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 has a proven track record of successfully resolving clients’ most important consumer protection matters before the FTC, State AGs, and the NAD. She is well-known for her insider knowledge of the FTC as well as her practical approach to accomplishing her…

Laura Kim has a proven track record of successfully resolving clients’ most important consumer protection matters before the FTC, State AGs, and the NAD. She is well-known for her insider knowledge of the FTC as well as her practical approach to accomplishing her clients’ objectives.

As chair of Covington’s Advertising & Consumer Protection Investigations practice group, Laura represents corporate and individual clients in investigations before the FTC and State Attorneys General. She also provides pragmatic compliance advice on a wide range of consumer protection issues, including substantiating claims involving generative artificial intelligence, environmental benefits, and “Made in USA.” She counsels brands on emerging issues involving influencers, consumer reviews, AI-generated content, and subscription autorenewals. Laura regularly represents both challengers and advertisers before the NAD, achieving favorable outcomes in matters involving artificial intelligence, influencers, and claim substantiation.

During her twelve-year tenure at the FTC, Laura served as Assistant Director in two divisions of the Bureau of Consumer Protection, Attorney Advisor to Chairman William E. Kovacic, and Chief of Staff to Bureau Director Jessica Rich. She oversaw major rulemakings—including the Green Guides and the Telemarketing Sales Rule—and supervised dozens of investigations and enforcement actions. As Assistant Director in the Division of Enforcement, Laura also supervised compliance monitoring and enforcement proceedings for companies under federal court or Commission order.

Photo of Jehan Patterson Jehan Patterson

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection…

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.

Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.

Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into 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.

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.