Regulate me, please...

Have you ever wondered if the playbook of Big Tech bears a striking resemblance to that of Big Tobacco? This back-of-an-envelope exploration reveals that tech giants have not only adopted the dark arts of corporate manipulation, but have also amplified them. They dispute science, distort narratives, and evade accountability with a precision that would make even the most seasoned lobbyist blush. The article clearly illustrates a systemic, cross-industry strategy of delay, deflection and control, involving cherry-picked research, astroturfing, revolving doors and tax havens. However, there's a twist: Big Tech's arsenal is turbocharged by their unprecedented access to our data, attention, and even our deepest fears. This gives them not just economic influence, but existential influence, too. The call to action? It's time to stop addressing individual scandals one by one and start dismantling the system as a whole. And no – policy and regulation alone are not enough.

I recently came across the book Food Fights by Stuart Gillespie. First published in Great Britain, the USA and Canada in 2025, I particularly spent some time on chapter 13, 'The Dark Arts'. Just a little clarification: this text is about tech, Big Tech in particular, it is not a book review – but we have to start somewhere before we get there. At Tactical Tech, we had a chance to work with various organisations that were active in fields way outside of our own expertise, such as Big Oil, Big Food, Big Pharma and Big Tobacco. We either developed projects with them that utilised digital technology in some way, or we worked with them in our creative capacity, helping to design their reports or visual campaigns.

So we were aware of the complex tactics that different corporate actors and their networks were utilising. We also look at it from another perspective: the role of tech in shaping people's opinions and narratives around complex issues or during specific events such as elections (check our Influence Industry Project), pandemics (check our Technologies of Hope & Fear), or the climate crisis and information crisis entanglement, which we tackle in The RePlaybook we recently published.

I will be referring extensively to the 'D' framework, which has been analysed in various contexts, such as the Russian pro-Kremlin propaganda machine (the '4Ds': Dismiss, Distract, Distort and Dismay), also known as 'weapons of mass destruction'. For a different take on these Ds, check out the 'Big Carbon' context: Deny, Deceive, Delay: Demystified – How Big Carbon uses disinformation to sabotage climate action and how we can stop them.

I am now going to summarise the main points of Chapter 13 of Gillespie's book in detail (because I love long texts, and you should too). The chapter outlines the five categories of method used by Big Tobacco and Big Food to control the information environment, from the media to policymaking. If you are not interested in my convoluted thought process and inspiration, go directly to the next section: 'Is Big Tech doing the same?' If not, go further down to 'Dissecting Big Tech Strategies And Tactics'.

The first strategy is to Dispute and Doubt. Apparently, a meeting was held in 1953 at the Plaza Hotel in New York, where it was decided that a strategy was needed to counter the scientific evidence that smoking is harmful. The strategy was to fund sceptical scientists, amplify their views and control research narratives in order to delay regulation. The following tactics were decided upon: claim that 'more research is needed' to stall action, even in the face of overwhelming evidence; 'blame individuals' ('overeating, under-exercising consumers') and frame health as a 'lifestyle choice'; suppress or cherry-pick research to cast doubt on the harms of ultra-processed food (UPF); and use front groups (e.g. the Tobacco Institute and the Washington Legal Foundation) to lobby and challenge regulations.

As you can imagine, when I thought about replacing Big Food/Tobacco with Big Tech, the idea felt familiar and far too close to home. But let's go through the remaining four strategies and their associated tactics as presented in the book.

The second strategy, Distort and Deceive, has four tactics. One is to reframe the problem. In the case of ultra-processed food, this involves portraying obesity as a 'problem of individual responsibility' or 'inactivity' rather than diet – examples include the 'Exercise is Medicine' campaign by Coca-Cola. Straw man argument: accuse critics of opposing all food processing or the private sector. Manipulate language by using vague terms such as 'balanced diet' or 'healthy lifestyle' to market unhealthy products, and co-opt terms such as 'natural', 'nutritious' and 'goodness' without regulation. Lobbying: spend billions of dollars to influence policy (e.g. $1.15 billion by UPF manufacturers from 1998 to 2020), pressure governments to weaken or delay regulations (e.g. the UK's HFSS advertising bans), and target the WHO: the Sugar Association pressured the US to withdraw WHO funding over sugar guidelines.

While reading these, I started writing a version of the same outline, but filling it with examples of the known behaviour or cases related to big tech companies. But let's go through the third one first.

Third Strategy: Distract & Deflect. Here we have three tactics at stake. Corporate Social Responsibility (CSR): fund small-scale "good" projects (e.g. PepsiCo donating to anti-hunger initiatives) to distract from harmful core business, and use 'youthwashing' to build brand loyalty early (e.g. Krispy Kreme handing out doughnuts in hospitals during COVID). Self-regulation: promise voluntary reformulation (e.g. reducing sugar/salt) to avoid government mandates, but changes are minimal or ineffective, and legal threats delay regulations (e.g. Kellogg's sued the UK over sugary cereal promotion bans). Crisis exploitation: leverage crises (e.g. COVID-19) for PR stunts while continuing harmful practices.

And now let's go quickly through the last two.

Number four – Disguise – and its three tactics. Use front groups: hide behind "non-profit" or 'sustainable' organisations (e.g. ILSI, Council for Tobacco Research) to lobby and publish industry-friendly science; use trade associations (e.g. Infant Feeding Association) to oppose WHO breastfeeding protections. Astroturfing: create fake grassroots movements (e.g. stolen photos, fake bios) to simulate public support. Revolving door: industry executives move between corporations and government (e.g. Coca-Cola's influence in Mexico via ex-President Vicente Fox), and lobbyists are often former government employees (two thirds of US lobbyists – for examples refer to the book).

And the last one – five – Dodge. Tax avoidance/evasion: shift profits to tax havens (e.g. McDonald's used Luxembourg, then London, to avoid £295M in UK taxes); exploit legal loopholes (e.g. franchise models to minimise taxable income); fight product taxes (e.g. Coca-Cola/PepsiCo blocked soda taxes by funding opposition groups). Exploit global inequality: profits flow to high-income countries, while harms (malnutrition, pollution) are borne by low-income nations.

As I said above, I am taking all the above tactics directly from the book. If you want more details, get the book. The point I am trying to make here is that many groups have a very systematic and strategic approach to corporate defence strategies. However, I am somehow not aware – it might just be me – of anyone or any organisation that would have a broad, holistic approach to studying and exposing all the strategies and tactics deployed by Big Tech, whether these are verbatim copies of those listed above or their updated variations. Who is carrying out a more thorough analysis of possible new tactics as well as existing ones?

So, I went through the simple process of using this outline to check how difficult it would be to write one for Big Tech. I did this on the back of an envelope, so to say. It wasn't hard. But it should be done properly.

So, is there any proof that Big Tech has ever publicly considered or admitted to using tactics from the corporate playbooks of the Big X'es (X = tobacco, food, pharma, oil)? There is one: in testimony given to the House Committee on Energy and Commerce in 2020, Tim Kendall, who was then Director of Monetisation at Facebook (Meta), explicitly admitted that 'we took a page from Big Tobacco's playbook'. An exception? Or an admission of something that is perhaps more systemic.

Let's go through them one by one – and as usual – if you might be sitting on more or better examples, please send them our way!

Fund research, amplify sceptical voices, and control narratives to delay regulation – there are plenty of examples here (see: Is big tech harming society? To find out, we need research – but it's being manipulated by big tech itself). Claim "more research is needed" to stall action, even with clear evidence (e.g. the harmful impacts of social media on young people). Blame users for "poor digital habits" or "lack of self-control" instead of addressing algorithmic design (see: Who's Responsible for Your Bad Tech Habits? It's Complicated). Suppress or cherry-pick studies to downplay harms (e.g. internal Facebook research on teen mental health) – and so on and so forth. This is not a research paper – just a little proof of concept.

Reframing: portray issues as individual failures (e.g. 'Users should log off' rather than addressing addictive design), while those designing technology to increase attention ban their own children from using it. (See: Bill Gates and Steve Jobs raised their kids with limited tech — and it should have been a red flag about our own smartphone use.) Straw man arguments: accuse critics of opposing all technology or innovation. We often get accused of this – of being doomers, alarmists, or straight-up Luddites, or simply people who take Black Mirror too seriously. Language manipulation: use vague terms like "responsible AI" or "ethical tech" without clear definitions (do I even need to bring any evidence here?); co-opt terms like "open", "accountability", "transparent", "user-friendly", "well-being" or "for good" for PR without meaningful change.

Lobbying: spend billions to influence policy (e.g. Big Tech's lobbying against antitrust laws, GDPR, or content moderation rules). Lobbying has been monitored to some extent at least in the US – see As Big Tech Gears Up for the 2026 Midterms, Its Lobbying Operations Continue Unabated. Put pressure on governments to weaken or delay regulations (e.g. the EU's Digital Services Act and US antitrust bills). Target regulators: tech giants fund campaigns to influence public opinion (e.g. opposing 'gatekeeper' designations). (Check: EU vs Big Tech: Brussels' bid to weaken the digital gatekeepers – if you have an FT subscription.)

Finally, take a look at Big Tech's Invisible Hand, an investigation by Pública - Agência de jornalismo investigativo, a Brazilian investigative journalism agency, a cross-border project run by 17 media outlets spanning 13 countries and focusing on 3,000 lobbying actions influencing the actions of congresses or governments in these countries. You can also read Reporters Without Borders' response to the investigation: in short, big tech lobbying is a global phenomenon in which all the companies behind the digital tools we depend on participate in anti-regulation efforts in a strategic and systematic way, with a scale and variety of tactics that has never been seen before.

If that's not enough, I would also like to point to the just-launched project by Molly White – who we have been following since the beginning of 2024 in regards to her outstanding research into the politics of crypto and the cryptocurrency industry's influence on politics in the US. Her new project Tech Influence Watch has just launched, and here is the project itself, which initially started by tracking the political spending of the cryptocurrency industry. Now, artificial intelligence companies are following the same approach, with the same strategists and the same backers.

Corporate Social Responsibility (CSR): fund small-scale initiatives, such as digital literacy programmes and AI ethics boards, to distract from core harms, such as data exploitation and automated harms. Use 'tech for good' campaigns to improve reputations while continuing harmful practices – here I can think of Microsoft promoting their work with health organisations and Google's focus on water-positive initiatives, but I would like to find out more on this subject. Self-regulation: promise voluntary reforms (e.g. content moderation and privacy controls) to avoid government mandates, but changes made are minimal. Legal threats delay regulations (e.g. lawsuits against GDPR fines or content moderation laws – check Delay, depress, destroy: How tech corporations subvert the EU's new digital laws).

Crisis exploitation: leverage crises to position tech as essential while expanding surveillance or data collection or harms. While we were working on the Technologies of Hope and Fear during the pandemic, we saw some companies come forward with data and resources that they had previously claimed not to have, such as location data, which they then offered to help the authorities monitor lockdowns. However, something else is happening here: none of the previous big tech companies had such a direct link to the military-industrial complex. They are the primary contractors when it comes to data processing and the use of AI for the automation of warfare. If you want to look into the scale of this connection, explore the AI War Cloud by Sarah Ciston. What happens to a government that depends on military contractors who are also the backbone of civilian communication and the information sphere? How does this shape their relationship and dependencies?

Front groups: hide behind "non-profit" or "industry coalition" organisations (e.g. tech-funded AI ethics institutes, trade associations) to lobby and publish industry-friendly research – this would require a bit more digging (which is what SOMO is doing in Recoding the system: how we can counter the Big Tech Lobby Playbook). Use trade associations (examples from the past: e.g. Internet Association, Chamber of Progress – the first has since been dissolved and the second is no longer visibly effective) to oppose regulations.

Astroturfing: create fake grassroots movements (e.g. bot-driven campaigns, fake user testimonials) to simulate public support. We have been around long enough to remember Microsoft funding the organisation Americans for Technology Leadership (ATL), which orchestrated a letter-writing campaign during the company's 2001 antitrust trial in an attempt to generate public support for a favourable ruling (see: Lobbyists Tied to Microsoft Wrote Citizens' Letters).

Revolving door: tech giants and government executives often move between the two sectors. For example, Niamh Sweeney is a former Meta lobbyist who now works in a regulatory role as one of the commissioners of Irish Data Protection – which in practice executed GDPR in the EU (see: Big Tech lawyer played key role in picking Ireland's new privacy regulator). Lobbyists are often former government officials (e.g. those in US FCC and EU digital policy roles). A long time ago, in 2017, we conducted an investigative project on Google called Investigating Google's revolving door at the Digital Methods Summer School at the University of Amsterdam (for full credits go there).

Tax avoidance/evasion: shift profits to tax havens (e.g. Apple's Ireland structure, Google's Double Irish arrangement). Exploit legal loopholes (e.g. patent box regimes and R&D tax credits) to minimise taxable income. Fight product taxes or fees (e.g. opposing digital services taxes in France and the UK, by the US administration and the Computer & Communication Industry Association (CCIA)).

Global inequality: profits flow to high-income countries, while harms (e.g. data exploitation, e-waste, the use of underpaid unregulated workforces as moderators and data cleaners) are borne by low-income nations. One would say – this is what all global businesses do in one way or another – but just look at the scale here. Big Tech leads alongside Big Pharma, and the data I am referring to here goes back to 2017 (see: Corporate tax chartbook: How corporations rig the rules to dodge the taxes they owe). For more current data, check: Four Big Tech Companies Avoid $51 Billion in Taxes in Wake of One Big Beautiful Bill Act.

I am sure that much more research and investigation could have been invested in the above quick review, and if I had spent more time on it, I would have found lots of other examples. While conducting the review, I also came across the following rather new research: Big AI's Regulatory Capture: Mapping Industry Interference and Government Complicity (ACM, ISBN 979-8-4007-2596-8/2026/06), by Abeba Birhane, Riccardo Angius, William Agnew, Harshvardhan J. Pandit, Bhaskar Mitra, Roel Dobbe and Zeerak Talat. They took a much more thorough look at the same problem, focusing specifically on Big Tech narratives around the regulation of AI, and took a much more precise approach. They examined the growing influence of AI and how this has led to corporate control over its regulation. Their study identifies 27 ways in which companies influence AI regulations, often using narratives such as 'regulation stifles innovation' to justify their actions. The most common tactics involve framing debates and bending laws. The authors warn that this regulatory capture constitutes an emergency and suggest ways to resist it. However, what shocked me most was how much their findings overlapped with those presented above. Below, I have reproduced their table, which uses different categories to those I discussed earlier, based on the 'Food Fights' book. For the full set of findings, please read their article. Here is the table in full.

I am going to make a partial conclusion here: the Big Tech playbook for capturing spheres of power and control is not only based on well-tested playbooks exercised over decades by Big Oil, Pharma, Tobacco and so on – they reuse and improve on tested strategies and tactics, share PR firms, lawyers, lobbyists, etc. Even if they did or might not, we can safely say that the capture of the public narrative is systemic, endemic and deep.

My personal interest lies in epistemic and discourse influence (the bottom part of the above table). What is new about Big Tech, and in particular Big Tech sitting on AI, is that none of the previous Big Xs had such unprecedented access to personal and behavioural data in terms of the ability to collect, store and process it, and turn it into personalised influence.

Worse still, none of the Big Xs ever created anything like the so-called AI – the Intimacy Machine, formerly the Attention Machine – which is totally out of proportion in terms of capturing society's deepest and most personal desires and fears, aspirations and vulnerabilities. The Eliza Effect is real – AI machines capture the most intimate attention there is. I have written about it previously: "Don't show me your AI. It is rude!". We also covered it in one of our posts as part of the "Hello AI!" Educational Intervention (also pictured in the aforementioned text). However, we now have more research covering this topic: Companion AI: Risks of Sycophantic and Addictive Designs in AI Systems, Legal Implications, and Policy Recommendations by Ramak Molavi-Vasse'i, published this month by the Center for Digital Rights and Democracy. Also check the Companion-AI Incident Database.

If you bring all these things together – the sophisticated and well-tested corporate playbook of wielding influence, the unprecedented amount of money at stake, and the extremely intricate, precise and deep capture of human inner thoughts – we have a problem.

Standard strategies involving different organisations and civil society groups building coalitions and addressing policy regulations, which are mostly focused on tools produced by Big Tech (i.e. actual applications or platforms), or individual businesses, are not enough. The pace is too fast and the control of these ecosystems is too sophisticated. Nobody has really succeeded in exposing and timing the revolving door, and even less has been done to address the circumvention of the law and tax avoidance. Plus, in these existing efforts there is very little focus on epistemic and discourse influence.

I am aware that there have been successes and that there are laws and regulations, particularly in the EU, in place. The example I always hear is the implementation of GDPR. Recently, I watched a talk by Johnny Ryan from Enforce at Re:publica called "How we avoid dystopia", in which he showed a slide demonstrating the efficacy of the GDPR and the fines imposed on Big Tech. He also showed how big the fines were in relation to their wealth and who paid what. Here is the table he was showing – it speaks for itself (at 11:53 in the video).

The point is that the regulations are intended to effect systemic change. In the case of the GDPR, for example, the aim is to enforce changes to business models that are based on the collection of personal data. This has not happened yet. I have not noticed many changes in the way these companies develop and implement their platforms and tools. Furthermore, the fines that were intended to create pressure to address this issue have not been effectively implemented since 2018.

There is plenty to do. In order to stand up to the systemic and coordinated capture by Big Tech, an equally well-oiled machine is required. Firstly, broader coalitions are needed between those working with all types of big corporations. Much more collaboration and coordination is required between those working with any of the Big Xs. Let's start by sharing some dos and don'ts. Within tech-focused groups, there is also a much greater need for wider coalitions across sectors and influences. Since we started Tactical Tech in 2003, a lot has changed – we now have hundreds, if not thousands, more groups and organisations working on issues related to the various impacts of Big Tech, as well as working on solutions to the problems they bring on.

I would like to make two bold observations here: first, we have far too many organisations with far too narrow a focus; second, the atomisation of the sector is great on the one hand, but on the other, we have far more organisations that are projects or tools, making civil tech very diverse and interesting – but also much easier to dominate. Big corporations thrive in atomised counter-influence spaces. At the same time, we see that many funders who historically were not interested in digital technology are now coming forward and joining funding coalitions. However, we have yet to see bolder and more coordinated approaches. Many funders have their own focus and interests, which is great on the one hand, but this plays into the strategies of Big Tech. The less coordinated and sustained the organising, the freer they are to do as they please.

The most pressing challenge of our time is the need to address the systemic issues surrounding Big Tech. This is not just about a collection of corporations, but also about the cultural, economic and political force that Big Tech has become, and the ways in which it has reshaped society. The issues they generate are not isolated or incidental, but rather the inevitable by-products of a business model based on extraction, surveillance and the commercialisation of attention and data.

At its core, this model is not only profit-driven, but also ideologically charged. It promotes a worldview in which efficiency, scale and disruption take precedence over equity, democracy and human and societal well-being. The algorithms that govern our digital lives are not neutral; they embed values – often those of unchecked capitalism and technocratic elitism – that reinforce inequality, polarise discourse and erode trust in institutions – and these values are, quite frankly, good for business. These are not mere market failures, but structural flaws that markets are not equipped to correct when left to their own devices.

The ambitions of Big Tech have long transcended the economic realm. Through lobbying, political influence and direct involvement in shaping public policy, these entities have positioned themselves at the heart of governance, blurring the line between corporate and state power. They now have a significant presence in education, healthcare, and national security, raising urgent questions about accountability, transparency, and the concentration of power in the hands of a few unelected individuals.

To address these challenges, we must recognise that Big Tech has become a political project. This requires more than just regulatory adjustments or antitrust measures, though these are necessary. We must engage in a fundamental reimagining of how technology can serve society. This requires democratic oversight, informed public debate, and policies that prioritise the common good over shareholder returns. Otherwise, we risk handing the future over to a handful of platforms that answer to no one but themselves, whose incentives are fundamentally misaligned with the needs of a just and functional society – a future that I fear we have already handed over to them.

All images taken by Marek. A mini series from the control room of one of Berlin's dysfunctional power stations; 2026. The credits for the other images are underneath them.