by Jeff Sovern
Here. The 22 words consists of the following statement, to appear on Facebook's help page:
“We use tools to identify and store links shared in messages, including a count of the number of times links are shared.”
As a general matter, I am skeptical of settlements that provide only a disclosure on a web site, given the evidence indicating that consumers often fail to read disclosures. I haven't dived into the documents for this case, so perhaps this is reported in them, but it would be interesting to know what percentage of Facebook members have clicked on the help page which is to contain the disclosure; how much time the page is open for on their computers; how many words appear on it (those last two items should enable a determination of how many people have the page open long enough to read the information on the help page); and whether the proposed disclosure has been tested on consumers to determine if they can understand it.