Despite his conviction on this point, Grimmelmann acknowledged in the final pages of his analysis that even the most rigorous imposition of the Common Rule would do little to curb the immense power of a company such as Facebook that routinely manipulates user behavior at scale, using means that are indecipherable and therefore uncontestable. Like Fiske, Grimmelmann sensed the larger project of economies of action just beyond the reach of established law and social norms.

Shoshana Zuboff, The Age of Surveillance Cap…, loc. 953