Ms. Patricia Ross, head of the mobile technology unit at the Federal Trade Commission (“FTC”), was quoted last week in The New York Times as urging mobile technology firms, who build applications for smartphones, to build security into their products from the beginning of development, not after a “privacy debacle” has occured. The direct message to the mobile application industry is in response to the continuing explosion of privacy violations by companies like Google, Facebook, and Apple. As the violations continue to grow, the FTC Commissioners are warning the technology industry in general that they can expect Congress to enact laws to protect consumers – which everyone agrees would stifle innovation. While the FTC has entered into consent decrees with Google and Facebook, privacy violations in the mobile application space is still of great concern, as there is little to no accountability.