Texas Attorney General sues multiple TV makers over ACR user data collection

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On December 15, 2025, Texas Attorney General Ken Paxton filed five separate lawsuits against Samsung, Sony, LG, Hisense, and TCL Technology, alleging that these manufacturers failed to adequately disclose the data collection capabilities of Automatic Content Recognition (ACR) technology in their smart televisions. The lawsuits, filed under the Texas Deceptive Trade Practices Act, allege that ACR technology captures screenshots of television displays at frequent intervals and that the resulting viewing data is sold to advertisers and data brokers without meaningful consumer consent.

Background

Automatic Content Recognition technology

Automatic content recognition (ACR) is a technology integrated into smart televisions that identifies content displayed on the screen. ACR operates through two primary methods: audio fingerprinting, which captures and analyzes audio samples to match against reference databases, and video fingerprinting, which periodically captures screenshots or frames of displayed content for identification purposes.

According to research conducted by a number of UK-based universities in 2024, ACR systems in LG televisions transmit digital fingerprints approximately every 15 seconds, while Samsung devices transmit approximately every 60 seconds under normal operation. The technology can identify content regardless of source, including some streaming services, cable television, over-the-air broadcasts, and content from HDMI-connected devices such as gaming consoles and laptops.

Precedent: FTC v. Vizio (2017)

Main article: Vizio fined by the FTC for collecting and selling user data without consumer consent

The foundational regulatory action concerning ACR technology was the Federal Trade Commission's 2017 settlement with Vizio. The FTC and New Jersey Attorney General reached a $2.2 million settlement with the company, alleging that Vizio had enabled ACR on approximately 11 million smart televisions without adequate notice to consumers. According to the FTC, Vizio collected up to 100 billion data points per day and had remotely installed ACR software on previously sold televisions that did not originally include the feature.

The settlement established that television viewing history constitutes sensitive information requiring affirmative express consent.

Allegations

Data collection practices

The Texas lawsuits allege that the defendant manufacturers' ACR systems capture screenshots of television displays at intervals as frequent as every 500 milliseconds, amounting to 7,200 images per hour. The complaints assert that ACR remains active regardless of content source, including when the television functions solely as a display for external devices, and that data is stored offline and transmitted when internet connectivity is restored.

The lawsuits further allege that viewing data is compiled into consumer profiles that include viewing habits, timing patterns, and content preferences, and that these profiles are sold to advertisers, data brokers, and measurement companies. The complaints contend that ACR data can be used to infer personal attributes including race, religion, and political beliefs from viewing patterns.

Consent and disclosure practices

A central allegation in the lawsuits concerns the methods by which manufacturers obtain consumer consent. The complaints allege that privacy disclosures are difficult to locate and understand, and that the interface design of television setup processes makes opting out of ACR significantly more difficult than opting in.

Specifically, the Samsung complaint alleges that while enrollment in data collection can be accomplished with a single click during setup, opting out requires approximately 15 or more clicks across multiple separate menus. The complaints also note that manufacturers use varied terminology for ACR features, with Samsung referring to "Viewing Information Services," LG using "Live Plus," and Hisense labeling the feature "Enhanced Viewing Services."

National security concerns

The complaints against Hisense and TCL include additional allegations concerning national security. Both companies are headquartered in China, and the lawsuits reference China's National Security Law, which the complaints state requires Chinese companies to provide data to the Chinese government upon request.

Legal basis

The lawsuits allege violations of the Texas Deceptive Trade Practices Act (DTPA), Texas Business & Commerce Code § 17.46, specifically section 17.46(a), which prohibits false, misleading, or deceptive acts or practices in trade or commerce, and section 17.46(b)(24), which addresses failure to disclose information concerning goods or services.

The complaints also serve as notice of noncompliance under the Texas Data Privacy and Security Act (TDPSA), which provides manufacturers with a 30-day cure period. The Attorney General's office has indicated its intention to amend the complaints to add TDPSA claims if violations are not addressed within this period.

The lawsuits seek civil penalties of up to $10,000 per DTPA violation, with enhanced penalties of up to $250,000 per violation in cases involving consumers aged 65 or older. The complaints also seek permanent injunctive relief, consumer restitution, and recovery of legal costs.

Affected consumers

According to the lawsuits, the alleged practices affect a substantial number of Texas residents. The Samsung complaint estimates that approximately 2.49 million Texas households, representing approximately 6.7 million residents, own Samsung smart televisions. The Hisense complaint estimates approximately 470,000 affected Texas households, representing approximately 1.27 million residents.

The same ACR data collection is performed on users outside Texas (though not relevant to this lawsuit).

Manufacturer responses

The named manufacturers provided limited public comment on the lawsuits.

Sony Electronics stated that it does not comment on pending legal matters. LG Electronics USA stated that "As a matter of policy, LG Electronics USA does not generally comment on pending legal matters". Hisense USA stated that it stands by the quality of its products and is unable to comment further on matters of a litigious nature. TCL stated that it does not comment on active litigation.

Samsung did not issue an official public statement but indicated to media outlets that ACR functionality is optional and can be disabled through device settings.

Lawsuit timeline

Date	Event
December 15, 2025	Lawsuits filed against Samsung, Sony, LG, Hisense, and TCL
December 17, 2025	Temporary restraining order granted against Hisense in Comal County
December 19, 2025	Texas Attorney General issues consumer alert regarding smart TV data collection
December 23, 2025	Texas abandons initial LG claims in Tarrant County following denial of TRO application
January 5, 2026	Temporary restraining order granted against Samsung in Collin County
January 6, 2026	Samsung TRO vacated by same court; LG case refiled in Bell County
January 9, 2026	Samsung TRO application formally denied at hearing

Current status

As of January 21, 2026, all five lawsuits remain active. The temporary restraining order against Hisense, granted on December 17, 2025, remains in effect, prohibiting the company from collecting ACR data from Texas consumers and from using, selling, sharing, or transferring previously collected data. The temporary restraining order granted against Samsung were denied following the vacation of the initial order. No temporary restraining order applications have been publicly reported for the Sony and TCL cases. The refiled case against LG in Bell County is proceeding.