On August 7, 2025, the Federal Trade Commission (“FTC”) announced a $45 million settlement with online lead generator MediaAlpha, Inc. and its subsidiary QuoteLab, LLC (collectively, “MediaAlpha”), resolving allegations that the companies misled consumers seeking health insurance products. According to the FTC, MediaAlpha tricked consumers into sharing sensitive personal information under the guise of offering health insurance options through their lead generation sites. MediaAlpha allegedly then used that data for abusive telemarketing, including calling numbers on the National Do Not Call Registry. The FTC also alleged that MediaAlpha auctioned off consumers’ information to third-party lead generators and telemarketers, who similarly used that data to make illegal telemarketing calls.

The FTC’s complaint alleges that MediaAlpha’s deceptive lead generation practices violated Section 5(a) of the FTC Act, the Telemarketing Sales Rule, and the FTC’s Government and Business Impersonation Rule (“Impersonation Rule”).

In an accompanying statement, Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection, emphasized the Commission’s commitment to addressing deceptive lead generation practices, stating that, “[c]oherently and systematically addressing unlawful lead generation is a priority for the FTC.”

Deceptive Collection of Consumers’ Personal Information

With this action, the FTC reaffirmed its focus on combating the deceptive collection of consumers’ personal information online. The FTC alleges that MediaAlpha violated Section 5 by deceptively collecting consumers’ personal information on its lead generation sites under the guise of purporting to sell them health insurance products. According to the complaint, MediaAlpha directed users to provide personal information so that MediaAlpha could provide them with health insurance quotes. The FTC contends that, in reality, MediaAlpha sells no health insurance products but instead auctions consumers’ personal information—including their contact details, zip code, household size, income, gender identity, pregnancy status, health history, and date of birth—to telemarketers and other lead generators, many of whom do not offer the health insurance products advertised by MediaAlpha.

False Government Affiliation Claims

This action also confirms the FTC’s interest in enforcing the Impersonation Rule by alleging that MediaAlpha misled consumers into believing it was connected to the federal government. The FTC’s Impersonation Rule prohibits materially false representations of government affiliation, endorsement, or sponsorship. Violations of the Rule allow the FTC to obtain consumer redress and civil penalties under Section 19 of the FTC Act, though the FTC is not seeking civil penalties in this action.

MediaAlpha’s allegedly unlawful tactics included disseminating videos featuring U.S. Presidents discussing healthcare, as well as lead generation websites with government-like domain names such as ObamacarePlans.com, GovernmentHealthInsurance.com, and Trump-Healthcare-Plans.com. The FTC also faulted a social media post from MediaAlpha’s account, @obamacareplans3088 that falsely claimed: “If you sign up today, the government will give you a full coverage policy for only $10/month, which includes FREE copays, FREE checkups, FREE treatments, and much more…. Click the link below & CALL RIGHT NOW!” The complaint also alleges that MediaAlpha spent millions to prominently place links to its lead generation sites in Google search results for terms like “Obamacare,” “marketplace insurance,” “Medicaid,” and “healthcare gov”—often appearing above the government’s own HealthCare.gov.

Fake Consumer Testimonials and Endorsements

The FTC also alleged that MediaAlpha used deceptive testimonials from paid actors and celebrities to promote non-existent health insurance products. One example involved a licensed medical professional appearing in a scripted, news-style video to endorse MediaAlpha’s products, including by encouraging viewers to visit MediaAlpha’s lead generation sites and even suggesting she recommended MediaAlpha’s services to her patients. The FTC alleged that MediaAlpha falsely presented the video as the medical professional’s independent, expert opinion and failed to disclose that the video was paid advertising, not actual news. The FTC also alleged that MediaAlpha created fake testimonials in which paid actors purported to be real consumers touting MediaAlpha’s purported low-cost insurance plans.

Abusive Telemarketing Acts and Practices

The FTC alleged that MediaAlpha violated the Telemarketing Sales Rule by making millions of unsolicited robocalls and calling over one million numbers listed on the National Do Not Call Registry since 2018. The FTC rejected MediaAlpha’s claim that consumers consented to these calls through hyperlinked advertiser lists on their websites. The FTC took the position that many consumers who provided their personal information to view health insurance plans or quotes were unaware that they were consenting to receive robocalls, telemarketing calls, text messages, and emails from thousands of potential sales agents. The complaint recounts consumer grievances, including one consumer who reported receiving 47 calls within one day and stated, “[T]his is harassment.” According to the complaint, many consumers who asked for the telemarketing calls to stop often continued to receive solicitations.

The FTC’s complaint further asserts that MediaAlpha violated the Telemarketing Sales Rule by furnishing substantial assistance or support to sellers and telemarketers engaged in illegal telemarketing practices. Specifically, the FTC claims that MediaAlpha either knew or deliberately ignored the fact that the third-party lead generators and telemarketers it supplied with consumer leads were making unsolicited robocalls and calling numbers listed on the National Do Not Call Registry—in direct violation of the Rule.

If you have any questions concerning the material discussed in this blog post, please contact the members of our Advertising and Consumer Protection Investigations practice.

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Photo of Laura Kim Laura Kim

Laura Kim draws upon her experience in senior positions at the Federal Trade Commission to advise clients across industries on complex advertising, privacy, and data security matters. She provides practical compliance advice and represents clients in FTC and State AG investigations. Laura advises…

Laura Kim draws upon her experience in senior positions at the Federal Trade Commission to advise clients across industries on complex advertising, privacy, and data security matters. She provides practical compliance advice and represents clients in FTC and State AG investigations. Laura advises on a wide range of consumer protection issues, including green claims, influencers, native advertising, claim substantiation, Made in USA claims, children’s privacy, subscription auto-renewal marketing, and other digital advertising matters. In addition, Laura actively practices before the NAD, including recent successful resolution of matters for both challengers and advertisers. She is the Chair of Covington’s Advertising and Consumer Protection Investigations Group and participates in the firm’s Internet of Things Initiative.

Laura re-joined Covington after a twelve-year tenure at the FTC, where she served as Assistant Director in two divisions of the Bureau of Consumer Protection, as well as Chief of Staff in the Bureau of Consumer Protection and Attorney Advisor to former Chairman William E. Kovacic. She worked on key FTC Rules and Guides such as the Green Guides, Jewelry Guides, and the Telemarketing Sales Rule. She supervised these and other rule making proceedings and oversaw dozens of the Commission’s investigations and enforcement actions involving compliance with these rules. Laura also supervised compliance monitoring for companies under federal court or Commission order.

Laura also served as Deputy Chief Enforcement Officer at the U.S. Department of Education, where she helped establish a new Enforcement Office within Federal Student Aid. In this role, she managed investigations of higher education institutions and oversaw issuance of fines and adverse actions for institutions in violation of federal student aid regulations. Laura also supervised the borrower defense to repayment division and the Clery campus safety and security division.

Photo of Jehan Patterson Jehan Patterson

Drawing from experience as a senior litigation counsel in the Office of Enforcement at the Consumer Financial Protection Bureau (CFPB) and in private practice, Jehan Patterson advises and represents clients on consumer protection matters, including issues relating to advertising, data privacy and security…

Drawing from experience as a senior litigation counsel in the Office of Enforcement at the Consumer Financial Protection Bureau (CFPB) and in private practice, Jehan Patterson advises and represents clients on consumer protection matters, including issues relating to advertising, data privacy and security, and financial services. She has represented banks, non-banks, and individuals in supervisory, enforcement, and rulemaking matters before the CFPB, the Federal Trade Commission (FTC), the Office of the Comptroller of the Currency (OCC), and the Federal Reserve Board of Governors (FRB).

While at the Bureau, Jehan investigated numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices, resulting in entry of administrative consent orders and federal district court judgments. Some of her notable settlements imposed extensive injunctive relief requiring entities to make significant investments in their technology systems and compliance programs to avoid future violations of law. Jehan coordinated on parallel matters with the United States Department of Justice and on enforcement investigations with states Attorneys’ General offices and state banking regulators. Among other matters, she led an investigation of a non-bank that culminated in a settlement joined by the Attorneys General of approximately 42 states and the District of Columbia.

Jehan also litigated on behalf of the Bureau, including representing the Bureau in its first advisory jury trial, obtaining a temporary restraining order and preliminary injunction to shut down a network of student loan debt relief companies and freeze their assets, and defeating a defendant’s motion for attorney’s fees and costs.

Photo of Alexandra Remick Alexandra Remick

Alexandra Remick is a member of the Advertising and Consumer Protection Investigations Group. Her practice focuses on regulatory and compliance matters related to consumer protection. She has experience advising clients on topics including endorsements, social media influencers, native advertising, automatically renewing subscriptions, consumer…

Alexandra Remick is a member of the Advertising and Consumer Protection Investigations Group. Her practice focuses on regulatory and compliance matters related to consumer protection. She has experience advising clients on topics including endorsements, social media influencers, native advertising, automatically renewing subscriptions, consumer reviews, and claim substantiation in a variety of contexts. She frequently provides advice on specific advertising compliance questions and works with companies on developing internal advertising compliance policies. She has also represented multiple clients in FTC investigations involving consumer protection issues, has conducted regulatory due diligence on multiple transactions, and has drafted comments on multiple rulemakings.

Photo of Carter McCants Carter McCants

Carter McCants specializes in advising clients on complex consumer protection matters.

Carter focuses her practice on the rapidly evolving field of consumer protection law and counsels clients across a broad array of industries, including media and technology, consumer products, live events, hotel and…

Carter McCants specializes in advising clients on complex consumer protection matters.

Carter focuses her practice on the rapidly evolving field of consumer protection law and counsels clients across a broad array of industries, including media and technology, consumer products, live events, hotel and lodging, and financial services. She regularly helps clients navigate critical legislative, regulatory, and compliance issues on topics such as advertising, claim substantiation, all-in pricing, consumer reporting, and automatic subscription renewals. Carter also represents clients in enforcement investigations before the Federal Trade Commission, Consumer Financial Protection Bureau, and State Attorneys General.