{"page":"/blog/telehealth-advertising-rules","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Case","Filed or announced","Order and court","Money","What the ad ban covers","Other duties","Source type"],"rows":[["GoodRx Holdings","Announced 1 February 2023","Order entered 17 February 2023, N.D. Cal. No. 23-cv-460 (89 FR 47028)","$1.5 million civil penalty (Gunderson)","Health data for advertising, permanently","Express consent for other sharing; ask recipients to delete; privacy program","Primary for court and date; secondary for terms"],["BetterHelp","Proposed order published 14 March 2023 (88 FR 15717)","Administrative consent order; final in July 2023 (secondary)","$7,800,000 consumer redress","Health information for advertising; any personal information for retargeting","Affirmative express consent; identify recipients and ask them to delete; notify pre-2021 users; assessments for 20 years","Primary (Federal Register)"],["Easy Healthcare (Premom)","Order entered 22 June 2023, N.D. Ill. No. 1:23-cv-3107 (89 FR 47028)","Second order under the breach rule","See our pixel enforcement timeline","Health data for advertising","Not re-verified for this page","Primary for court and date"],["Monument","Complaint 11 April 2024","Stipulated order filed the same day (Robinson+Cole, 9 May 2024)","$2.5 million penalty, expected to be waived for inability to pay (Choate)","Health information for advertising","Affirmative consent before other sharing","Secondary"],["Cerebral","Complaint 12 April 2024; order 15 April 2024 (Robinson+Cole)","Stipulated order","More than $7 million; a further $8 million suspended (Choate)","Personal and health information for most advertising, with no consent exception (Arnold & Porter)","Privacy and security program; biennial assessments; cancellation fixes","Secondary"]],"sourceUrls":[["https://www.federalregister.gov/documents/2024/05/30/2024-10855/health-breach-notification-rule","https://www.gunder.com/en/news-insights/insights/spotlight-on-recent-ftc-enforcement-actions-is-your-users-health-data-being-leaked-through-your-adtech"],["https://www.federalregister.gov/documents/2023/03/14/2023-05139/betterhelp-inc-analysis-of-proposed-consent-order-to-aid-public-comment"],["https://www.federalregister.gov/documents/2024/05/30/2024-10855/health-breach-notification-rule"],["https://www.dataprivacyandsecurityinsider.com/2024/05/federal-trade-commission-continues-to-target-healthcare-companies-for-unauthorized-data-disclosures/","https://www.choate.com/insights/ftc-seeks-significant-penalties-from-two-health-companies-alleging-misuse-of-consumer-personal-information/"],["https://www.dataprivacyandsecurityinsider.com/2024/05/federal-trade-commission-continues-to-target-healthcare-companies-for-unauthorized-data-disclosures/","https://www.choate.com/insights/ftc-seeks-significant-penalties-from-two-health-companies-alleging-misuse-of-consumer-personal-information/","https://www.arnoldporter.com/en/perspectives/blogs/enforcement-edge/2024/05/ftc-bans-health-information-for-advertising"]]}