a digital ecosystem ultimately answerable to Beijing—certainly did demand scrutiny. But if TikTok represented a severe national security threat, other U.S. companies do too.

We do not need novel remedies to address foreign state exploitation of social media. All we need, really, is a bit of consistency. The same disclosure requirements that have governed broadcast advertising since 1971 should be applied, with a few changes, to digital platforms. The ad transparency archives that Meta and Google built largely for show should be replaced by a public repository that no company can delete in a fit of pique. And more of us—especially those of us with very different political orientations and visions for the future of the country—should agree that these companies have given far too little while taking altogether too much from American public life.

These are either American companies with clear obligations to the American people, or they are stateless profit machines that deserve no special protections from American policymakers. They should not be permitted to have it both ways.

1 “Online Advertising Market Size, Share Analysis & Industry Research Report, 2031,” Mordor Intelligence, accessed June 2026.

2 Mordor Intelligence, “Online Advertising Market, accessed June 2026.

3 “Facebook CPM by Country,” Lebesgue, accessed June 2026.

4 P. W. Singer, Emerson T. Brooking, LikeWar: The Weaponization of Social Media (New York: Houghton Mifflin Harcourt, 2018).

5 Alix Fraser et al., “The Tech Money Machine: How Silicon Valley Buys Power — and Shapes Reality,” Tech Policy Press, May 22, 2025.

6 Taylor Lorenz, Drew Harwell, “Facebook Paid GOP Firm to Malign TikTok,” Washington Post, March 30, 2022.

7 Shoshana Zuboff, The Age of Surveillance Capitalism (New York: PublicAffairs, 2019).

8 Zuboff, The Age of Surveillance Capitalism, 75.

9 Naveen Kumar, “Facebook Users Statistics 2026 – Global Data & Growth Trends,” DemandSage, May 7, 2026.

10 Julia Angwin, Madeleine Varner, and Ariana Tobin, “Facebook Enabled Advertisers to Reach ‘Jew Haters,’” ProPublica, September 14, 2017.

11 Piotr Sapiezynski et al., “On the Use of Proxies in Political Ad Targeting,” arXiv, October 18, 2024.

12 Siva Vaidhyanathan, Antisocial Media: How Facebook Disconnects Us and Undermines Democracy (Oxford: Oxford University Press, 2018).

13 “Creating Facebook Unpublished/Dark Posts,” Brandwatch Help Center, February 2, 2026.

14 “Ads about Social Issues, Elections or Politics,” Meta, accessed June 2026.

15 Donara Barojan, “Made in China: Economic Influence Operations,” DFRLab, February 7, 2019.

16 Lisa Femia, “Decoding Meta’s Advertising Policies for Abortion Content,” Electronic Frontier Foundation, September 30, 2025.

17 Brandon Silverman, “How Transparent Is TikTok?” Some Good Trouble, March 16, 2023.

18 Ben Nimmo, et al., “Iran’s Broadcaster: Inauthentic Behavior,” Graphika, May 5, 2020.

19 Alex Stamos, “An Update on Information Operations on Facebook,” Facebook Newsroom, September 6, 2017.

20 John Fritze, “House Committee Releases Russian-Linked Ad Depicting Freddie Gray,” Baltimore Sun, November 1, 2017.

21 Evgeny Morozov, “Capitalism’s New Clothes,” The Baffler, no. 43 (January 2019).

22 FireEye Intelligence, “Suspected Iranian Influence Operation Leverages Network of Inauthentic News Sites & Social Media Targeting Audiences in U.S., UK, Latin America, Middle East,” FireEye, August 21, 2018; Billy Perrigo, “Exclusive: How a Chinese Influence Operation Spent $30,000 on U.S. Facebook and Instagram Ads,” Time, March 28, 2023.

23 Estimated from eight Meta attributions of Iranian campaigns, August 2018–March 2025. See: Emerson Brooking and Suzanne Kianpour, Iran’s Digital Influence Efforts: Guerrilla Broadcasting for the Twenty-First Century (Washington D.C.: Atlantic Council, 2020).

24 Ryan Mac and Rosalind Adams, “Have You Seen These Ads About Hong Kong’s Protests? China Certainly Hopes You Have,” BuzzFeed News, August 19, 2019.

25 Mac and Adams, “Have You Seen These Ads About Hong Kong’s Protests? China Certainly Hopes You Have,”.

26 Twitter Safety, “Information Operations Directed at Hong Kong,” Twitter Blog, August 19, 2019; Kate Conger, Raymond Zhong, “Facebook and Twitter Say China Is Spreading Disinformation in Hong Kong,” New York Times, August 20, 2019.

27 “Coca-Cola Co.—Ad Spending, Facts and Profile,” Ad Age, updated December 10, 2025.

28 Renée DiResta et al., “The Tactics & Tropes of the Internet Research Agency,” New Knowledge, prepared for the Senate Select Committee on Intelligence, December 17, 2018.

29 “Quarterly Adversarial Threat Report, Third Quarter 2023,” Meta, November 2023; Roman Osadchuk, “Massive Russian Influence Operation Targeted Former Ukrainian Defense Minister on TikTok,” DFRLab, December 14, 2023; DFRLab, “Tensions Escalate on Social Media Platforms after Soleimani’s Death,” DFRLab, January 4, 2020.

30 Heather C. Hughes, Israel Waismel-Manor, “The Macedonian Fake News Industry and the 2016 US Election,” PS: Political Science & Politics 54, no. 1 (January 2021); “Partisan US-Seeming Accounts Run from Africa and Southeast Asia,” BBC News, [date unverified].

31 Herbert Hoover, “Address to the First National Radio Conference,” U.S. Department of Commerce, February 27, 1922.

32 Herbert Hoover, “Address to the Fourth National Radio Conference,” U.S. Department of Commerce, November 9, 1925.

33 Mark Goodman, “The Radio Act of 1927 as a Product of Progressivism,” Media History Monographs 2, no. 2 (1999); Radio Act of 1927, Pub. L. No. 69-632, 44 Stat. 1162 (Feb. 23, 1927).

34 “Review of the Commission’s Regulations Governing Television Broadcasting; Market Entry and Ownership Rules,” Federal Communications Commission, NPRM, 10 FCC Rcd 4873 (1995), para. 99; “Review of Foreign Ownership Policies for Broadcast, Common Carrier and Aeronautical Radio Licensees under Section 310(b)(4) of the Communications Act of 1934, as Amended,” Federal Communications Commission, Report and Order, FCC 13-150 (2013).

35 Philip M. Taylor, Munitions of the Mind: A History of Propaganda from the Ancient World to the Present Era, 3rd ed. (Manchester University Press, 2003).

36 “Foreign Adversary Attestation and Disclosure Requirements,” Report and Order, FCC 26-3, Federal Communications Commission, January 29, 2026.

37 Tim Wu, The Master Switch: The Rise and Fall of Information Empires (New York: Alfred A. Knopf, 2010); Siva Vaidhyanathan, Antisocial Media: How Facebook Disconnects Us and Undermines Democracy (New York: Oxford University Press, 2018); Josh Hawley, The Tyranny of Big Tech (Washington, DC: Regnery Publishing, 2021).

38 Honest Ads Act, S. 1989, 115th Cong. (2017).

39 Mark R. Warner, Amy Klobuchar, and Lindsey Graham, “Warner, Klobuchar, Graham Reintroduce Honest Ads Act,” press release, U.S. Senate, February 27, 2023. The bill had been introduced in every Congress since the 115th (2017), originally co-sponsored by John McCain; Graham assumed McCain’s role following McCain’s death in 2018. Provisions were also incorporated into the For the People Act and Freedom to Vote Act. The bill was not reintroduced in the 119th Congress.

40 “Meta Platforms: Lobbying Profile, 2024,” OpenSecrets, accessed February 2026.

41 Mark Zuckerberg, testimony before the U.S. House Committee on Energy and Commerce, Facebook: Transparency and Use of Consumer Data, 115th Cong., 2nd sess., April 11, 2018.

42 Heather Timmons and Hanna Kozlowska, “Facebook’s Quiet Battle to Kill the First Transparency Law for Online Political Ads,” Quartz, March 22, 2018.

43 “Ending Political, Electoral and Social Issue Advertising in the EU,” Meta, July 25, 2025.

44 Samantha Cole, “Google Just Removed Seven Years of Political Advertising History,” 404 Media, November 26, 2024.

45 TikTok Inc. v. Garland, 604 U.S. ___ (2025) (per curiam), upholding Protecting Americans from Foreign Adversary Controlled Applications Act (PAFACA), Pub. L. 118-50, div. H (2024); Gorsuch, J., concurring in the judgment. U.S. Supreme Court, January 17, 2025.

46 David Shepardson, “TikTok Seals Deal for New US Joint Venture to Avoid American Ban,” Reuters, January 23, 2026.

47 Jeff Horwitz, Engen Tham, “Meta Tolerates Rampant Ad Fraud from China to Safeguard Billions in Revenue,” Reuters, December 15, 2025.