CLEARVIEW AI

OLYMPUS opened an institutional file. A firm has no Big Five and no Dark Triad, and the unit does not invent them; what a firm has is an asset, a client list, and an enforcement record. Clearview AI is catalogued here as the dragnet — the private company that scraped the open web into a reverse index of the human face and sold the search box to police. The finding is not any single search. It is the asset: thirty billion faces by the company’s own count, held by a firm that four European regulators fined, one American class sued into part-ownership, and one American state could not establish jurisdiction over. The numbers in the front matter are reach, entrenchment, and durability — not malice.

Institutional Archetype

THE DRAGNET — The archetype is the net cast before anyone consented to swim. Clearview does not run cameras, does not arrest anyone, and does not write policing policy; it scraped faces already posted — social media, employer pages, news sites, anywhere a face sat next to a name — and turned the scrapings into a search engine for people. The instrument is the database. The leverage is that it cannot be un-scraped: a deletion order in Italy reaches the Italians Italy can prove are in the net, and the net keeps the rest. Every enforcement action in this file ran into the same asymmetry — the remedy is jurisdictional, the asset is not.

Mandate & Origin

Clearview AI was founded in 2017 by Hoan Ton-That (co-founder and chief executive — cross-reference Hoan Ton-That) and Richard Schwartz, and operated in near secrecy until the New York Times exposed it on January 18, 2020 — at which point, per the Times investigation, its database held some three billion images and its tool was in use by more than 600 law-enforcement agencies, including the FBI and the Department of Homeland Security. By March 2023 the company’s own figures, announced by its chief executive, had grown to 30 billion+ scraped facial images, roughly one million police searches, and 3,100+ agencies among its clients — company self-report, unaudited. The company has stated a goal of 100 billion images.

In its own words. Clearview’s home page now claims “70+ Billion Images in our law enforcement database — the largest in the world by far,” and states its mission as “To help reduce crime, fraud and risk, to create safer communities and ensure secure commerce, and enhance our national security and military defense” (clearview.ai). The Seventh Circuit’s description of the product, in an opinion of 13 July 2026, is that Clearview “operates “a search engine for faces.”” (In re Clearview AI Consumer Privacy Litigation, No. 25-1673 (7th Cir.), opinion of 13 July 2026). The company’s own leadership page lists an advisory board and no executive team: Raymond Kelly (“Former NYPD Commissioner”), Steve K. Francis (“Acting Executive Associate Director, Homeland Security Investigations (Retired)”), Floyd Abrams (“Of Counsel, Cahill Gordon”), Rudy Washington (“Former Deputy Mayor of NYC”), Richard Clarke (“Former National Coordinator for Counter-terrorism, Former Deputy Assistant Secretary State Department”) and Amb. Lee Wolosky (“Former Special Envoy for Guantanamo Closure; Partner, Jenner & Block”) (clearview.ai/leadership). The chief executive’s seat has moved since Ton-That: The Record reported in February 2025 that “Hoan Ton-That has been succeeded by Hal Lambert and Richard Schwartz” (The Record, 21 February 2025), and a speaker biography published under Amos Kyler’s name says “As CEO, he guides Clearview AI’s overall vision, strategy, and growth,” adding that he previously served as CTO and joined in 2019 (Potomac Officers Club).

Funding & Backers

Clearview is a commercial firm, and its capital history is thin enough to be load-bearing. Early backing included $200,000 from Peter Thiel, per the Times investigation. By the time the Illinois biometric-privacy class settlement was structured in March 2025, the company could not fund a cash settlement: the class instead received a ~23% equity stake ($51.75M against a **$225M** valuation). Read the cap table after that settlement and the finding writes itself: the people the company scraped without consent are now among its owners, and their compensation is tied to the continued commercial success of the machine that scraped them.

The settlement, in the Seventh Circuit’s words. The court that heard the objectors’ appeal (No. 25-1673, argued 28 January 2026, decided 13 July 2026, Judge Hamilton writing for a panel of Hamilton, Maldonado and Taibleson) records that the first round of mediation “fell apart because Clearview, an undercapitalized start-up, was not in the financial condition to make a large and immediate payment,” and that the parties then agreed that payment would come through “what amounted to an equity stake.” On an initial public offering or a “liquidation event” the Class would receive “a payment equivalent to a 23% equity stake in Clearview as of September 6, 2023, “subject to the same dilution by future investments as for the founders,”” or the settlement master could instead sell the stake or make a cash demand for 17% of Clearview’s GAAP-recognized revenue from the date of final approval, no later than 30 September 2027. The stake was divided “ten shares to each member of the Illinois Subclass, five shares to each member of the California, New York, and Virginia Subclasses, and one share to each member of only the Nationwide Class,” and “Clearview has not committed to any additional limits on its business activities.” The panel found “no inherent substantive problems” with the absence of injunctive relief or with an equity payment, and held the other way on process: “Class-action settlement requires structural assurances of fair and adequate representation, and those were lacking here. We therefore vacate approval of the settlement and remand for further proceedings,” adding that “this is a general remand, and this opinion does not imply that any future settlement needs to be substantially similar to the one we review here” (Seventh Circuit opinion, 13 July 2026). The March 2025 approval described above therefore no longer stands, and the class’s stake is back before the district court.

Institutional Voice & Intent

The voice is the odometer — the company’s public register is its database milestone, announced by its chief executive to the press: three billion, thirty billion, a hundred billion to come. Where the field’s other institutions speak in “decision intelligence” and “emerging risks,” Clearview speaks in inventory. The persuasion is in the scale itself: a number that large reads as inevitability, and inevitability is the strongest sales argument a surveillance vendor can make.

Stated intent: Provide an after-the-fact investigative tool that helps law enforcement identify suspects, victims, and witnesses from images — built on publicly available photographs.

Observed intent: Build and hold the largest privately owned index of the human face, sell search access to as many agencies as possible, and keep the asset beyond the effective reach of any single regulator.

Gap: The jurisdictional defense is not incidental to the business — on the record, it is the business’s most successful legal product. The UK First-tier Tribunal accepted in 2023 that a foreign firm serving foreign law-enforcement clients sat outside UK data-protection law; a Vermont judge held in December 2025 that the company “conducts no substantial business in Vermont” and dismissed the state’s suit on personal jurisdiction. A firm whose product is everyone’s face turns out, when sued, to be located nowhere in particular. That is the gap between the stated intent (a lawful tool for police) and the observed structure (an asset engineered to survive every remedy aimed at it).

Interest: What each position pays, documented, with the best case its holders state. The positions are Clearview’s own, taken from its pages, its contracts and the courts’ records of its litigation; the agencies that buy and the regulators and plaintiffs it faces are named where the record places them beside it.

• Government agencies should be able to license a face search of the public web. Position: the company’s mission, “To help reduce crime, fraud and risk, to create safer communities and ensure secure commerce, and enhance our national security and military defense” (clearview.ai). What it pays: USAspending lists 22 awards to Clearview, Inc. from eight federal awarding agencies, $12.4 million at award value, of which ICE holds four worth $11.3 million, among them 70CMSD25P00000111 ($7,687,500 obligated, $9,225,000 ceiling, 5 September 2025 to 4 September 2027) (USAspending, ICE award 70CMSD25P00000111). The rule that makes this possible was written into the court order itself: the consent order of 11 May 2022 bars private customers nationwide but “in no way limits Clearview’s ability to work with federal or other State government agencies” (Consent Order, ACLU v. Clearview AI, No. 2020 CH 04353 (Cook County Cir. Ct., 11 May 2022)), and the Seventh Circuit records that since then Clearview’s customers “have included only federal and state government agencies and their contractors.” Best case, the award’s own: “THIS AWARD PROCURES FACIAL RECOGNITION SOFTWARE, WHICH SUPPORTS HOMELAND SECURITY INVESTIGATIONS WITH CAPABILITIES OF IDENTIFYING VICTIMS AND OFFENDERS IN CHILD SEXUAL EXPLOITATION CASES AND ASSAULTS AGAINST LAW ENFORCEMENT OFFICERS.” Who else gains: the investigating agencies that hold the licences. The same order’s five-year ban on Illinois government access, entered 11 May 2022, runs out in May 2027.
• A foreign regulator cannot reach a firm that serves foreign police. Position: the argument the First-tier Tribunal accepted in October 2023, that serving foreign law-enforcement clients put the processing outside UK data-protection law. What it pays: no UK penalty while the ground stood. The Upper Tribunal rejected it on three of four grounds: “Clearview’s processing of personal information is related to monitoring of behaviour of UK residents,” and the case went back “to determine the substantive appeal” on the footing that the Commissioner had jurisdiction (ICO, Upper Tribunal judgment, October 2025). The ICO’s update records that on 19 December 2025 the Upper Tribunal granted Clearview “permission to appeal its decision to the Court of Appeal.” Best case, the company’s: a foreign firm working for foreign agencies is not a UK monitor of UK behaviour; the Commissioner’s, John Edwards: “It is essential that foreign organisations are held accountable.” Who else gains: none documented beyond Clearview’s foreign-agency customers.
• Settle in stock, without injunctive relief. Position: the 2023 mediation outcome the Seventh Circuit describes, in which “Clearview was not likely to agree to a settlement that surrendered its business model.” What it pays: the firm keeps its cash and its business model while the class holds a contingent claim on a liquidation event; the court’s own count is that “Clearview has not committed to any additional limits on its business activities.” Best case, the court’s: litigating on “may well have exhausted Clearview’s assets before it could pay anything at all.” Who else gains: the Illinois subclass, which took ten shares a head against one for the nationwide class, and the objectors’ point, which succeeded, was that no representative of the nationwide class endorsed that split (Seventh Circuit opinion).

Interest is a documented fact about each position, not a claim about motive, and not a verdict that the argument is wrong. Each best case is stated at the strength its author states it.

Position in the Apparatus

Clearview is the privatized square of the convergence table. In China the state runs the face layer directly; in Britain the Metropolitan Police operate Live Facial Recognition under their own published policy; in the United States there is no federal ban and the capability is largely privatized into the identity layer — and the name in that cell is Clearview. The research corpus places it in the facial-recognition-deployers and surveillance-customer-cohort clusters alongside Palantir, Anduril, NSO, and Cellebrite (cross-reference Palantir); the structural contrast is with the state-run enrollment systems (cross-reference Aadhaar / UIDAI) — Aadhaar enrolls you with your thumbprint on a form, Clearview enrolled you the day you posted a photograph. The body-layer rhyme is with the genetic database (cross-reference 23andMe): both files end with the asset changing hands in ways none of the people in the database chose — one in bankruptcy, one in a settlement paid in stock.

Actions & Leadership Choices

Founding purpose, judged on evidence. The scrape was the founding act, not a drift. The company assembled its database by harvesting faces from the open web without the consent of the people in it, and sold search access to police — that is the business as documented from the first public account of it in January 2020. This is not a neutral-tool prior gone wrong at the margins; non-consent is the input the product is made of. The deeds below are weighed against that, and so are the defenses.

Consequential actions — the enforcement ledger. Europe fined it on four fronts: Italy’s Garante, EUR 20M (February 2022, with a deletion order); France’s CNIL, EUR 20M (October 2022) plus a EUR 5.2M overdue penalty (April 2023); Greece’s HDPA, EUR 20M (July 2022); and the Dutch DPA, EUR 30.5M (September 2024) — which, in Reuters’ dry summary, did not stop the US business. Britain’s ICO fined it GBP 7.5M with a deletion order in May 2022; the First-tier Tribunal overturned the action on jurisdiction in October 2023; the Upper Tribunal restored three of the four grounds in October 2025; and in December 2025 Clearview was granted permission to appeal again — the fine is currently remitted, not finally upheld, and this file does not state otherwise. In Illinois, the one American statute with real teeth — the Biometric Information Privacy Act — produced the March 2025 settlement paid in equity described above. And Vermont’s attorney general, Charity Clark, refiled suit in April 2025 under the state’s Consumer Protection Act, alleging the company stored the biometric identifiers of Vermonters, “including children,” without consent; in December 2025 the case was dismissed for lack of personal jurisdiction — the merits were never adjudicated, and the State’s allegation remains exactly that, an allegation.

The steel-man travels with the file. Two defenses are documented and both are real. First, the company’s product is, by US government testing standards, among the most accurate facial-recognition systems available — accuracy is not the problem this file documents. Second, its jurisdictional arguments have repeatedly won: the UK Tribunal accepted them once and the fight is still live; Vermont’s suit died on them. The wrongful-arrest record that shadows this technology class — the NIST finding that false-positive rates run ten to one hundred times higher for Asian and African American faces, the Detroit arrests of Robert Williams and Porcha Woodruff — belongs to facial recognition generally and is not attributed to Clearview’s product; the Nijeer Parks case, sometimes attached to the company, is specifically un-attached here — his attorney retracted the attribution and the company denies it. The discipline matters because the file does not need the embellishment: the finding against Clearview is the database, not the error rate.

Leadership choices. The company’s public face through these years was its co-founder and, until February 2025, chief executive, Hoan Ton-That (cross-reference Hoan Ton-That), whose signature act as leader is the announcement of the database’s growth — three billion at exposure, thirty billion by his own March 2023 statement, one hundred billion as the stated goal — through five years of multinational enforcement that never stopped the scrape. The choice on the record is continuity: fined in Italy, France, Greece, and the Netherlands; litigated to a standstill in Britain; sued into part-ownership in Illinois — and still operating, still growing, still selling.

The orders, in the courts’ and regulators’ own words. Illinois, the ACLU case. In ACLU v. Clearview AI, Inc., No. 2020 CH 04353, Judge Pamela McLean Meyerson of the Cook County Circuit Court entered on 11 May 2022 a “Consent Order of Permanent and Time-Limited Injunctions.” It records that it was entered “without admission of any fact alleged or liability of any kind,” that “The Court makes no final determination on the merits,” and orders that “Clearview is permanently enjoined from granting paid or free access to the Clearview database of alleged facial vectors” to private entities and individuals anywhere in the United States, with exceptions for use consistent with BIPA. For five years from entry it bars access for Illinois state, county and local agencies, including police, and for any private entity located in Illinois. Paragraph 6 leaves the rest standing: the order “does not restrict Clearview’s ability to contract with third parties, including with any and all federal government agencies (even those in Illinois), and any other State or local government agencies outside of Illinois” (Consent Order, 11 May 2022, the signed order as the court entered it). Illinois, the class case. The class settlement approved on 20 March 2025 was vacated by the Seventh Circuit on 13 July 2026, as set out under Funding & Backers.

Italy. The Garante’s injunction order of 10 February 2022 (register entry no. 50) orders Clearview “di pagare la somma di euro venti milioni a titolo di sanzione amministrativa pecuniaria,” imposes “il divieto di prosecuzione del trattamento e di ulteriore raccolta, mediante tecniche di web scraping,” “ordina la cancellazione dei dati, comuni e biometrici,” and requires it to designate a representative in the Union, all as to people in Italy (Garante, doc. web n. 9751362). The Netherlands. The Dutch authority’s notice, published 3 September 2024, gives the final decision date as 16 May 2024, the fine as “a total amount of € 30 500 000,” and finds that Clearview processes personal data “without a legal basis to do so” (EDPB national news, Dutch SA). Australia. The Australian Information Commissioner found in November 2021 that Clearview breached the Privacy Act by “collecting Australians’ sensitive information without consent” and among other breaches, and the determination requires it “to cease collecting facial images and biometric templates from individuals in Australia” and “to destroy existing images and templates collected from Australia”; Commissioner Angelene Falk said “The indiscriminate scraping of people’s facial images” may adversely affect the personal freedoms of all Australians. No penalty was imposed by that determination (OAIC). The United Kingdom. The ICO’s own account of the Upper Tribunal result is that its appeal succeeded on “three of the Commissioner’s four grounds of appeal,” that the matter returns to the First-tier Tribunal “to determine the substantive appeal,” and, in its update of 19 December 2025, that Clearview was granted “permission to appeal its decision to the Court of Appeal” (ICO).

Federal contracts, from the award records. USAspending’s award search for recipient “CLEARVIEW AI, INC.” returns 22 contract awards, $12,415,542 at award value, from eight awarding agencies. Immigration and Customs Enforcement: 70CMSD20P00000130 (“CLEARVIEW LICENSES,” $224,000, 12 August 2020 to 4 September 2021); 70CMSD21P00000127 (“CLEARVIEW FACIAL RECOGNITION ENTERPRISE LICENSES,” $2,287,500, 3 September 2021 to 3 September 2024); 70CMSD24P00000119 (“FORENSIC SOFTWARE,” $1,102,500, 4 September 2024 to 3 September 2025); 70CMSD25P00000111 ($7,687,500 obligated against a $9,225,000 ceiling, 5 September 2025 to 4 September 2027). Customs and Border Protection: three licence awards of $30,000, $15,000 and $15,750 (2025 and 2026). The FBI: 15F06722P0000068 ($18,000, 2022), 15F06723P0001356 ($359,000, 26 January 2023 to 25 January 2026, “CLEARVIEW ACTS AS A SEARCH ENGINE OF PUBLICLY AVAILABLE IMAGES ON THE INTERNET”) and 15F06726P0000453 ($150,000, 26 January 2026 to 27 July 2027). The Army: five awards of $15,000 to $75,000. The Air Force: two 2019 and 2021 awards of about $50,000 each, the second titled “PROTECTING AIRFIELDS WITH AUGMENTED REALITY FACIAL RECOGNITION GLASSES.” The Marshals Service: $95,000 and $78,750. The IRS: $63,000 (2026). Offices, Boards and Divisions of the Justice Department: $15,995 and $31,500 (USAspending award search, recipient “Clearview AI, Inc.”; ICE award 70CMSD25P00000111). The shape is the finding: a long tail of small annual licences across the investigating agencies, and four ICE awards that are 91 percent of the listed value, the newest of them 62 percent on its own obligation.

CONDUCT verdict: ADJUDICATED — FINED ON FOUR FRONTS, PAID IN ITS OWN STOCK, STILL OPERATING — a firm whose founding act was non-consensual collection at web scale, adjudicated against by four European regulators with fines and deletion orders, settled in Illinois with equity because it lacked the cash, and preserved throughout by the one defense that keeps winning: that no court asked to stop it has jurisdiction over enough of it to matter.

Alliance Map

These run at the same time, and the overlap is the finding. In 2025 and 2026 the firm was at once a licensee of eight federal agencies, the holder of a federal order that bars private customers and leaves agencies untouched, a defendant in a class settlement paid in its own stock, the respondent of a UK fine on appeal, the respondent of fines from the Italian and Dutch authorities, and the subject of a new ICE vehicle running to 2027. The same agencies that license the search are the ones the 2022 order carved out. Each tie is documented in a court record, a regulator’s text, an award record or the company’s own page; no coordination among them is asserted.

Reach Assessment

Institutional: By the company’s own count, 3,100+ agencies against a country of roughly nineteen thousand police departments — a minority of departments and a majority of the argument, because the asset any one agency searches is the same thirty billion faces. Memetic: The number itself is the reach. “Thirty billion” became the reference point for the end-of-anonymity argument across four books of this series and most of the litigation record cited above; a database that size reads as a fact of nature rather than one company’s decision, which is precisely the trick. Civilizational: This is the body layer, and the body layer does not rotate. A password can be changed and a card reissued; a face is broadcast with every step, and the scrape of it is permanent in a way no fine addressed — Europe fined, Britain litigated, Illinois was paid in stock, Vermont was told the defendant wasn’t there. A fine is a price. A wall is a stop. The record shows fines. The face was the last anonymous thing a person carried in public, and it is now an index term.

Score basis. Atk 9 is reach: Clearview’s own page claims “70+ Billion Images in our law enforcement database,” and USAspending lists 22 federal awards from eight awarding agencies, so investigators at ICE, CBP, the FBI, the Army and the Marshals Service act on its matches (clearview.ai; USAspending). It is not a 10 because every customer is a voluntary licensee, the 2022 consent order bars private buyers nationwide, and no statute or procurement standard obliges anyone to use the product. Def 8 is funding insulation, read narrowly: the Seventh Circuit records an “undercapitalized start-up” whose customers since 2022 “have included only federal and state government agencies and their contractors,” which spreads the money across the claimed thousands of agencies and 22 federal awards rather than one payer (Seventh Circuit opinion); it is not higher because those payers are the users the product serves and the firm could not fund a cash settlement, and ICE’s four awards are 91 percent of the listed federal value. Hp 5 is entrenchment: ICE award 70CMSD25P00000111 runs to 4 September 2027 on a $9,225,000 ceiling, and the firm has outlasted European and Australian regulators (USAspending); it is not higher because the class settlement was vacated on 13 July 2026, the other federal awards are one-year licences, and no program of record protects the product. Peers on the same values: METR at 9/8/7, hazard 84, shares atk, def and hazard and sits two points higher on hp, because its evaluations are written into the labs’ release process and Clearview’s licences lapse each year; CISA at 9/8/7, hazard 86, is two points higher on hp for the same reason and two higher on hazard on a statutory footing Clearview lacks; US CAISI at 9/8/6, hazard 80, shares atk and def and sits one point higher on hp, with a hazard four points lower, which rests on Clearview’s reach being a face index of the public where CAISI’s is a voluntary testing program. The values hold.

Companion file — the drama. The litigation posture, the press war, and the running public receipts are documented on troll.fan, the drama register of this same story: Clearview AI case file. This file keeps the mechanism; the drama lives there.

Sources: The Secretive Company That Might End Privacy as We Know It — New York Times, Jan 18 2020; Clearview CEO claims company’s database of scraped images is now 30 billion strong — Engadget, Mar 2023; Facial recognition: Italian SA fines Clearview AI EUR 20 million — EDPB, 2022; Clearview AI fined $33.6 million by Dutch watchdog — Reuters, Sep 3 2024; UK Upper Tribunal hands down judgment on Clearview AI Inc — ICO, Oct 2025; ICO wins appeal over Clearview AI jurisdiction ruling — Pinsent Masons Out-Law; First BIPA Litigation: Class Members Receive Equity in Clearview AI — National Law Review, 2025; $51.75M Settlement in Clearview AI Biometric Privacy Litigation — Regulatory Oversight, Apr 2025; Attorney General Clark Refiles Lawsuit Against Clearview AI — Vermont AG, Apr 25 2025; Judge throws out Vermont’s lawsuit against facial recognition software firm Clearview AI — VTDigger, Dec 18 2025; NIST Study Evaluates Effects of Race, Age, Sex on Face Recognition Software — NIST, Dec 2019; Illinois Biometric Information Privacy Act, 740 ILCS 14 — Illinois General Assembly; In re Clearview AI Consumer Privacy Litigation, No. 25-1673, opinion of 13 July 2026 — Seventh Circuit; ACLU v. Clearview AI, Inc., No. 2020 CH 04353, Consent Order of 11 May 2022 — Cook County Circuit Court; Ordinanza ingiunzione nei confronti di Clearview AI, 10 February 2022 — Garante; Dutch SA imposes a fine on Clearview — EDPB national news, 3 September 2024; Clearview AI breached Australians’ privacy — OAIC; UK Upper Tribunal hands down judgment on Clearview AI Inc — ICO; USAspending.gov, award 70CMSD25P00000111 (ICE); Clearview AI — clearview.ai; Clearview AI leadership — clearview.ai; Clearview AI — The Record, 21 February 2025; Amos Kyler — Potomac Officers Club.