Protecting Public Health Amidst Data Theft, Sludge, and Dark Patterns: Overcoming the Constitutional Barriers to Health Information Regulations
Akron Law Review
Volume 56
Issue 2 Intellectual Property Issue
Article 1
2023
Protecting Public Health Amidst Data Theft, Sludge, and Dark
Patterns: Overcoming the Constitutional Barriers to Health
Information Regulations
Jon M. Garon
Follow this and additional works at: https://ideaexchange.uakron.edu/akronlawreview
Part of the Intellectual Property Law Commons
Please take a moment to share how this work helps you through this survey. Your feedback will
be important as we plan further development of our repository.
Recommended Citation
Garon, Jon M. (2023) "Protecting Public Health Amidst Data Theft, Sludge, and Dark Patterns:
Overcoming the Constitutional Barriers to Health Information Regulations," Akron Law Review: Vol.
56: Iss. 2, Article 1.
Available at: https://ideaexchange.uakron.edu/akronlawreview/vol56/iss2/1
This Article is brought to you for free and open access by Akron Law Journals at
IdeaExchange@UAkron, the institutional repository of The University of Akron in Akron, Ohio, USA.
It has been accepted for inclusion in Akron Law Review by an authorized administrator of
IdeaExchange@UAkron. For more information, please contact ,
.
Garon: Protecting Health Information
PROTECTING PUBLIC HEALTH AMIDST DATA THEFT,
SLUDGE, AND DARK PATTERNS: OVERCOMING THE
CONSTITUTIONAL BARRIERS TO HEALTH INFORMATION
REGULATION
Jon M. Garon *
Publicity is justly commended as a remedy for social and industrial
diseases. Sunlight is said to be the best of disinfectants; electric light the
most efficient policeman.
–– Justice Louis D. Brandeis**
Knowing is not enough; we must apply.
Willing is not enough; we must do.
–– Johann Wolfgang von Goethe
I.
II.
III.
Introduction ...................................................................... 180
Key Components and Vulnerabilities to the Health
Infosystem ........................................................................ 182
A. HIPAA Protected Information and Cyberattacks ...... 183
B. Personal Health Information Not Protected by HIPAA
187
C. The Exacerbating Threat of Misinformation and
Disinformation ........................................................... 194
Individual Autonomy in Health Care and Health
Information Versus the Threats of Sludge and Dark
Professor of Law and Director, Intellectual Property, Cybersecurity, and Technology Law program,
Nova Southeastern University Shepard Broad College of Law. Earlier versions of this paper were
presented at the Center for Intellectual Property Law & Technology annual IP Scholars Forum,
University of Akron School of Law (Dec. 2022) and the Thirteenth Annual Loyola Constitutional
Law Colloquium, cosponsored by Chicago Loyola and George Washington School of Law Nov.
2022). The author wishes to extend special thanks for insights and feedback from Mark F. Schultz,
Sandra Aistars, Mark A. Cohen, Alexandra George, Camilla Hrdy, Willajeanne McLean, Emily
Michiko Morris, Craig Nard, Cesar-Joel Ramirez-Montes, and Guy Rub.
** Louis D. Brandeis, What Publicity Can Do, HARPER’S WEEKLY 10 (December 20, 1913),
https://books.google.com/books?id=WktAQAAMAAJ&q=%22of+disinfectants%22#v=snippet&q=%22of%20disinfectants%22&f=fals
e [https://perma.cc/2SGE-SF5T].
*
179
Published by IdeaExchange@UAkron, 2023
1
Akron Law Review, Vol. 56 [2023], Iss. 2, Art. 1
180
AKRON LAW REVIEW
[56:179
Patterns. ............................................................................ 201
The FTC’s Role in Policing Unfair and Deceptive Trade
Practices ............................................................................ 210
V.
Limits on Health Care Information Reform: Commercial
Free Speech Jurisprudence ............................................... 222
VI. Regulating the User Experience ....................................... 229
VII. Reclaiming the Marketplace of Health information From
Disinformation .................................................................. 232
VIII. Conclusion ........................................................................ 238
IV.
I. INTRODUCTION
In 2017, popular health blogger Belle Gibson was fined $410,000
(Australian Dollars) for a campaign she perpetrated using her blog and
phone apps in which the young, vivacious blogger wrote about curing her
multiple forms of cancer, including an incurable brain tumor, by eating
whole foods. Gibson spun out her increasingly incredible story on her
blog, her fictionally autobiographical book entitled “The Whole Pantry,”
and an accompanying smartphone app. 1 As the prosecution for violations
of Australian consumer protection law determined, Gibson never suffered
from cancer. In addition, many of the financial claims she made were used
to defraud donors who thought they were contributing to the medical
expenses of other cancer victims. 2
A very different form of health care fraud was suffered by Anndorie
Cromar. 3 Her health care information was stolen and used by another
woman to receive maternity care. The imposter’s infant was born with
drugs in the baby’s system, leading to an intervention by child protective
services. Cromar, who had no idea that her identity was stolen, was
required to submit DNA evidence to exonerate her from the claims of
1. Elizabeth Pratt, Fake Blogs: Warnings About Medical Advice from Online ‘Experts’,
HEALTHLINE (Oct. 19, 2017), https://www.healthline.com/health-news/fake-blogs-warning-aboutmedical-advice-from-online-experts [https://perma.cc/BWA3-3TEZ]; Libby-Jane Charleston,
‘Health Guru’ Faker Belle Gibson Fined $410,000 For Lying About Cancer Cure, HUFFPOST (Sept.
27, 2017), https://www.huffpost.com/archive/au/entry/health-guru-faker-belle-gibson-fined-410000-for-lying-about-cancer-cure_a_23225383 [https://perma.cc/7SDM-3U8H].
2. See Charleston, supra note 1 (“Shortly after her book was released, it was revealed that
Gibson never had brain cancer, or any other disease. There were also many allegations that the
charities she claimed had received money, never received a cent.”).
3. See Michelle Andrews, The Rise of Medical Identity Theft, CONSUMER REPORTS (Aug. 25,
2016),
https://www.consumerreports.org/health/medical-identity-theft-a1699327549/
[https://
perma.cc/A4LE-D8FM].
https://ideaexchange.uakron.edu/akronlawreview/vol56/iss2/1
2
Garon: Protecting Health Information
2022]
PROTECTING HEALTH INFORMATION
181
child endangerment and retain the custody of her own four children. 4
Medical identity theft also led to the arrest of Deborah Ford. 5 Her purse
was stolen. She promptly reported the theft to police, cancelled her credit
card, and even had a new driver’s license issued. But over the next two
years, the medical insurance information stolen from her purse had been
used to purchase “more than 1,700 prescription opioid painkiller pills
through area pharmacies.” 6 Her compromised data was a link in the chain
supporting the nationwide opioid crisis and only her timely police report
kept her from being arrested as part of the massive fraudulent conspiracy.7
Hea (...truncated)