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Investigation Process

Sliding Scale of Engagement

If IDAC has enough evidence to believe that a developer is violating a law, regulation, or platform terms of service, IDAC intervenes along a sliding scale of engagement based on how severe the violation is and how widespread the harm is.

There are multiple ways IDAC works with platforms, developers, and law enforcement throughout the investigations process, including:

  1. Requests for information from developers. We will initially engage with developers to gather more information and ensure our findings are accurate. In many cases, we resolve the issue directly with the developer without the need to engage with platforms or law enforcement. In the instances where developers cooperate with us and take remedial action to fix issues we identified, we may report what we found without specifically naming the developer in question in our “Dogs That Don’t Bark” series.

  2. Requests for information from the platform. When we have reasonable suspicion that misconduct is occurring and are unable to gather information directly from a developer, IDAC may request further information from a platform. The platforms are better situated to provide IDAC with more information about a developer on its platform.

  3. Referring cases to platforms and law enforcement. In more serious cases, when IDAC believes there is a violation of laws, regulations, or platform terms and/or when IDAC believes there is ongoing harm to the public, IDAC will bring the concern to the attention of platforms and law enforcement authorities such as the Federal Trade Commission or an Attorney General.