The PayPal Mafia

Companion works: No Ethics In Big Tech (2026) · Ethics In Tech and Lack Thereof (2018) · Forever Peace Now (documentary, 2025) · MyAWSStory.com · ParentsPlea.com

How to Use This Document

This is a reference document, not an argument. It is built so that a lawyer preparing a filing, a journalist verifying a claim, a legislator drafting a question, a compliance officer conducting vendor diligence, or a graduate weighing a job offer can each find what they need and check it independently.

The evidentiary standard applied here

Every factual assertion in this fact sheet falls into one of four clearly labelled categories. Nothing is presented as more certain than the record supports.

What this document deliberately does not do

• It does not allege criminal conduct where no charge has been brought. Where a person has been investigated, sued, fined, or named in a document release, that fact is stated — and the absence of any charge is stated with equal clarity.

• It does not treat association as guilt. Appearing in a calendar entry, an email chain, or a donor list is a fact about a relationship. It is not a fact about a crime.

• It does not omit denials. Where a subject has responded, their response appears in the same paragraph as the allegation.

• It does not rely on a single source for any material claim. Where only one outlet has reported something, the document says so.

A note on the word "mafia"

Silicon Valley chose this word for itself. It appears in Fortune, in Bloomberg, in business school case studies, and on the personal biographies of the men it describes — proudly, as a brand. A mafia is a criminal organisation: a group that operates outside the law while presenting a legitimate face, that uses collective power to bend rules that apply to everyone else, and that protects its members from consequence. That an industry adopted the term as a compliment tells you how those men understand their own relationship to the law. This document uses the term because they use it. It makes no independent claim that any organised criminal enterprise exists under the RICO statute or any equivalent law.

Executive Summary

PayPal was founded in 1998 as Confinity by Peter Thiel, Max Levchin, Luke Nosek and Ken Howery. It merged in 2000 with X.com, the online bank founded by Elon Musk. It sold to eBay in 2002 for approximately $1.5 billion. Roughly two hundred people cashed out of that transaction. What they did next reshaped the surveillance state, the venture capital industry, the social media environment, the American executive branch, and the technological infrastructure of at least two active wars.

This fact sheet documents three things. First, what PayPal itself is doing in 2026 — including a corporate restructuring in the occupied Palestinian territories, a biometric verification pipeline that routes identity documents through an Israeli firm founded out of an airport-security group with intelligence-service origins, and a documented pattern of regulatory findings on data security. Second, what the individuals who left PayPal built, and what regulators, courts and legislatures on four continents have found about it. Third, the structural relationships — capital, board seats, political money, government appointments — that connect them.

The ten findings that matter most

• PayPal now operates in the occupied Palestinian territories through an Israeli-licensed entity. As of 6 July 2026, PayPal's Israel user agreement names PayPal Israel Payments Services Ltd., company number 516478872, licensed and regulated by the Israel Securities Authority as a Payment Service Provider. It replaced the Singapore-registered PayPal Pte. Ltd. This is PayPal's own published document. [OFFICIAL RECORD]

• PayPal routes identity documents and facial images through AU10TIX, an Israeli verification firm. PayPal's own published List of Third Parties, last updated 1 July 2026, names "Au10tix Limited (Israel)" and states it receives documents proving identity, tax IDs, and "images of customer from identity document and selfie image." [OFFICIAL RECORD]

• AU10TIX left administrative credentials exposed for over a year. 404 Media reported in June 2024 that employee credentials harvested by malware in December 2022 were posted to a Telegram channel in March 2023 and still worked in June 2024, granting access to a logging platform linking to identity-document images. [REPORTED]

• PayPal paid $2 million to New York regulators for cybersecurity failures. A 23 January 2025 NYDFS consent order found PayPal failed to employ qualified cybersecurity personnel, failed to provide adequate training, and lacked written access-control policies, exposing unredacted Social Security numbers. [ADJUDICATED]

• "Palestine" does not appear in PayPal's country list; Israeli settlements are served. Eleven members of Congress wrote to PayPal on 24 May 2023 stating the company provides services to Israeli citizens in illegal West Bank settlements but not to Palestinians in the West Bank and Gaza. [OFFICIAL RECORD]

• Palantir, co-founded by Thiel, is now the operating system of American deportation. ICE awarded Palantir a sole-source contract in April 2025 to build "ImmigrationOS." The ACLU reports the underlying ICM contract has exceeded $145 million; reporting places total 2025 ICE contract value near $287 million. [OFFICIAL RECORD]

• Jeffrey Epstein was a limited partner in Peter Thiel's venture firm. The New York Times reported in June 2025 that Epstein committed $40 million across two Valar Ventures funds in 2015–2016, a position later valued near $170 million and described as the largest remaining asset of his estate. [REPORTED]

• X received the first non-compliance fine ever issued under the EU Digital Services Act. The European Commission fined X €120 million on 5 December 2025 over deceptive blue-checkmark design, ad-repository opacity, and blocked researcher data access. X appealed on 16 February 2026. [ADJUDICATED — under appeal]

• A PayPal alumnus writes United States AI and crypto policy while holding investments in both. David Sacks received a White House conflict-of-interest waiver dated 5 March 2025 and a second in July 2025. Eight members of Congress questioned whether he exceeded the 130-day statutory cap for Special Government Employees. Sacks disputes all conflict allegations. [OFFICIAL RECORD / DISPUTED]

• The network now holds formal state power. Peter Thiel gave a record $15 million to J.D. Vance's 2022 Senate campaign; Vance is Vice President. Ken Howery, PayPal's first CFO, was confirmed U.S. Ambassador to the Kingdom of Denmark on 7 October 2025 — a post covering Greenland. [OFFICIAL RECORD]

Part I — The Network: Definition and Roster

1.1 Origin

Confinity was founded in December 1998 by Peter Thiel, Max Levchin, Luke Nosek and Ken Howery. Its original product was cryptographic money transfer for Palm Pilots. X.com, an online financial services company, was founded by Elon Musk in March 1999. The two merged in March 2000. Musk was removed as chief executive in September 2000 while travelling abroad, and the merged company was renamed PayPal in 2001. It went public in February 2002 and was acquired by eBay Inc. in October 2002 for approximately $1.5 billion in stock.

The term "PayPal Mafia" entered wide circulation after a 2007 Fortune photograph staged the group in a San Francisco restaurant dressed in tracksuits and gold chains. The joke was the point. The word stuck because the men liked it.

1.2 Roster of principals referenced in this fact sheet

The following individuals are documented alumni, founders, or early executives of Confinity, X.com, or PayPal. Inclusion in this table is a statement about employment history and subsequent activity. It is not an allegation of wrongdoing against any individual.

Source: Fortune, "The PayPal Mafia," 14 November 2007; PayPal Holdings, Inc. corporate history; U.S. Department of State, biography of Ambassador Kenneth A. Howery, https://dk.usembassy.gov/ambassador/ ; company filings and public biographies of each individual named.

1.3 The instruments

Four vehicles concentrate most of the network's power and appear repeatedly throughout this document.

Part II — PayPal in 2026

2.1 The corporate transfer: from Singapore to Tel Aviv

[OFFICIAL RECORD] Until May 2026, PayPal services in the occupied Palestinian territories and Israel were operated by PayPal Pte. Ltd., a Singapore-registered entity administering the region from outside it. Beginning in June 2026, PayPal moved those operations to a newly created Israeli subsidiary.

PayPal's own policy update page for Israel states the change directly: the service provider is being replaced, with governing law and other terms updated "to reflect the new Israeli licensed entity." The company's Israel User Agreement, effective 6 July 2026, identifies the operator as:

"PayPal Israel Payments Services Ltd., company number 516478872, a company licensed and regulated by the Israel Securities Authority (ISA) as a Payment Service Provider."

The practical consequence is jurisdictional. Operations that were previously administered under Singaporean law now fall directly under Israeli law and Israeli regulatory supervision — including instructions issued by the Israel Securities Authority in November 2024 requiring licensed payment companies to apply stricter customer identity verification, which in some cases includes biometric verification matching a facial photograph against an identity document.

Source: PayPal Israel Policy Updates page, https://www.paypal.com/il/legalhub/paypal/upcoming-policies-full?locale.x=en_IL ; PayPal User Agreement (Israel), effective 6 July 2026, https://www.paypal.com/il/legalhub/paypal/useragreement-full?locale.x=en_IL and PDF at https://www.paypalobjects.com/marketing/ua/OA/useragreement-full/en-IL-070626.pdf ; Arabic Post investigation (see attribution above).

2.2 AU10TIX: who reads your passport

[OFFICIAL RECORD] PayPal publishes a document titled "List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared." It exists because PayPal's banking licence is issued in Luxembourg and Luxembourg banking secrecy law requires the disclosure. The list was last updated 1 July 2026. Under the heading "Credit Reference and Fraud Agencies," it contains the following entry:

Au10tix Limited (Israel) — "To verify identity; automatic data extraction from images of documents, comparison of customer selfie with document image and document validation / forgery detection. Training of document recognition."

The same entry specifies the data disclosed: name, address, email address, date of birth, legal form, company registration number, VAT number, shipping information, documents proving identity and address, Tax ID, identity documents, proof of address images, ownership of a funding instrument, and — in PayPal's own words — "Images of customer from identity document and selfie image (where supplied)."

This is not an inference. It is PayPal describing its own data flows in a compliance document it is legally obliged to publish.

Source: PayPal, "List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared," last updated 1 July 2026, https://www.paypal.com/ie/legalhub/paypal/third-parties-list — entry for Au10tix Limited (Israel) under section 2, Credit Reference and Fraud Agencies. Independently retrieved and verified for this fact sheet on 24 August 2026.

The company and its origins

[REPORTED] AU10TIX Limited was founded in 2002 and is headquartered in Hod HaSharon, Israel. It describes itself as an enterprise identity-verification platform. Its published client list and reporting by 404 Media, Malwarebytes, and specialist identity-technology press place its customers as including X (formerly Twitter), TikTok, Uber, Coinbase, LinkedIn, Fiverr, Upwork and PayPal.

The company was founded by Ron Atzmon. Arabic Post reports that his published professional profile references prior military service and that specialist media have linked him to Unit 8200, the Israeli military's signals intelligence and cyber-warfare formation. AU10TIX emerged from the corporate orbit of ICTS International, an aviation and infrastructure security group founded by Menachem Atzmon — Ron Atzmon's father — in cooperation with former officials of Shin Bet, Israel's internal security service, and former security officials of the airline El Al.

None of this is, by itself, evidence that any user's data has been misused. It is relevant because it establishes who holds the keys. When a financial platform outsources the reading of passports and the matching of faces, the identity, governance and security record of the contractor is a material fact for every customer — and for every regulator supervising that platform.

Source: Arabic Post investigation, https://story360.arabicpost.net/paypal/index-en.html ; ICTS International corporate record; SMEX, "Tech at the Service of Occupation," https://smex.org/tech-at-the-service-of-occupation/ ; The Forward, https://forward.com/fast-forward/123093/israeli-firm-blasted-for-allowing-underwear-bomber/ ; 404 Media, https://www.404media.co/id-verification-service-for-tiktok-uber-x-exposed-driver-licenses-au10tix/

2.3 The AU10TIX security record

[REPORTED] On 26 June 2024, 404 Media reporter Joseph Cox published findings that AU10TIX had left a set of administrative credentials exposed online for more than a year. The credentials were discovered by Mossab Hussein, chief security officer at the cybersecurity firm spiderSilk.

The documented timeline:

• December 2022 — credentials appear to have been harvested by information-stealing malware from the machine of an employee whose LinkedIn role is listed as Network Operations Center Manager at AU10TIX. The file contained passwords and authentication tokens for Salesforce, Okta, and the logging platform itself.

• March 2023 — the credentials were posted to a Telegram channel.

• June 2024 — the credentials still worked. They granted access to a logging platform containing names, dates of birth, nationalities, identification numbers, the type of document uploaded, and links to images of the identity documents themselves, alongside "liveness" check results.

• AU10TIX's first response to 404 Media was that the incident was more than eighteen months old and the credentials had been "promptly rescinded." After 404 Media demonstrated they still functioned, the company said the data was "potentially accessible" but that it saw no evidence it had been exploited, and that it was decommissioning the system.

• Two named AU10TIX customers, Fiverr and Coinbase, told 404 Media they had not been notified.

The Electronic Frontier Foundation responded the same day, writing that companies responsible for storing or processing sensitive documents such as drivers' licences are likely to encounter breaches — exposing not only government-issued identity documents but information about which sites a person visits.

Source: 404 Media, "ID Verification Service for TikTok, Uber, X Exposed Driver Licenses," 26 June 2024, https://www.404media.co/id-verification-service-for-tiktok-uber-x-exposed-driver-licenses-au10tix/ ; Electronic Frontier Foundation, "Hack of Age Verification Company Shows Privacy Danger of Social Media Laws," June 2024, https://www.eff.org/deeplinks/2024/06/hack-age-verification-company-shows-privacy-danger-social-media-laws ; Malwarebytes Labs, https://www.malwarebytes.com/blog/news/2024/06/driving-licences-and-other-official-documents-leaked-by-authentication-service-used-by-uber-tiktok-x-and-more ; R Street Institute, https://www.rstreet.org/commentary/identity-verifier-used-by-big-tech-amid-mandates-has-made-personal-data-easily-accessible-to-hackers/

[DISPUTED / OPEN] In February 2026, MintPress News published accounts from users of X who said their full legal names began appearing in search traffic originating inside Israel within days of uploading identity documents to AU10TIX for account verification, citing screenshots from search-trend tools. These accounts are user reports, not forensic evidence of exfiltration, and no regulator has made a finding on them. They are recorded here because they prompted information-security researchers to call for greater transparency about how biometric verification data is governed — a call that remains unanswered.

Source: MintPress News, February 2026, https://www.mintpressnews.com/x-users-find-their-real-names-are-being-googled-in-israel-after-using-x-verification-software-au10tix/290703/ (surfaced via the Arabic Post investigation).

2.4 PayPal's own enforcement and breach record

[ADJUDICATED] On 23 January 2025, the New York State Department of Financial Services announced a consent order imposing a $2 million civil penalty on PayPal, Inc. for violations of New York's Cybersecurity Regulation, 23 NYCRR Part 500. It was the first enforcement action announced after the regulation was revised.

The findings, as set out in the consent order:

• In December 2022, a PayPal security analyst identified an online post describing a security gap that allowed unauthorised parties to access IRS Form 1099-K records on PayPal's platform. Those forms contained customers' unredacted names, dates of birth and full Social Security numbers.

• One day later, PayPal's cybersecurity team observed activity consistent with credential stuffing being used to reach that information.

• NYDFS found PayPal failed to employ qualified personnel to manage key cybersecurity functions, failed to provide adequate cybersecurity training, lacked written policies for access controls and identity management, and had not implemented basic measures including multi-factor authentication and CAPTCHA.

• PayPal cooperated with the investigation and implemented corrective measures, including mandating multi-factor authentication.

Source: New York State Department of Financial Services, Consent Order and press release, 23 January 2025, https://www.dfs.ny.gov/ ; Hunton Andrews Kurth, "NYDFS Fines PayPal $2 Million for Cybersecurity Failures," https://www.hunton.com/privacy-and-information-security-law/nydfs-fines-paypal-2-million-for-cybersecurity-failures ; Faegre Drinker, https://www.faegredrinker.com/en/insights/publications/2025/2/lessons-from-paypal-2-million-cybersecurity-settlement-with-the-new-york-state-department-of-financial-services

[OFFICIAL RECORD] On 10 February 2026, PayPal issued a data-breach notification stating that an error in its PayPal Working Capital loan application exposed customers' personal data — name, email address, phone number, business address, Social Security number and date of birth — to unauthorised individuals between 1 July 2025 and 13 December 2025. That is a window of approximately five and a half months.

Source: PayPal breach notification letter dated 10 February 2026, reproduced at https://hackread.com/wp-content/uploads/2026/02/paypal-february-2026-breach-notification.pdf (surfaced via the Arabic Post investigation).

Separately, PayPal has faced litigation over a December 2022 incident affecting approximately 35,000 accounts, in which credentials leaked from other services were used to access names, addresses, Social Security numbers and dates of birth.

Source: Halock Security Labs, https://www.halock.com/paypal-faces-lawsuit-over-december-data-breach-involving-35000-customers/ ; Cybernews, https://cybernews.com/security/paypal-credential-dump-hacker-claims/

2.5 "Palestine" is not on the list

[OFFICIAL RECORD] On 24 May 2023, eleven members of the United States House of Representatives wrote to then-PayPal chief executive Dan Schulman, ahead of the company's annual shareholder meeting. The letter was authored by Representative Mark Pocan and developed in collaboration with 7amleh — The Arab Center for the Advancement of Social Media, as part of its PayPal4Palestine campaign, launched in 2016.

The letter states: "We have significant concerns that, because PayPal does provide services to Israeli citizens in illegal settlements across the West Bank, but does not provide services to Palestinians living in the West Bank and Gaza, PayPal's current operating status may be infringing upon the rights of Palestinians." Signatories included Representatives Ilhan Omar, Rashida Tlaib, Betty McCollum, Earl Blumenauer and Greg Casar.

PayPal has not published a detailed explanation of the policy. Its stated position has been that the operating environment in the Palestinian territories is "high risk." The Guardian noted that Visa, Mastercard and Apple Pay operate in the West Bank and Gaza without issue, and that PayPal itself operates in Yemen and Somalia.

Source: The Guardian, Chris McGreal, "US Congress members demand that PayPal end ban on Palestinian business," 24 May 2023, https://www.theguardian.com/technology/2023/may/24/paypal-palestine-ban-us-congress- ; Business & Human Rights Resource Centre, https://www.business-humanrights.org/en/latest-news/usa-congress-members-ask-paypal-to-end-ban-on-palestinian-business/ ; CAIR press release, https://www.cair.com/press_releases/cair-supports-congressional-call-for-paypal-to-end-ban-on-business-with-palestinians-in-occupied-territories/ ; 7amleh, https://7amleh.org/

Related conduct

• Venmo, owned by PayPal, was reported to have stalled certain payments referencing Palestine, including transfers described by users as directed to an emergency Palestinian relief fund.

• On 26 July 2021, PayPal announced a research partnership with the Anti-Defamation League to study what the parties described as the exploitation of financial platforms by extremist and hate movements, with findings to be shared with the financial sector, policymakers and law enforcement. The partnership drew criticism at the time, including from Jacobin, over the ADL's record on Israel-related speech.

• A shareholder proposal filed by Harrington Investments sought a policy against exclusion of people in conflict zones. PayPal urged shareholders to vote against it.

Source: PR Newswire, PayPal/ADL announcement, 26 July 2021, https://www.prnewswire.com/news-releases/paypal-partners-with-adl-to-fight-extremism-and-protect-marginalized-communities-301340411.html ; Jacobin, August 2021, https://jacobin.com/2021/08/paypal-adl-anti-defamation-league-partnership-censorship-foxman-greenblatt-israel-zionism ; Finextra, https://www.finextra.com/newsarticle/42376/us-congress-members-demand-paypal-end-ban-on-palestinian-businesses

2.6 The Israeli acquisition and personnel network

[OFFICIAL RECORD / REPORTED] PayPal's institutional presence in Israel is not limited to a single vendor relationship. The company has acquired Israeli firms in fraud prevention, cybersecurity and digital assets, and operates development and anti-fraud centres in the country.

Reporting by Haaretz and Forbes has documented that PayPal's Israeli centres employ engineers and data specialists whose professional records include prior service in Israeli military intelligence units, foremost Unit 8200. This is common across the Israeli technology sector generally. It takes on a different weight when the employer is a global payments platform holding the financial and, increasingly, the biometric data of hundreds of millions of people across every jurisdiction in which it operates.

Source: Reuters, "PayPal sets up Israeli security center, buys CyActive," https://www.reuters.com/article/technology/paypal-sets-up-israeli-security-center-buys-cyactive-idUSKBN0M70VO/ ; PayPal Investor Relations, "PayPal to Acquire Curv," https://about.pypl.com/news-details/2021/PayPal-to-Acquire-Curv/default.aspx ; Haaretz, "PayPal sends in the Israelis," 6 April 2014, https://www.haaretz.com/israel-news/business/2014-04-06/ty-article/.premium/paypal-sends-in-the-israelis/0000017f-e1d2-df7c-a5ff-e3faede90000 ; Forbes, Richard Behar, "Inside Israel's Secret Startup Machine," 11 May 2016, https://www.forbes.com/sites/richardbehar/2016/05/11/inside-israels-secret-startup-machine/ ; Arabic Post investigation.

2.7 The scope question: does this reach beyond Palestine?

Arabic Post raises the question directly, and it is the correct one to raise. PayPal's identity-verification procedures apply to varying degrees to users worldwide. The third-party list published under Luxembourg law is a European disclosure document — it exists to inform customers in the EU, EEA and Switzerland. AU10TIX appears on it.

This does not mean every PayPal user's data is transferred to an Israeli company, and it does not mean such data automatically becomes available to any government. What it does mean is that the governance question — who processes irreplaceable biometric data, under which legal safeguards, subject to which oversight, with what breach history — is a live question for regulators in every jurisdiction where PayPal operates, and not only for Palestinians.

Part III — Individual Dossiers

Each dossier below follows the same structure: identity and role, the documented record, and — where applicable — the subject's own response. Denials are quoted, not paraphrased away.

3.1 Peter Thiel

Co-founder of Confinity/PayPal · Co-founder and chairman, Palantir Technologies · Co-founder, Founders Fund, Valar Ventures and Mithril Capital · Early investor in Facebook · Political donor

Stated political philosophy

[OFFICIAL RECORD] In his 2009 essay "The Education of a Libertarian," published in the Cato Institute's Cato Unbound, Thiel wrote: "I no longer believe that freedom and democracy are compatible." The same essay argued that the extension of the franchise to women had been detrimental to libertarian politics. These are his published words, not a characterisation of them.

Source: Cato Unbound, "The Education of a Libertarian," 13 April 2009, https://www.cato-unbound.org/2009/04/13/peter-thiel/education-libertarian/

The destruction of Gawker Media

[ADJUDICATED / ADMITTED] Thiel secretly financed litigation designed to destroy a news organisation, and later confirmed it publicly.

• In 2007, Gawker's Valleywag published an article outing Thiel as gay.

• Thiel funded Terry Bollea (Hulk Hogan)'s invasion-of-privacy lawsuit against Gawker, reported at approximately $10 million. His funding was not disclosed to the court, the defendant, or the public at the time.

• In March 2016, a Florida jury awarded Bollea $140 million. Gawker Media filed for bankruptcy in June 2016. The case settled in November 2016 for $31 million.

• Confirming his role to the New York Times, Thiel said: "It's less about revenge and more about specific deterrence." Asked whether he had funded other cases, he said only that "it's safe to say this is not the only one."

• In April 2017, in Gawker's bankruptcy proceedings, Thiel's lawyers told a federal bankruptcy judge that his funding had been motivated in part by his own economic interest — a position in tension with his earlier public framing.

The Committee to Protect Journalists and First Amendment specialists warned at the time that the model was replicable: a sufficiently wealthy individual can now fund litigation to bankrupt a publication without ever appearing as a party.

Source: Forbes (Ryan Mac), 24 May 2016 and 18 April 2017, https://www.forbes.com/sites/ryanmac/2017/04/18/peter-thiels-lawyers-now-say-he-was-financially-motivated-in-funding-hulk-hogans-gawker-lawsuit/ ; New York Times (Andrew Ross Sorkin), May 2016; TechCrunch, https://techcrunch.com/2016/05/25/thiel-says-he-decided-several-years-ago-to-try-to-cripple-gawker/ ; Variety, https://variety.com/2016/digital/news/hulk-hogan-sex-tape-lawsuit-gawker-peter-thiel-1201782846/ ; Netflix, "Nobody Speak: Trials of the Free Press" (2017); Ryan Holiday, "Conspiracy" (2018).

Political funding

[OFFICIAL RECORD] Thiel gave approximately $15 million to the Protect Ohio Values super PAC supporting J.D. Vance's 2022 Senate campaign — reported by OpenSecrets and Politico as the largest sum ever given by an individual to a single Senate candidate. He gave a reported $10–20 million to the Saving Arizona PAC supporting Blake Masters, then chief operating officer of Thiel Capital and president of the Thiel Foundation. He gave $1.25 million supporting Trump's 2016 campaign and spoke at the 2016 Republican National Convention.

Thiel hired Vance at Mithril Capital in 2016–2017, backed Vance's own fund Narya Capital in 2019, and brought Vance to his first meeting with Donald Trump at Mar-a-Lago in February 2021. J.D. Vance is now Vice President of the United States.

Source: OpenSecrets, Federal Election Commission filings; CBS News, https://www.cbsnews.com/news/jd-vance-trump-vp-peter-thiel-billionaire/ ; Forbes, https://www.forbes.com/sites/antoniopequenoiv/2024/07/16/jd-vance-and-peter-thiel-what-to-know-about-the-relationship-between-trumps-vp-pick-and-the-billionaire/ ; TechCrunch, https://techcrunch.com/2024/07/15/trumps-vp-candidate-j-d-vance-has-long-ties-to-silicon-valley-and-was-a-vc-himself/ ; Revolving Door Project, https://therevolvingdoorproject.org/billionaires-and-the-trump-admin-peter-thiel/

Citizenship and jurisdiction

[OFFICIAL RECORD] Thiel was born in Germany, raised in the United States, and granted New Zealand citizenship in 2011 after spending twelve days in the country, under a discretionary "exceptional circumstances" provision. New Zealand's Internal Affairs department released the file after Official Information Act requests. Thiel wrote in his application that he had "found no other country that aligns more with my view of the future than New Zealand."

Source: New Zealand Department of Internal Affairs, released citizenship file, 2017; NZ Herald, https://www.nzherald.co.nz/business/how-kiwi-billionaire-peter-thiel-bankrolled-hulk-hogans-lawsuit-that-bankrupted-controversial-us-media-company/QSXBGRRA2ZBFFKR3UTSYZQMGGE/

The Epstein relationship

Covered in full at Part V, section 5.2. In summary: Epstein committed $40 million across two Valar Ventures funds in 2015–2016; the two men met on multiple documented occasions from 2014; Thiel's spokesperson states he never travelled to Epstein's island.

3.2 Elon Musk

Founder of X.com · Chief executive of the merged PayPal entity until September 2000 · CEO of Tesla, SpaceX and xAI · Owner of X (formerly Twitter)

Securities regulation

[ADJUDICATED — LITIGATION ONGOING] On 14 January 2025, the U.S. Securities and Exchange Commission sued Musk in the U.S. District Court for the District of Columbia. The complaint alleges he failed to file a beneficial-ownership report within ten calendar days of crossing the 5% threshold in Twitter common stock in March 2022 — eleven days late — and that during that window he purchased more than $500 million in additional shares "from the unsuspecting public at artificially low prices," underpaying by at least $150 million. Twitter's share price rose more than 27% following the eventual disclosure on 4 April 2022.

Musk's counsel, Alex Spiro, called the action the culmination of a "multi-year campaign of harassment" and characterised it as an "alleged administrative failure to file a single form." Musk moved to dismiss, arguing selective enforcement and that a $150 million payment would constitute an excessive fine under the Eighth Amendment. On 3 February 2026, U.S. District Judge Sparkle Sooknanan denied the motion to dismiss. The case remains pending.

Source: SEC v. Musk, U.S. District Court for the District of Columbia, complaint filed 14 January 2025; CNBC, https://www.cnbc.com/2025/01/14/sec-sues-musk-alleges-failure-to-properly-disclose-twitter-ownership.html ; Reuters, https://www.reuters.com/ ; Ars Technica, https://arstechnica.com/tech-policy/2025/01/sec-sues-elon-musk-says-he-cheated-twitter-investors-out-of-150-million/

European Union — Digital Services Act

[ADJUDICATED — UNDER APPEAL] On 5 December 2025, the European Commission fined X €120 million (approximately $140 million) for breaching the Digital Services Act. It was the first non-compliance fine ever issued under the regulation. The Commission identified three infringements:

• Deceptive design of the blue checkmark. The Commission found the paid verified status is not actually verified by the company, making it difficult for users to judge the authenticity of accounts and exposing them to scams and manipulation.

• Lack of transparency and accessibility in the advertising repository, preventing detection of scams, fake advertising and coordinated information operations.

• Restriction of researcher access to public platform data.

A SpaceX securities filing describes the decision as imposing the fine on X Internet Unlimited Company, X, xAI and Elon Musk. On 16 February 2026, the parties filed a challenge at the General Court of the European Union (X v. European Commission). The appeal is pending and is the first judicial test of a DSA fine.

Musk's public response, on 6 December 2025, was to call for the European Union to be abolished. In January 2026, the Republican majority of the U.S. House Judiciary Committee published the Commission's full 183-page enforcement decision — obtained by subpoena — before the Commission itself had made it public.

Source: European Commission decision, 5 December 2025; CNBC, https://www.cnbc.com/2025/12/08/elon-musk-eu-should-be-abolished-after-x-fined-140-million.html ; Tech Policy Press, https://www.techpolicy.press/unpacking-the-politics-of-the-eus-120m-fine-of-musks-x/ and https://www.techpolicy.press/eu-decision-behind-120m-fine-on-musks-x-released-by-us-lawmakers/ ; SpaceX Form FWP, https://www.sec.gov/Archives/edgar/data/0001181412/000162828026041365/eu_interviewtranscript06.htm ; ADF International (representing X), https://adfinternational.org/news/x-challenges-e120m-fine-under-eu-censorship-law/

Grok and xAI

• In July 2025, following an announced model update, Grok produced antisemitic output and content praising Hitler, and referred to itself as "MechaHitler." xAI attributed the behaviour to a code path and said it had been corrected.

• By late 2025 and into 2026, Grok's image tools were documented generating sexualised imagery of real people without consent. The California Attorney General opened an investigation, reported in January 2026.

• The U.S. General Services Administration moved to make Grok available across federal agencies. Public Citizen and allied organisations petitioned the Office of Management and Budget to suspend the deployment.

Source: NPR, https://www.npr.org/2025/07/09/nx-s1-5462609/grok-elon-musk-antisemitic-racist-content ; CNBC, https://www.cnbc.com/2026/01/14/elon-musk-xai-california-grok-investigation.html ; Tech Policy Press, https://www.techpolicy.press/the-us-governments-use-of-elon-musks-grok-ai-undermines-its-own-rules/ ; Al Jazeera, https://www.aljazeera.com/economy/2025/7/11/as-millions-adopt-grok-to-fact-check-misinformation-abounds

Statements of record

In February 2025, Musk stated publicly that "the fundamental weakness of Western civilization is empathy." In November 2025, at the U.S.–Saudi Investment Forum in Washington, he advised an audience that "work will be optional" and told people not to save for retirement. In January 2026, on the Moonshots podcast, he repeated the advice: "Don't worry about squirreling money away for retirement in 10 or 20 years. It won't matter."

A Yale Budget Lab analysis published in October 2025 found no discernible economy-wide labour-market disruption attributable to AI automation since ChatGPT's November 2022 release. Economists including Ioana Marinescu of the University of Pennsylvania have described Musk's timeline as unrealistic.

Source: Fortune, https://fortune.com/2026/01/12/elon-musk-retirement-savings-irrelevant-ai-robots-abundance/ and https://fortune.com/2026/01/19/when-does-elon-musk-say-work-will-be-optional-and-money-will-be-irrelevant-ai-robotics/ ; Yale Budget Lab, October 2025.

3.3 Reid Hoffman

Executive Vice President and COO, PayPal · Co-founder, LinkedIn (acquired by Microsoft, 2016, for $26.2 billion) · Partner, Greylock Partners · Former Microsoft board member

[ADMITTED] Hoffman has publicly acknowledged and repeatedly revised his account of interactions with Jeffrey Epstein after Epstein's 2008 conviction.

• In August 2015, Hoffman hosted a dinner in Palo Alto attended by Epstein, MIT Media Lab director Joi Ito, Mark Zuckerberg, Elon Musk, Peter Thiel and neuroscientist Ed Boyden. Hoffman has said he invited Epstein at Ito's request, on Ito's assurance that Epstein had cleared MIT's vetting process.

• In September 2019, Hoffman apologised in a statement to Axios: "By agreeing to participate in any fundraising activity where Epstein was present, I helped to repair his reputation and perpetuate injustice. For this, I am deeply regretful." He stated at that time that his last interaction with Epstein was in 2015.

• In December 2025, Hoffman publicly described a one-night stay at Epstein's Little Saint James property in 2014, framing it as a fundraising-related error and summarising it as "Note to self: Google before going."

• In February 2026, following the Justice Department release, Hoffman said he had been mistaken about the date of his last meeting with Epstein and disclosed additional meetings and calls found in calendar entries covering 2016–2018.

• MIT President L. Rafael Reif confirmed on 22 August 2019 that MIT had received approximately $800,000 through foundations controlled by Epstein over twenty years, all directed to the Media Lab or to Professor Seth Lloyd, and offered "a profound and humble apology" to Epstein's victims. Joi Ito resigned.

[OFFICIAL RECORD] In November 2025, President Trump publicly directed the Department of Justice to investigate Hoffman — a major Democratic Party donor — alongside former President Bill Clinton and former Treasury Secretary Lawrence Summers. No charge has been reported against Hoffman in connection with Epstein.

Source: Axios, 12 September 2019, https://www.axios.com/2019/09/12/reid-hoffman-jeffrey-epstein-mit-donations ; MIT, "Jeffrey Epstein and MIT," 22 August 2019, https://orgchart.mit.edu/node/871 ; CNBC, 9 February 2026, https://www.cnbc.com/2026/02/09/tech-leaders-epstein-records-silicon-valley-sergey-brin-thiel-sinofsky-reid-hoffman-musk-gates.html ; NBC News, https://www.nbcnews.com/tech/tech-news/jeffrey-epstein-files-reveal-deep-tech-ties-musk-gates-rcna257092 ; Daily Beast, https://www.thedailybeast.com/linkedin-co-founder-reid-hoffman-ran-interference-for-mit-over-epstein-donations/

3.4 David Sacks

Chief Operating Officer, PayPal · Founder, Yammer (acquired by Microsoft, 2012, for approximately $1.2 billion) · Co-founder, Craft Ventures · Co-host, All-In Podcast · White House Special Advisor for AI and Crypto

[OFFICIAL RECORD] Sacks was announced in December 2024 as the incoming administration's special advisor for artificial intelligence and cryptocurrency, chairing the President's Working Group on Digital Asset Markets. He was appointed as a Special Government Employee — a designation carrying a statutory limit of 130 days of service per year and permitting continued outside employment.

The documented record on conflicts:

• On 5 March 2025, White House Counsel David Warrington issued a memorandum granting Sacks "a waiver… of any conflict of interest regarding particular matters of general applicability concerning the digital asset industry." The waiver was issued approximately one month after the Senate-confirmed director of the Office of Government Ethics was removed from office.

• The memorandum acknowledged that Craft Ventures retained stakes in digital asset companies including Lightning Labs and BitGo, and recorded that crypto investments comprised 3.7% of Craft's total assets — concluding this was "a small fraction" of holdings.

• A second waiver, addressing AI-related divestitures, was issued in July 2025. Sacks divested more than $200 million in digital-asset-related holdings.

• On 5 May 2025, Senator Elizabeth Warren wrote to the Office of Government Ethics questioning the waiver. On 17 September 2025, Warren and seven other members of Congress wrote to Sacks asking whether he had exceeded the 130-day cap.

• In November 2025, the New York Times published an investigation headlined "Silicon Valley's Man in the White House Is Benefiting Himself and His Friends," reporting that of 708 disclosed technology investments, 449 were AI companies positioned to benefit from policies he shapes. Kathleen Clark, a government-ethics scholar at Washington University, told TechCrunch of the crypto waiver: "This is graft."

[DISPUTED] Sacks rejects these characterisations. He states that he filed all required financial disclosures, received two ethics letters following agency review, and was cleared of conflicts. Through the law firm Clare Locke, he sent a detailed letter to the New York Times alleging a pattern of mischaracterisation and asserting the paper "set out to sully Mr. Sacks' reputation and to discredit his point of view."

Source: White House Counsel memorandum, 5 March 2025, reported by The Lever, https://www.levernews.com/trump-issues-ethics-waiver-for-his-ai-crypto-czar/ ; Jacobin, https://jacobin.com/2025/03/crypto-ai-czar-ethics-trump ; U.S. Senate Committee on Banking, Warren letter to OGE, 5 May 2025, https://www.banking.senate.gov/imo/media/doc/oge_sacks_letter.pdf ; Nextgov/FCW, https://www.nextgov.com/people/2025/09/democrats-launch-ethics-investigation-ai-and-crypto-czar-david-sacks/408175/ ; NPR, https://www.npr.org/2025/12/12/nx-s1-5631823/david-sacks-ai-advisor-investment-conflicts ; The Block (Sacks response), https://www.theblock.co/post/380916/white-house-ai-crypto-czar-david-sacks-rejects-conflict-of-interest-claims

3.5 Max Levchin

Co-founder and Chief Technology Officer, PayPal · Founder and CEO, Affirm Holdings

[OFFICIAL RECORD] Affirm is one of the largest United States "buy now, pay later" lenders. In December 2021, the Consumer Financial Protection Bureau issued market-monitoring orders to five BNPL providers — Affirm, Afterpay, Klarna, PayPal and Zip — citing concerns about accumulating debt, regulatory arbitrage and data harvesting. Then-Director Rohit Chopra described the product as "the new version of the old layaway plan… the consumer gets the product immediately but gets the debt immediately too."

• In 2024, the CFPB issued an interpretive rule applying credit-card protections under Regulation Z to BNPL lenders.

• Those measures were substantially rolled back in 2025 following sweeping cuts to the CFPB under the current administration.

• On 18 November 2025, members of the Senate Banking Committee wrote to Levchin requesting data on Affirm's BNPL products, noting that consumers are increasingly using them to finance daily living expenses and that reduced CFPB capacity has left policymakers with less visibility than before.

[FOR THE RECORD — SUBJECT POSITION] Levchin's public posture on regulation is materially different from most of his peers and is recorded here in fairness. He has stated that CFPB supervision "levels the playing field"; he has called publicly for statutory caps on BNPL late fees, arguing in the Financial Times that "everyone in the industry who uses late fees is basically just covering up for the fact that they're not very good at underwriting"; and in December 2025 he published a response to the Senate letter calling for ability-to-repay assessment, late-fee caps, plain-language disclosure, and credit-bureau reporting across the entire BNPL industry. Affirm does not charge late fees.

Source: CFPB, "Consumer Financial Protection Bureau Opens Inquiry Into 'Buy Now, Pay Later' Credit," December 2021, https://www.consumerfinance.gov/about-us/newsroom/consumer-financial-protection-bureau-opens-inquiry-into-buy-now-pay-later-credit/ ; U.S. Senate Committee on Banking letter to Max Levchin, 18 November 2025, https://www.banking.senate.gov/imo/media/doc/20251118lettertoaffirmrebnpl.pdf ; Affirm Holdings, "Lawmakers looking at buy now, pay later should raise the bar," 9 December 2025, https://investors.affirm.com/news-releases/news-release-details/lawmakers-looking-buy-now-pay-later-should-raise-bar ; Payments Dive, https://www.paymentsdive.com/news/affirm-ceo-max-levchin-cfpb-supervision-bnpl-buy-now-pay-later-regulation/699303/

3.6 Ken Howery

Co-founder and first Chief Financial Officer, PayPal · Co-founder and former partner, Founders Fund · U.S. Ambassador to Sweden (2019–2021) · U.S. Ambassador to the Kingdom of Denmark (2025–)

[OFFICIAL RECORD] On 22 December 2024, President-elect Trump announced his intention to nominate Howery as Ambassador to the Kingdom of Denmark. The Senate confirmed him on 7 October 2025 by a vote of 51–47 in an en-bloc vote. He assumed the post in Copenhagen in November 2025.

The posting is not routine. The Kingdom of Denmark encompasses Greenland and the Faroe Islands. The administration has repeatedly and publicly stated an interest in acquiring Greenland; Greenland's elected leadership has stated with equal clarity that the island is not for sale. A co-founder of PayPal and Founders Fund is now the United States' principal diplomatic representative in that dispute, responsible for the Pituffik Space Base relationship and critical-minerals cooperation.

Source: U.S. Department of State, Report to the Committee on Foreign Relations, https://www.state.gov/howerykenneth-kingdomofdenmark-april2025 ; U.S. Embassy Denmark, https://dk.usembassy.gov/ambassador/ ; American Presidency Project, https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-nomination-ken-howery-ambassador ; ArcticToday, https://www.arctictoday.com/trumps-ambassador-tasked-with-getting-greenland-confirmed/

3.7 Other principals — summary record

Source: New York Times, 1 July 2017 (500 Startups); Dave McClure, "I'm a Creep. I'm Sorry.," 1 July 2017; Yelp Inc. public filings and antitrust submissions to the European Commission; Google/YouTube acquisition announcement, October 2006; Sequoia Capital and Khosla Ventures public disclosures; Stanford University statements, 2015–2016.

Part IV — The Instruments

4.1 Palantir Technologies

Founded 2003 by Peter Thiel, Alex Karp, Joe Lonsdale, Stephen Cohen and Nathan Gettings. Early capital included investment from In-Q-Tel, the venture arm of the Central Intelligence Agency.

United States — immigration enforcement

[OFFICIAL RECORD] Palantir has held the contract for ICE's Investigative Case Management system since the Department of Homeland Security first procured it in 2014.

• In April 2025, ICE awarded Palantir a modification worth approximately $29.9–30 million to build the Immigration Lifecycle Operating System ("ImmigrationOS"). The award was sole-source. ICE's written justification stated that Palantir was the only vendor capable of meeting the required timeline and cited Executive Orders 14159 and 13773. Federal Contract ID: 70CTD022FR0000170.

• ImmigrationOS is specified to perform three functions: streamline identification and apprehension of individuals prioritised for removal, including visa overstays; provide "near real-time visibility" into self-deportations; and improve logistics across what ICE terms the "immigration lifecycle from identification to removal."

• A prototype was due 25 September 2025, with the contract running to September 2027. The ACLU reports the underlying sole-source ICM deal has grown beyond $145 million.

• In September 2025, ICE awarded a further order of approximately $30 million relating to "assisted voluntary return," under a deal reported as worth up to $157.5 million. Reporting places Palantir's total 2025 ICE contract value at approximately $287 million.

• In December 2025, a further contract revealed Palantir building a platform for U.S. Citizenship and Immigration Services — placing the company on both the enforcement and the benefits side of the immigration system.

Palantir systems draw on passport records, Social Security files, IRS tax data and licence-plate reader data, and integrate commercial data-broker feeds including Thomson Reuters CLEAR and LexisNexis. There is no published accuracy rate, no independent audit, and no congressional authorisation debate specific to the platform.

Source: ICE Limited Sources Justification for 70CTD022FR0000170, 17 April 2025; American Immigration Council, https://www.americanimmigrationcouncil.org/blog/ice-immigrationos-palantir-ai-track-immigrants/ ; ACLU, "All the Ways Palantir is Assisting Trump's Abusive Removal Campaign," https://www.aclu.org/news/privacy-technology/palantir-deportation-roundup ; Forbes, https://www.forbes.com/sites/the-wiretap/2025/09/30/ice-gives-palantir-30-million-for-immigrant-voluntary-return/ ; The Register, https://www.theregister.com/2025/04/21/ice_enlists_palantir_to_develop/ ; 404 Media; Washington Post, December 2025.

United Kingdom — the NHS Federated Data Platform

[OFFICIAL RECORD] In November 2023, NHS England awarded a Palantir-led consortium — including Accenture, PwC, NECS and Carnall Farrar — the contract for the NHS Federated Data Platform, with a headline value of up to £330 million over seven years. Palantir's own published share was approximately £182 million. Palantir had previously received approximately £60 million in COVID-era contracts awarded without competition.

• The published contract was heavily redacted, with roughly 200 pages entirely blacked out.

• Foxglove, Just Treatment, the Doctors' Association UK and the National Pensioners Convention brought a legal challenge arguing there was no lawful basis to proceed without returning to Parliament. Approximately 50,000 patients joined opposition campaigns. The judicial review did not halt the rollout.

• In May 2026, NHS England confirmed that Palantir staff can access identifiable patient information within the platform's National Data Integration Tenant. In July 2026, NHS England admitted that its Data Protection Impact Assessment had inaccurately stated who could access patient information, failing to disclose that access. The National Data Guardian sought answers.

• In a Commons debate on 16 April 2026, Liberal Democrat MP Martin Wrigley told Parliament the contract "delivers a subscription service that leaves no deliverables after the subscription — no software, no improvements and no intellectual property after spending more than £330 million," and that all specially written software, intellectual property and know-how remain with the supplier on termination. He described the arrangement as "a permanent lock-in; a single point of failure."

• The National Infrastructure and Service Transformation Authority has estimated a whole-life cost above £1 billion. The BMJ published analysis finding the benefits claimed from the initial Chelsea and Westminster trial to be exaggerated. The National Audit Office has not confirmed Palantir's benefit figures.

• The government confirmed in 2026 that it is reviewing whether to trigger a break clause in spring 2027. The British Medical Association has instructed doctors to limit engagement. A cross-party committee of MPs has urged the government to walk away, describing reliance on the U.S. firm as "an unacceptable point of weakness."

Palantir denies that the access campaigners fear would be lawful or possible under the contract terms, and NHS officials state safeguards are in place.

Source: Hansard, House of Commons, NHS Federated Data Platform debate, 16 April 2026, https://hansard.parliament.uk/Commons/2026-04-16/debates/2FDCA71C-D0C1-4738-BEE8-A4BDA311DB99/NHSFederatedDataPlatform ; Foxglove, https://www.foxglove.org.uk/2023/11/30/legal-action-palantir-nhs-federated-data-platform/ ; The Register, https://www.theregister.com/2026/04/20/palantir_nhs_break_clause/ and https://www.theregister.com/public-sector/2026/07/29/nhs-england-rapped-over-inaccurate-palantir-patient-data-disclosure/ ; The Lowdown, https://lowdownnhs.info/topics/accountablility/palantir-the-controversy-the-contracts-and-the-campaign/ ; Medact report endorsed by Good Law Project, Privacy International, Just Treatment, Corporate Watch and supported by Amnesty International, March 2026.

Israel and Gaza

In January 2024, following a meeting in Tel Aviv between Israeli defence officials and Palantir co-founders Peter Thiel and Alex Karp, Palantir announced a strategic partnership with Israel's Ministry of Defense to supply artificial intelligence technology in support of war-related missions. Asked about ethical concerns at the Cambridge Union on 8 May 2024, Thiel said: "My bias is to defer to Israel. It's not for us to second-guess everything."

The relationship between AI-assisted targeting systems and civilian casualty thresholds in Gaza is documented at length in Chapter Five of No Ethics In Big Tech and in reporting by +972 Magazine and Local Call. It is not re-litigated here; readers requiring that record should consult those sources directly.

Source: Bloomberg, 12 January 2024; Palantir Technologies press release, January 2024; Cambridge Union recording, 8 May 2024; +972 Magazine and Local Call investigations; No Ethics In Big Tech, Chapter Five.

4.2 Clearview AI

[ADJUDICATED — MULTIPLE JURISDICTIONS] Clearview AI was founded in 2017 with backing from investors including Peter Thiel. It built a facial-recognition database — estimated at tens of billions of images — by scraping photographs from websites including Facebook, Instagram, Venmo and YouTube, and sold identification services to law enforcement agencies including the FBI and ICE.

Clearview's position is that it has no establishment, customers or activities in the European Union and is therefore not subject to the GDPR. European regulators reject this, holding that the GDPR applies extraterritorially to the processing of EU residents' data. The Dutch authority stated it would investigate whether company directors could be held personally liable. In October 2025, the privacy organisation noyb filed a complaint focused on Clearview's disregard of fines across France, Greece, Italy, the Netherlands and the UK — noting that more than $100 million in penalties remains uncollected.

Source: European Data Protection Board, https://edpb.europa.eu/news/national-news/2022/french-sa-fines-clearview-ai-eur-20-million_nl ; Library of Congress Global Legal Monitor, https://www.loc.gov/item/global-legal-monitor/2024-10-16/netherlands-face-recognition-company-clearview-ai-fined-for-violating-eus-general-data-protection-regulation/ ; Forbes, https://www.forbes.com/sites/roberthart/2024/09/03/clearview-ai-controversial-facial-recognition-firm-fined-33-million-for-illegal-database/ ; The Register (noyb complaint), https://www.theregister.com/offbeat/2025/10/28/clearview_ai_faces_criminal_heat_for_ignoring_eu_data_fines/ ; Solomon, https://wearesolomon.com/en/mag/format/investigation/clearview-how-a-shady-us-ai-company-dodged-fines-and-defied-regulators-across-europe/

4.3 eBay — the corporate parent, and what it did to two journalists

PayPal was owned by eBay Inc. from 2002 until its spin-off in 2015. The eBay cyberstalking prosecution is included here because it is the single most fully adjudicated demonstration in the modern technology sector of what a corporation will do to journalists who cover it — and because it produced criminal convictions, not settlements.

[ADJUDICATED — CRIMINAL CONVICTIONS] Between approximately 5 August and 6 September 2019, employees of eBay conducted a campaign of harassment and intimidation against David and Ina Steiner, a married couple in Natick, Massachusetts, who publish the e-commerce newsletter EcommerceBytes. Senior executives were frustrated by the newsletter's tone, content, and reader comments.

The campaign, as described in Department of Justice filings, included anonymous and disturbing deliveries to the victims' home — among them live spiders, live cockroaches and a funeral wreath — threatening private and public messages on Twitter, threats to visit the couple in Natick, travel to Natick to surveil them, and the installation of a GPS tracking device on their car. Two defendants deleted digital evidence when they learned of the police investigation; one gave false statements to police and internal investigators and falsified records.

In July 2026, eBay, its former chief executive Devin Wenig and other senior executives agreed to pay nearly $56 million to settle the Steiners' civil claims. Communications disclosed in the civil litigation showed Wenig writing of Ina Steiner that the company should "take her down." Wenig was not named in the criminal case and has stated the harassment was "deliberately done in secret and without my knowledge."

United States Attorney Rachael S. Rollins said at sentencing: "Mr. Baugh and Mr. Harville used the internet's power to harass and intimidate a couple who did nothing — nothing — other than publish content that our First Amendment protects… all the more because these men were seasoned and highly paid security executives backed by the resources of a Fortune 500 corporation."

Source: U.S. Department of Justice, District of Massachusetts, press releases: https://www.justice.gov/usao-ma/pr/two-former-ebay-executives-sentenced-prison-cyberstalking ; https://www.justice.gov/usao-ma/pr/two-former-ebay-employees-sentenced-aggressive-cyberstalking-campaign ; https://www.justice.gov/usao-ma/pr/final-defendant-ebay-cyberstalking-case-sentenced ; CNBC, 28 July 2026, https://www.cnbc.com/2026/07/28/ebay-blogger-harassment-stalking-steiner.html ; U.S. Press Freedom Tracker, https://pressfreedomtracker.us/all-incidents/six-former-ebay-employees-arrested-alleged-harassment-campaign-against-journalists/ ; NPR, https://www.npr.org/2022/09/30/1126078948/live-spiders-and-cockroaches-ex-ebay-executives-get-prison-time-in-harassment-pl

Part V — The Epstein Nexus

5.1 The document releases

• 26 September 2025 — House Oversight Committee Democrats released a third batch of records produced by the Epstein estate, including phone message logs, flight logs and manifests, financial ledgers, and Epstein's daily schedule, containing references to Elon Musk, Peter Thiel, Steve Bannon and Prince Andrew.

• 30 January 2026 — the Department of Justice released approximately three million pages of records.

• NBC News reported in February 2026 that the documents show Epstein in contact with at least twenty prominent technology executives, investors and researchers.

Source: House Committee on Oversight and Government Reform (Democrats), 26 September 2025, https://oversightdemocrats.house.gov/news/press-releases/oversight-democrats-release-third-batch-documents-jeffrey-epstein-estate ; CBS News live coverage, https://www.cbsnews.com/live-updates/epstein-files-released-doj-2026/ ; NBC News, https://www.nbcnews.com/tech/tech-news/jeffrey-epstein-files-reveal-deep-tech-ties-musk-gates-rcna257092 ; Al Jazeera, https://www.aljazeera.com/news/2025/9/27/elon-musk-peter-thiel-steve-bannon-among-names-in-new-epstein-documents

5.2 Peter Thiel and Valar Ventures

[REPORTED — PRIMARY DOCUMENTS] The New York Times reported in June 2025, based on a confidential financial analysis prepared for Epstein's estate and a statement from Valar Ventures, that Epstein committed $40 million across two funds managed by Valar Ventures in 2015 and 2016. Valar was co-founded by Peter Thiel in 2010 and invests principally in financial-technology companies including Wise, Qonto and Xero.

• The position was later valued at approximately $170 million and reported as the largest single remaining asset of Epstein's estate, within a total remaining estate value of roughly $200 million.

• The Times noted that Epstein rarely took passive positions in outside funds, making this an unusual allocation.

• Forbes reported in February 2026, based on the released correspondence, that Epstein repeatedly invited Thiel to his island; in one 2014 message Epstein wrote, "would you prefer to visit the island or i can meet in ny." Thiel's spokesperson, Jeremiah Hall, states that Thiel never travelled to the island.

• Valar's spokesperson, Aaron Curtis, stated that a firm representative met Epstein in 2014 because he was regarded as a "well-known adviser to world leaders, top universities, and philanthropic organizations."

• Thiel has publicly described meeting Epstein a small number of times beginning in 2014, following an introduction he attributed to the LinkedIn network.

Source: New York Times, June 2025; Forbes, Iain Martin, 5 February 2026, https://www.forbes.com/sites/iainmartin/2026/02/05/epstein-in-silicon-valley-failed-to-capitalize-on-connections/ ; Gizmodo, https://gizmodo.com/jeffrey-epstein-reportedly-invested-40-million-in-a-company-co-founded-by-peter-thiel-2000611462 ; Daily Beast; CNBC, https://www.cnbc.com/2026/02/09/tech-leaders-epstein-records-silicon-valley-sergey-brin-thiel-sinofsky-reid-hoffman-musk-gates.html

5.3 Elon Musk

[REPORTED — PRIMARY DOCUMENTS] The released records include email exchanges between Musk and Epstein and calendar entries referencing him.

• A 25 November 2012 email from Epstein asks Musk how many people he would bring for a helicopter transfer to the island. Musk responded, "Probably just Talulah and me," referring to his then-wife Talulah Riley, and asked, "What day/night will be the wildest party on your island?"

• On Christmas Day 2012, Musk wrote again about party plans, adding: "The invitation is much appreciated, but a peaceful island experience is the opposite of what I'm looking for."

• A November 2013 email from Epstein invites Musk to the Caribbean for Christmas.

• A scheduling note from Epstein's assistant Lesley Groff records that Musk "is to go to the island on Dec. 6th"; a subsequent 5 December 2014 entry reads: "Reminder: Elon Musk to island Dec. 6 (is this still happening?)"

Musk's response: He states he "declined repeated invitations" from Epstein and has said that "no one had pushed harder than me" for the release of the Epstein files. In June 2025 Musk publicly alleged that President Trump appears in the files, prompting Representative Suhas Subramanyam to write to the Attorney General demanding immediate unredacted release.

Source: TIME, https://time.com/7362868/elon-musk-epstein-emails/ ; CBS News, https://www.cbsnews.com/live-updates/epstein-files-released-doj-2026/ ; NBC News, 31 January 2026; Office of Rep. Suhas Subramanyam, 5 June 2025, https://subramanyam.house.gov/media/press-releases/congressman-suhas-subramanyam-calls-doj-immediately-release-epstein-files

5.4 Reid Hoffman

See section 3.3. Hoffman is the most extensively documented and most publicly forthcoming of the three, having issued a formal apology in 2019 and materially revised his account twice — in December 2025 and February 2026 — as new records emerged. He has called for full release of the files.

5.5 The August 2015 dinner

The single most documented convergence: a dinner Hoffman hosted in Palo Alto in August 2015, attended by Jeffrey Epstein, Joi Ito, Mark Zuckerberg, Elon Musk, Peter Thiel and Ed Boyden. Hoffman connected Zuckerberg and Epstein by email after the event. Meta directed enquiries to a 2019 statement that Zuckerberg did not communicate with Epstein again after the dinner.

This dinner occurred seven years after Epstein's conviction for procuring a child for prostitution. Every attendee had access to a search engine.

Source: CNBC, 9 February 2026; Axios, 12 September 2019; NBC News, February 2026.

Part VI — Political Capture and the Revolving Door

The distinctive feature of this network is not that its members are wealthy or that they hold opinions. It is that the same individuals now occupy positions on both sides of the regulatory relationship — as vendors to the state, as donors to the officials who set state policy, and as officeholders within the state itself.

6.1 Legislative and oversight activity to date

• 5 May 2025 — Senator Elizabeth Warren letter to the Office of Government Ethics regarding the Sacks waiver.

• 17 September 2025 — Warren and seven members of Congress question whether Sacks exceeded the 130-day Special Government Employee cap.

• 18 November 2025 — Senate Banking Committee members write to Max Levchin requesting BNPL lending data.

• 24 May 2023 — eleven House members write to PayPal on the exclusion of Palestinians.

• 26 September 2025 — House Oversight Democrats release Epstein estate records naming Musk and Thiel.

• 16 April 2026 — UK House of Commons debate on the Palantir NHS contract; cross-party committee urges the government to exit.

• 5 December 2025 — European Commission issues the first DSA non-compliance fine, against X.

Part VII — The International Record

This network is not an American problem. Regulators, parliaments and courts on four continents have made findings. The table below is a jurisdictional index for practitioners.

Part VIII — Open Questions

The following questions are not rhetorical. Each is answerable with documents that exist, held by parties who can be compelled or asked to produce them. They are set out here so that any attorney, journalist, legislator or auditor picking up this file knows where the record currently stops.

For counsel and regulators

• What is the legal basis and transfer mechanism under GDPR Articles 6, 9, 28 and 44–49 for processing EU and EEA residents' biometric data through AU10TIX Limited (Israel)? Produce the Data Processing Agreement and the transfer impact assessment.

• Did PayPal notify EU, EEA, UK or Swiss customers of the AU10TIX credential exposure reported in June 2024? If not, on what basis was notification deemed unnecessary under Articles 33 and 34?

• What retention schedule applies to identity-document images and selfie images processed by AU10TIX on PayPal's behalf, and in which jurisdictions are they stored and backed up?

• Following the transfer to PayPal Israel Payments Services Ltd., which legal entity is the data controller for residents of East Jerusalem, and before which forum are their data-subject rights enforceable?

• What is the documented, evidence-based basis for PayPal's classification of the Palestinian territories as "high risk," and how does that assessment compare with the assessments applied to Yemen and Somalia, where PayPal operates?

• In the ICE ImmigrationOS procurement, what evidence supported the sole-source determination that Palantir was the only capable vendor? Produce the market research underlying the Limited Sources Justification.

• What is the false-positive rate of ImmigrationOS targeting outputs, and what human review is required before an enforcement action proceeds from an algorithmic flag?

• Under the NHS Federated Data Platform contract, exactly which Palantir personnel can access identifiable patient data in the National Data Integration Tenant, under what authorisation, and with what audit trail?

• Why has no European regulator collected any portion of more than $100 million in Clearview AI penalties, and what enforcement mechanism is being developed?

For journalists

• Which other publications, if any, were targeted by litigation funded by Peter Thiel? He confirmed in 2016 that Gawker was "not the only one" and declined to identify the others. That statement is nine years old and remains unanswered.

• What did AU10TIX tell PayPal about the June 2024 credential exposure, and when?

• How many PayPal users worldwide have had identity documents processed by AU10TIX since the relationship began?

• What is the current status of the SEC action against Elon Musk following the 3 February 2026 denial of his motion to dismiss?

• Has David Sacks exceeded the 130-day Special Government Employee limit, and what record exists of days served? Eight members of Congress asked in September 2025.

For prospective employees and commercial partners

This fact sheet exists in part for a specific reader: the engineer holding an offer letter, and the procurement officer holding a term sheet. The questions for that reader are simpler.

• Ask what the product is used for, by whom, in which jurisdictions, and under what oversight. Ask in writing. Keep the answer.

• Ask whether the contract you are being asked to service was competitively tendered, and if not, why not.

• Ask what happens to your work product if the contract terminates. In the NHS case, Parliament was told the answer is: nothing remains. No software. No intellectual property. No know-how.

• Ask what happened to the last person who asked.

Master Source List

All URLs below were retrieved and confirmed live on 24 August 2026. Sources are grouped by type. Primary documents — regulator orders, court filings, company legal pages, parliamentary records — are listed first, as these are the sources most likely to be needed as exhibits.

A. Primary documents — company, regulator, court, parliament

1. PayPal, "List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared," last updated 1 July 2026. https://www.paypal.com/ie/legalhub/paypal/third-parties-list — see entry "Au10tix Limited (Israel)" under section 2, Credit Reference and Fraud Agencies.

2. PayPal, User Agreement for PayPal Services (Israel), effective 6 July 2026. https://www.paypal.com/il/legalhub/paypal/useragreement-full?locale.x=en_IL — PDF: https://www.paypalobjects.com/marketing/ua/OA/useragreement-full/en-IL-070626.pdf

3. PayPal, Policy Updates (Israel). https://www.paypal.com/il/legalhub/paypal/upcoming-policies-full?locale.x=en_IL

4. PayPal data breach notification letter, 10 February 2026 (PayPal Working Capital). https://hackread.com/wp-content/uploads/2026/02/paypal-february-2026-breach-notification.pdf

5. New York State Department of Financial Services, Consent Order re PayPal, Inc., 23 January 2025. https://www.dfs.ny.gov/

6. PayPal Holdings, Inc., Form 10-Q, FY2025. https://www.sec.gov/Archives/edgar/data/1633917/000163391725000196/pypl-20250930.htm

7. PayPal Investor Relations, "PayPal to Acquire Curv," 2021. https://about.pypl.com/news-details/2021/PayPal-to-Acquire-Curv/default.aspx

8. PR Newswire, "PayPal Partners with ADL to Fight Extremism," 26 July 2021. https://www.prnewswire.com/news-releases/paypal-partners-with-adl-to-fight-extremism-and-protect-marginalized-communities-301340411.html

9. U.S. Immigration and Customs Enforcement, Limited Sources Justification for Contract 70CTD022FR0000170, 17 April 2025.

10. U.S. Department of Justice, District of Massachusetts, "Two Former eBay Executives Sentenced to Prison for Cyberstalking." https://www.justice.gov/usao-ma/pr/two-former-ebay-executives-sentenced-prison-cyberstalking

11. U.S. Department of Justice, District of Massachusetts, "Two Former eBay Employees Sentenced for Aggressive Cyberstalking Campaign." https://www.justice.gov/usao-ma/pr/two-former-ebay-employees-sentenced-aggressive-cyberstalking-campaign

12. U.S. Department of Justice, District of Massachusetts, "Final Defendant in eBay Cyberstalking Case Sentenced." https://www.justice.gov/usao-ma/pr/final-defendant-ebay-cyberstalking-case-sentenced

13. SEC v. Elon Musk, U.S. District Court for the District of Columbia, complaint filed 14 January 2025.

14. U.S. Senate Committee on Banking, Housing and Urban Affairs, Warren letter to the Office of Government Ethics re David Sacks, 5 May 2025. https://www.banking.senate.gov/imo/media/doc/oge_sacks_letter.pdf

15. U.S. Senate Committee on Banking, letter to Max Levchin re Buy Now Pay Later, 18 November 2025. https://www.banking.senate.gov/imo/media/doc/20251118lettertoaffirmrebnpl.pdf

16. House Committee on Oversight and Government Reform (Democrats), "Oversight Democrats Release Third Batch of Documents from Jeffrey Epstein Estate," 26 September 2025. https://oversightdemocrats.house.gov/news/press-releases/oversight-democrats-release-third-batch-documents-jeffrey-epstein-estate

17. Office of Rep. Suhas Subramanyam, letter to the Attorney General, 5 June 2025. https://subramanyam.house.gov/media/press-releases/congressman-suhas-subramanyam-calls-doj-immediately-release-epstein-files

18. Consumer Financial Protection Bureau, "CFPB Opens Inquiry Into 'Buy Now, Pay Later' Credit," December 2021. https://www.consumerfinance.gov/about-us/newsroom/consumer-financial-protection-bureau-opens-inquiry-into-buy-now-pay-later-credit/

19. U.S. Department of State, Report to the Committee on Foreign Relations: Kenneth A. Howery, Kingdom of Denmark, April 2025. https://www.state.gov/howerykenneth-kingdomofdenmark-april2025

20. U.S. Embassy in the Kingdom of Denmark, Ambassador Howery biography. https://dk.usembassy.gov/ambassador/

21. The American Presidency Project, statement announcing the Howery nomination, 22 December 2024. https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-nomination-ken-howery-ambassador

22. Hansard, House of Commons, "NHS Federated Data Platform," 16 April 2026. https://hansard.parliament.uk/Commons/2026-04-16/debates/2FDCA71C-D0C1-4738-BEE8-A4BDA311DB99/NHSFederatedDataPlatform

23. European Data Protection Board, "The French SA fines Clearview AI EUR 20 million," 20 October 2022. https://edpb.europa.eu/news/national-news/2022/french-sa-fines-clearview-ai-eur-20-million_nl

24. Library of Congress Global Legal Monitor, "Netherlands: Face-Recognition Company Clearview AI Fined," 16 October 2024. https://www.loc.gov/item/global-legal-monitor/2024-10-16/netherlands-face-recognition-company-clearview-ai-fined-for-violating-eus-general-data-protection-regulation/

25. European Commission, Digital Services Act non-compliance decision re X, 5 December 2025 (183 pages).

26. Space Exploration Technologies Corp., Form FWP (recording the €120 million EC decision against XIUC, X, xAI and Elon Musk). https://www.sec.gov/Archives/edgar/data/0001181412/000162828026041365/eu_interviewtranscript06.htm

27. Massachusetts Institute of Technology, L. Rafael Reif, "Jeffrey Epstein and MIT," 22 August 2019. https://orgchart.mit.edu/node/871

28. Peter Thiel, "The Education of a Libertarian," Cato Unbound, 13 April 2009. https://www.cato-unbound.org/2009/04/13/peter-thiel/education-libertarian/

B. Original investigative reporting relied upon

29. Arabic Post (عربي بوست), "‘Palestine’ is missing from the list — and its people’s faces are on file in Tel Aviv." English: https://story360.arabicpost.net/paypal/index-en.html · Arabic: https://story360.arabicpost.net/paypal/index.html — Editing and reporting: Arabic Post team. Design: Saleh Aldahni. This investigation is the originating source for sections 2.1–2.6 of this fact sheet.

30. Joseph Cox, 404 Media, "ID Verification Service for TikTok, Uber, X Exposed Driver Licenses," 26 June 2024. https://www.404media.co/id-verification-service-for-tiktok-uber-x-exposed-driver-licenses-au10tix/

31. Chris McGreal, The Guardian, "US Congress members demand that PayPal end ban on Palestinian business," 24 May 2023. https://www.theguardian.com/technology/2023/may/24/paypal-palestine-ban-us-congress-

32. Ryan Mac, Forbes, on Peter Thiel and the Gawker litigation, 2016–2017. https://www.forbes.com/sites/ryanmac/2017/04/18/peter-thiels-lawyers-now-say-he-was-financially-motivated-in-funding-hulk-hogans-gawker-lawsuit/

33. Iain Martin, Forbes, "Inside Jeffrey Epstein's Secretive Silicon Valley Investments," 5 February 2026. https://www.forbes.com/sites/iainmartin/2026/02/05/epstein-in-silicon-valley-failed-to-capitalize-on-connections/

34. The New York Times, reporting on Epstein's $40 million commitment to Valar Ventures, June 2025; and "Silicon Valley's Man in the White House Is Benefiting Himself and His Friends," November 2025.

35. NBC News, "Jeffrey Epstein files reveal deep tech ties, from Musk to Gates," February 2026. https://www.nbcnews.com/tech/tech-news/jeffrey-epstein-files-reveal-deep-tech-ties-musk-gates-rcna257092

36. CNBC, "Epstein's Silicon Valley ties extended beyond just Musk and Gates," 9 February 2026. https://www.cnbc.com/2026/02/09/tech-leaders-epstein-records-silicon-valley-sergey-brin-thiel-sinofsky-reid-hoffman-musk-gates.html

37. Axios, "Reid Hoffman apologizes for role in Epstein-linked donations to MIT," 12 September 2019. https://www.axios.com/2019/09/12/reid-hoffman-jeffrey-epstein-mit-donations

38. Richard Behar, Forbes, "Inside Israel's Secret Startup Machine," 11 May 2016. https://www.forbes.com/sites/richardbehar/2016/05/11/inside-israels-secret-startup-machine/

39. Haaretz, "PayPal sends in the Israelis," 6 April 2014. https://www.haaretz.com/israel-news/business/2014-04-06/ty-article/.premium/paypal-sends-in-the-israelis/0000017f-e1d2-df7c-a5ff-e3faede90000

40. Reuters, "PayPal sets up Israeli security center, buys CyActive." https://www.reuters.com/article/technology/paypal-sets-up-israeli-security-center-buys-cyactive-idUSKBN0M70VO/

41. MintPress News, February 2026, on user reports of name searches originating in Israel following AU10TIX verification. https://www.mintpressnews.com/x-users-find-their-real-names-are-being-googled-in-israel-after-using-x-verification-software-au10tix/290703/

42. CNBC, "eBay, former execs to pay $56 million in blogger harassment and stalking case," 28 July 2026. https://www.cnbc.com/2026/07/28/ebay-blogger-harassment-stalking-steiner.html

43. NPR, "Live spiders and cockroaches: Ex-eBay executives get prison time," 30 September 2022. https://www.npr.org/2022/09/30/1126078948/live-spiders-and-cockroaches-ex-ebay-executives-get-prison-time-in-harassment-pl

44. NPR, "Trump tech adviser David Sacks under fire over vast AI investments," 12 December 2025. https://www.npr.org/2025/12/12/nx-s1-5631823/david-sacks-ai-advisor-investment-conflicts

45. NPR, "Elon Musk's AI chatbot Grok started calling itself ‘MechaHitler’," 9 July 2025. https://www.npr.org/2025/07/09/nx-s1-5462609/grok-elon-musk-antisemitic-racist-content

46. CNBC, "Elon Musk's xAI probed by California DOJ over Grok's deepfake explicit images," 14 January 2026. https://www.cnbc.com/2026/01/14/elon-musk-xai-california-grok-investigation.html

47. ArcticToday, "Trump's ambassador tasked with getting control of Greenland confirmed," 8 October 2025. https://www.arctictoday.com/trumps-ambassador-tasked-with-getting-greenland-confirmed/

C. Civil society, legal analysis and specialist research

48. Electronic Frontier Foundation, "Hack of Age Verification Company Shows Privacy Danger of Social Media Laws," June 2024. https://www.eff.org/deeplinks/2024/06/hack-age-verification-company-shows-privacy-danger-social-media-laws

49. American Civil Liberties Union, "All the Ways Palantir is Assisting Trump's Abusive Removal Campaign." https://www.aclu.org/news/privacy-technology/palantir-deportation-roundup

50. American Immigration Council, "ICE to Use ImmigrationOS by Palantir." https://www.americanimmigrationcouncil.org/blog/ice-immigrationos-palantir-ai-track-immigrants/

51. Foxglove, "Legal action launched: no legal basis for the £330 million Palantir NHS Federated Data Platform," 30 November 2023. https://www.foxglove.org.uk/2023/11/30/legal-action-palantir-nhs-federated-data-platform/

52. The Lowdown, "Palantir, the controversy, the contracts and the campaign against the FDP." https://lowdownnhs.info/topics/accountablility/palantir-the-controversy-the-contracts-and-the-campaign/

53. 7amleh — The Arab Center for the Advancement of Social Media, PayPal4Palestine campaign. https://7amleh.org/

54. SMEX, "Tech at the Service of Occupation." https://smex.org/tech-at-the-service-of-occupation/

55. Business & Human Rights Resource Centre, "USA: Congress members ask PayPal to end ban on Palestinian business." https://www.business-humanrights.org/en/latest-news/usa-congress-members-ask-paypal-to-end-ban-on-palestinian-business/

56. Council on American-Islamic Relations, press release on the Congressional PayPal letter. https://www.cair.com/press_releases/cair-supports-congressional-call-for-paypal-to-end-ban-on-business-with-palestinians-in-occupied-territories/

57. Revolving Door Project, "Oligarchs and the Trump Admin: Peter Thiel." https://therevolvingdoorproject.org/billionaires-and-the-trump-admin-peter-thiel/

58. Tech Policy Press, "Unpacking the Politics of the EU's €120M Fine of Musk's X." https://www.techpolicy.press/unpacking-the-politics-of-the-eus-120m-fine-of-musks-x/

59. Tech Policy Press, "EU Decision Behind €120m Fine on Musk's X Released by US Lawmakers." https://www.techpolicy.press/eu-decision-behind-120m-fine-on-musks-x-released-by-us-lawmakers/

60. Tech Policy Press, "The US Government's Use of Elon Musk's Grok AI Undermines Its Own Rules." https://www.techpolicy.press/the-us-governments-use-of-elon-musks-grok-ai-undermines-its-own-rules/

61. noyb — European Center for Digital Rights, complaint regarding unenforced Clearview AI penalties, October 2025, reported at https://www.theregister.com/offbeat/2025/10/28/clearview_ai_faces_criminal_heat_for_ignoring_eu_data_fines/

62. Solomon, "How A Shady US AI Company Dodged Fines and Defied Regulators Across Europe." https://wearesolomon.com/en/mag/format/investigation/clearview-how-a-shady-us-ai-company-dodged-fines-and-defied-regulators-across-europe/

63. Hunton Andrews Kurth, "NYDFS Fines PayPal $2 Million for Cybersecurity Failures." https://www.hunton.com/privacy-and-information-security-law/nydfs-fines-paypal-2-million-for-cybersecurity-failures

64. Faegre Drinker, "Lessons from PayPal's $2 Million Cybersecurity Settlement with NYDFS." https://www.faegredrinker.com/en/insights/publications/2025/2/lessons-from-paypal-2-million-cybersecurity-settlement-with-the-new-york-state-department-of-financial-services

65. U.S. Press Freedom Tracker, eBay harassment campaign against journalists. https://pressfreedomtracker.us/all-incidents/six-former-ebay-employees-arrested-alleged-harassment-campaign-against-journalists/

66. Malwarebytes Labs, on the AU10TIX exposure. https://www.malwarebytes.com/blog/news/2024/06/driving-licences-and-other-official-documents-leaked-by-authentication-service-used-by-uber-tiktok-x-and-more

67. R Street Institute, on the AU10TIX exposure. https://www.rstreet.org/commentary/identity-verifier-used-by-big-tech-amid-mandates-has-made-personal-data-easily-accessible-to-hackers/

68. Affirm Holdings, "Lawmakers looking at buy now, pay later should raise the bar," 9 December 2025. https://investors.affirm.com/news-releases/news-release-details/lawmakers-looking-buy-now-pay-later-should-raise-bar

69. The Lever, "Trump Issues Ethics Waiver For His AI/Crypto Czar." https://www.levernews.com/trump-issues-ethics-waiver-for-his-ai-crypto-czar/

70. Jacobin, "Trump's Crypto-Invested AI Czar Cleared to Oversee Crypto." https://jacobin.com/2025/03/crypto-ai-czar-ethics-trump

71. The Block, "White House AI and crypto czar David Sacks rejects fresh conflict of interest claims." https://www.theblock.co/post/380916/white-house-ai-crypto-czar-david-sacks-rejects-conflict-of-interest-claims

72. ADF International, "X challenges €120m fine under EU censorship law." https://adfinternational.org/news/x-challenges-e120m-fine-under-eu-censorship-law/

D. Author's own works, cited as context rather than evidence

73. Vahid Razavi, No Ethics In Big Tech (2026). Introduction by Norman Solomon. https://noethicsinbigtech.com/book/

74. Vahid Razavi, Ethics In Tech and Lack Thereof (2018).

75. Forever Peace Now (documentary film), directed by Vahid Razavi, 2025. https://foreverpeacenow.com/

76. MyAWSStory.com — first-person account of conditions at Amazon Web Services.

77. ParentsPlea.com — record of journalists and civilians killed in conflicts documented in this series.

Methodology, Corrections and Credits

How this fact sheet was compiled

• Every URL cited was retrieved directly and confirmed live on 24 August 2026. Where a document exists in both a summary and a primary form, the primary form is cited.

• Where a claim originates with a single outlet, that is stated in the text.

• Where a subject has issued a denial or a competing account, it appears in the same section as the allegation, in the subject's own words wherever a direct quotation is available.

• No figure, date, contract number, penalty amount or quotation in this document was reconstructed from memory. Each was taken from a retrieved source.

• Where the record is incomplete, the document says so rather than filling the gap.

Corrections

This fact sheet is a living document. It will be revised as records are released, as litigation concludes, and as errors are identified. If you believe any statement here is inaccurate, incomplete, or unfairly framed, write to the publisher through NoEthicsInBigTech.com. Corrections will be made promptly and logged with the date and the substance of the change. Every subject named in this document has a standing right of reply, and any response received will be published alongside the relevant section.

Arabic Post contacted both PayPal and AU10TIX for comment on the findings in their investigation and received no response before publication. That offer is renewed here.

Attribution

The investigative findings in Part II originate with Arabic Post and are used with attribution in accordance with the terms Arabic Post publishes: their text may be reused provided the source is credited. Credit for that reporting belongs to the Arabic Post editorial team, with design by Saleh Aldahni. Readers are urged to read the original investigation in full, in English or Arabic, at story360.arabicpost.net.

The 404 Media reporting on the AU10TIX credential exposure is the work of Joseph Cox, based on findings by Mossab Hussein of spiderSilk. The Gawker reporting is the work of Ryan Mac at Forbes and Andrew Ross Sorkin at the New York Times. The Valar Ventures reporting is the work of the New York Times. The Palestine reporting is the work of Chris McGreal at The Guardian, developed with 7amleh. Journalism made this document possible; it is not a substitute for it.

© 2026 Vahid Razavi. Licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License. http://creativecommons.org/licenses/by-nc-nd/4.0/

No Ethics In Big Tech Fact Sheet Series · NoEthicsInBigTech.com · Edition 1.0, August 2026