Consent Farm Predators
How Citizens Disability tricked disabled and low-income Americans into accepting millions of illegal robocalls — using fake coupon sites, phony sweepstakes, and 290-company fine-print traps — then lied about why they were calling.
Between just May 1 and June 30, 2019 — a single two-month window — Citizens Disability and its agents launched over 46 million phone calls as part of one robocall campaign alone, targeting people who had never asked to be called and had no idea a disability advocacy company even knew their name.
The Non-Financial Ledger: What This Really Cost Real People
Think about what it means to be 55 years old, disabled, struggling to figure out whether you qualify for Social Security benefits, and your phone rings. A voice that sounds human — her name is “Amber” — tells you that she’s calling because she can see you recently asked about your eligibility. You feel a flicker of relief. Someone is following up. Someone is paying attention. You start answering questions. You give them your Social Security number. Your date of birth. Your medical history. Your employment record. And none of it was real. Amber was a prerecorded bot. The “recent inquiry” she referenced never happened. Citizens Disability’s agents invented it to get you talking.
This is the specific population Citizens Disability targeted: Americans between 50 and 64, unemployed, living with disabilities, not yet receiving benefits, and without a lawyer. These are people already navigating one of the most confusing and humiliating bureaucratic processes in American life — the Social Security Disability system — where most first applications get denied and the appeal process can drag on for years. Citizens Disability saw a vulnerable population and built an industrial-scale phone harassment operation around it.
One person. Fifty-five calls. Over two and a half years. The DOJ complaint documents this as a factual data point, almost casually. But behind that number is a human being — someone dealing with a disability, already stressed, already fighting a government system, who picked up or ignored the same robocall operation fifty-five separate times. That is not a marketing error. That is a sustained campaign of harassment directed at a person who had done nothing wrong except exist in a demographic that Citizens Disability found profitable.
The consent farm system Citizens Disability built was architected specifically to exploit the trust of people who don’t have lawyers, don’t read fine print, and are genuinely excited about the idea of free coupons or a $50,000 sweepstakes win. The company purchased leads from websites like CouponQlik.net and Super-Sweepstakes.com. These sites hid telemarketing consent language in tiny text, placed it below the submit button where no one reads, and never once mentioned Citizens Disability by name. Clicking “GET FREE COUPONS NOW” was the trap. The person thought they were getting grocery deals. Citizens Disability thought they had a new lead to call — repeatedly, with prerecorded scripts, until the person either signed up or stopped answering entirely.
The Consumer Sentinel database — the FTC’s repository of consumer complaints — collected over 10,000 separate complaints from people who registered for the Do Not Call Registry specifically to avoid calls like these, and got them anyway. Another 700 complaints documented illegal robocalls specifically. These are people who took a deliberate civic action to protect their own peace and privacy, and Citizens Disability’s operation plowed through that boundary like it didn’t exist. The company even developed written policies about the Do Not Call Registry in 2022 and 2023 — and then kept breaking the rules anyway.
The Scale of the Campaign: Key Call Volume Data Points
Legal Receipts: The Words That Damn Them
These are direct quotes and citations from the U.S. Department of Justice complaint. Every word below came from federal court filings.
“Hi. My name is Amber . . . Now, it show [sic] here that you recently inquired about your eligibility for Social Security Disability benefits.”
— Verbatim script from Citizens Disability’s robocall agent campaign, cited in DOJ Complaint ¶ 40. The DOJ confirms this statement was false. No such inquiry existed.
“Defendants are aware that their telemarketing campaigns violate the TSR.”
— DOJ Complaint ¶ 45. Citizens Disability knew. They had lawsuits. They had 10,000+ consumer complaints. They had a letter from the Mississippi Attorney General. They kept calling.
“consumers are tricked into providing their personal information to websites that purport to offer consumers coupons, prizes, and other services that have nothing to do with Defendants’ business, but are in fact ‘consent farms.'”
— DOJ Complaint ¶ 33. The federal government’s own words for what Citizens Disability built: an industrial trick.
“consumers have provided Defendants with information, such as their social security number, date of birth, medical history, or employment history, because they believed that Defendants were contacting them in response to their inquiry about benefits eligibility.”
— DOJ Complaint ¶ 44. Citizens Disability extracted Social Security numbers and medical records from people using a lie as a key.
“Despite their own policies, the consumer complaints, lawsuits and government inquiries, Defendants have continued to place telemarketing calls to consumer leads obtained from consent farm websites in violation of the TSR.”
— DOJ Complaint ¶ 49. Citizens Disability wrote down the rules. Citizens Disability broke the rules anyway. The document that contained the rules was also evidence of guilt.
Timeline: Citizens Disability Knew and Kept Going
Societal Impact Mapping: Who Gets Hurt and How
Public Health: Targeting People Who Are Already Suffering
Citizens Disability’s entire business model rested on finding people who were sick, injured, or disabled enough to potentially qualify for Social Security Disability Insurance. The company specifically required its lead generators to source consumers between the ages of 50 and 64 who were unemployed and not currently receiving benefits. This is not a random demographic. This is a population dealing with chronic illness, job loss tied to health conditions, financial stress, and the psychological weight of fighting a government benefits system that denies most first-time applicants.
Into that context, Citizens Disability dropped robocalls. Dozens of them, sometimes. The DOJ complaint documents a single consumer receiving 55 calls over a two-and-a-half-year stretch. For someone managing a serious health condition, repeated unwanted phone calls from a company impersonating a government response to their inquiry represent a form of targeted psychological harassment. The complaint also documents that consumers handed over their Social Security numbers, medical histories, and employment records because they believed the call was legitimate. The extraction of that sensitive health and identity information under false pretenses compounds the harm significantly.
The robocall campaigns used prerecorded messages that left voicemail after the first, fifth, and tenth call attempt to each person. This is a system engineered to wear people down. The DOJ’s complaint confirms the company’s agents “call consumers repeatedly” — a phrase that, applied to disabled people in financial distress, describes a pattern of exploitation dressed up as advocacy.
Economic Inequality: Building a Business on the Backs of the Broke
Citizens Disability selected its targets by economic condition, not just age. The lead specifications required unemployed consumers who were not receiving benefits — people who were, by definition, in an income gap. They had a disability or impairment. They had lost their job. They were not yet getting government support. They were exactly the people a predatory company could exploit, because desperation makes people more likely to hand over information to anyone who sounds like they might be able to help.
The “consent farm” infrastructure Citizens Disability funded reinforces economic inequality at a structural level. The company contracted with over 50 lead generators since 2019 and purchased the vast majority of its leads from Fluent, Inc. and Digital Media Solutions, Inc. These lead generators operated sweepstakes and coupon websites that were specifically designed to attract people who are financially squeezed — people who actually need free coupons, who actually want a shot at $50,000. The bait was economic precarity. The trap was a telemarketing call that extracted personal information under false pretenses.
Every penalty dollar that Citizens Disability avoided paying by not complying with the Do Not Call Registry fee requirements — the company is also accused of calling numbers in area codes for which it never paid the required annual access fee — is a cost shifted onto the public system. The National Do Not Call Registry exists as a public utility. Citizens Disability treated it as an obstacle to route around, not a rule to follow. The federal government now estimates each TSR violation carries a civil penalty of up to $50,120 (enough to cover a month of groceries for roughly 1,000 families). With millions of illegal calls documented, the potential liability is staggering — but only if the court forces them to pay it.
The “Cost of a Life” Metric
Outbound calls made between January 2019 and July 2022
That is enough calls to phone every single person in the United Kingdom, then do it again, with millions to spare.
Illegal calls placed to Do Not Call Registry numbers between 2019 and 2022
Each one was a deliberate violation against someone who explicitly asked to be left alone.
Calls in a single two-month window, May–June 2019, from one campaign alone
That is 750,000 calls per day, every day, for sixty days straight.
Maximum civil penalty per TSR violation, authorized by the FTC Act
$50,120 (enough to pay a minimum-wage worker’s annual salary and still have money left over). Multiply that by millions of documented illegal calls, and you begin to understand what Citizens Disability gambled the public would never actually collect from them.
Companies listed as “marketing partners” on the Super Sweepstakes consent farm
A person who clicked “CONFIRM YOUR ENTRY” to try to win $50,000 (a sum that would change most people’s lives) unknowingly handed their phone number to 290 corporations at once — buried in a list written in blue text on a blue background.
How the Consent Farm Machine Worked: The Pipeline
What Now? Who to Watch and What to Do
Regulatory Watchlist: Who Has Power Here
- Federal Trade Commission (FTC): The agency that investigated Citizens Disability and referred the case to the DOJ. Track their enforcement actions at ftc.gov.
- U.S. Department of Justice, Civil Division, Consumer Protection Branch: Filed this federal complaint. The DOJ is seeking a permanent injunction and civil penalties from Citizens Disability and CD Media.
- State Attorneys General: The Mississippi AG already sent a complaint letter to Citizens Disability in 2020. If you are in any state where you received illegal calls from this operation, contact your own state AG’s consumer protection division.
- FTC National Do Not Call Registry: If your number is not already registered, go to DoNotCall.gov. It will not stop all illegal callers, but it creates legal liability when companies like Citizens Disability ignore it.
The FTC has a press release about this scandal: https://www.ftc.gov/news-events/news/press-releases/2025/09/citizens-disability-pay-1-million-over-ftc-charges-it-made-tens-millions-illegal-misleading-calls
It also led to the FTC having an additional info blurb, which is kinda neat I guess: https://www.ftc.gov/business-guidance/blog/2025/09/are-you-telemarketing-business-heres-what-know-about-citizens-disability
If you want to spam call the spam caller back, Citizens Disability can be reached by calling 1-781-854-4857
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