PolicyBrief
S. 3516
119th CongressDec 17th 2025
Stopping Grinch Bots Act of 2025
IN COMMITTEE

This bill prohibits circumventing online purchasing limits enforced by technological controls and grants enforcement authority to the FTC and state attorneys general.

Richard Blumenthal
D

Richard Blumenthal

Senator

CT

LEGISLATION

New 'Grinch Bots' Bill Makes Bypassing Online Purchase Limits Illegal, Hands FTC Enforcement Power

This bill, officially called the Stopping Grinch Bots Act of 2025, is aimed squarely at the automated software that snatches up limited-edition goods, concert tickets, and even everyday high-demand items faster than any human finger can click. Essentially, the bill makes it illegal for anyone to bypass a website’s security or technological controls—like CAPTCHAs or inventory management systems—if those controls are used to enforce posted purchasing limits.

Think about trying to buy a new gaming console or concert tickets only to see them sell out instantly to bots. This bill is the government trying to level that playing field. Crucially, it also makes it illegal to sell or offer to sell products acquired through this kind of technological bypass if the seller knew, or should have known, the item was acquired unfairly. This is a big deal because it targets not just the bot operators but the secondary market—the scalpers—who profit from the practice.

The Digital Bouncer: What Changes for Shoppers and Sellers

For you, the consumer trying to snag that limited-edition sneaker drop or a ticket to a popular show, the hope is that this law will increase your chances against the bots. If retailers can enforce their “one per customer” limits without sophisticated software instantly overriding them, more regular people get a shot. For retailers, the bill provides a clear federal tool to combat bot attacks, reinforcing their own terms of service.

The law is enforced by the Federal Trade Commission (FTC), treating any violation as an unfair or deceptive act or practice under existing consumer protection rules. This means the FTC can hit violators with significant penalties. Furthermore, State Attorneys General are also given the power to file civil lawsuits in federal court on behalf of their residents to stop these practices and seek damages. This dual enforcement mechanism—federal and state—means bot operators and scalpers will have more legal avenues coming after them.

The Fine Print: Where Things Get Complicated

While the goal is clear—stop the bots—the language opens up a few practical questions. The law prohibits circumventing “any security measure, access control system, or other technological control” used to enforce limits. That term, “technological control,” is broad. If a website’s standard inventory management system is considered a “technological control,” could this law be used against legitimate business practices that involve interacting with a site’s back end, even if they aren't trying to scalp? The vagueness could create confusion for businesses trying to comply.

Another point of concern is the liability extended to sellers who should have known the product was acquired through a bypass. For a small business owner who buys inventory from various sources, proving they didn't know the origin of every single item could be challenging. This provision requires secondary sellers to perform significant due diligence, adding a layer of risk and compliance cost to the resale market.

The Security Researcher Loophole (and Its Limits)

There is an important exception for security research. The bill allows the creation and use of software for two reasons: to investigate or aid in enforcing the law, or to conduct research to identify security flaws or vulnerabilities to advance computer security knowledge. This is good news for “white hat” hackers and security firms who test systems to make them safer. However, the exception is specific. If a security researcher’s activities don't strictly fall under these defined categories—say, they are testing a system for inventory efficiency rather than a security flaw—they might inadvertently run afoul of the new prohibition, which could be a chilling effect on broader, beneficial technological testing.