Context: ACT | The App Association is a notorious astroturfing operation, which means that it claims to represent the interests of one category of stakeholders while actually being funded and controlled by another. A major news agency exposed that fact (September 19, 2022 Bloomberg article). Presently, ACT is trying to become a member of the European Telecommunications Standards Institute (ETSI), and has been caught lying about the status of its membership, which for now is just an application (June 20, 2025 ip fray article). The ETSI General Assembly (GA) will have to vote on the application in a month, and ETSI must be careful about whom to give voting rights as the organization ven believes it should (or at least might) have to let its membership vote on licensing disputes (October 23, 2025 ip fray article), even on the basis of single-judge decisions that later get overturned (October 31, 2025 ip fray article).
What’s new: With a view to the upcoming ETSI GA, we have taken another look at ACT’s antics, and not only ETSI but also policy makers in the EU, the U.S. and around the globe should be aware of what ACT really is about (and, especially, what it is not). Even by its own admission, ACT collects no membership dues from small and medium-sized enterprises (SMEs) but is funded by Big Tech.
- The non-paying, non-voting and presumably clueless “SME members” are not the 5,000 SMEs that ACT has been claiming for decades, but in the EU Transparency Register they list fewer than 500, out of which only 95 can be verified to have apps on the Apple App Store or Google Play Store. And there is no sign that even a single one of them has ever implemented, much less had to license, a standard-essential patent (SEP). The other members are either imaginary or, to the extent their names are listed, “consultancies, agencies, or B2B software firms that build apps for clients but don’t publish under their own name” (according to ChatGPT).
- ACT used to display the names of the ones who really call the shots (large corporations) on its homepage, but but has now buried references to only a subset of them in the middle of a web page describing its membership concept without listing any members there.
- ACT is not naming Google as a sponsor anymore, but did so earlier this year, and continues to file amicus briefs on Google’s behalf as recently as last month (October 1, 2025 amicus curiae brief by ACT filed with the Supreme Court of the United States).
Common sense: “He who pays the piper picks the tune”
It is a loophole in the EU’s transparency register that an organization can list “members” even they do not meet any reasonable definition of an association member:
- The so-called members don’t pay membership dues. ACT itself admits this much on its “membership” page: “The App Association works with sponsors like Amazon, Apple, Continental, Intel, Verisign, and Verizon to provide a no-cost membership for the small and medium-sized businesses that want to be involved in advocacy and have their voice heard when it is all too often ignored.”
- Nor do the so-called members enjoy any such thing as power. ACT is, as it told the U.S. government in connection with the COVID-era paycheck protection program (PPP), a company. It’s not an association of companies: it is a company. Its “president” and “chairman” are president and chairman in a corporate (not association) sense. They are not elected. They are owners and/or executives, and the ones who really control the organization are the ones who send the money: Big Tech.
Anyone who knows a thing or two about SEPs can figure that small app makers are not a stakeholder group that would ever consider in SEP-related lobbing (for lack of implementing patent-protected standards except in a “one a million” outlier case; in fact, no mobile app ever implements cellular standards like 5G because it uses the built-in implementations of the phones it runs on).
ACT’s astroturfing is even clearer in the app store context. ACT argues that any regulatory or judicial pressure on Apple and/or Google to open up their ecosystems and/or to lower their app store commissions poses an existential threat to small app makers as consumers would lose faith and stop downloading apps. That is preposterous. For decades, there have been thriving app ecosystems on platforms like Windows that allow “sideloading” (Apple and Google’s pejorative term for direct installations that circumvent app stores). Obviously, consumers may not (and should not) trust every dubious third-party app store, but there is no reason to assume that app store operators like Microsoft or Fortnite maker Epic Games couldn’t do a good job at that. There actually have been numerous fraudulent apps on Apple’s and Google’s app stores, and for lack of competition they sometimes took really long to kick them out.
In the SEP context, ACT claims to advocate the interests of those who have no issues (particularly not with respect to cellular SEPs). ACT claims that it also represents small IoT device makers, but where are they? Why can’t ACT put forward specific examples of ACT members that have been contacted by SEP holders? Because it’s just astroturfing.
Google was named as a sponsor, but not anymore, though it presumably still is
The amicus brief mentioned further above suggests Google is still an ACT sponsor. But why is Google not mentioned explicitly anymore? ACT says it has ” sponsors like Amazon, Apple, Continental, Intel, Verisign, and Verizon” and that apparently includes Google, but why wouldn’t they name them? The answer is that Google is in major antitrust trouble in the United States because Epic Games has so far won every single important decision against it and the Department of Justice is also pursuing litigation, with a major win on the merits. Google wants ACT to file more such amicus briefs, but doesn’t want to properly disclose its sponsorship of ACT.
The so-called members are not even 10% of the number ACT claims, and only one in five has ever published a mobile app
In the EU Transparency Register, ACT lists 488 companies while publicly claiming to have 5,000 such members and then appointing itself the voice of a trillion-dollar ecosystem.
We submitted the list of 488 to Perplexity and ChatGPT. Here are quotes from ChatGPT’s analysis:
That’s correct. Out of the nearly 500 names you shared, the list I gave you earlier are the ones I could confirm as direct publishers of consumer-facing apps on the Apple App Store or Google Play Store.
For the rest:
- Many are consultancies, agencies, or B2B software firms that build apps for clients but don’t publish under their own name.
- Some are enterprise-only vendors whose apps may exist but are distributed privately (e.g., through enterprise app stores or internal distribution), not on the public App Store/Play Store.
- A few may have niche or regional apps that are harder to verify without searching each one individually, but there’s no evidence of widely available consumer-facing apps under their own publisher account.
So yes — aside from the confirmed publishers I listed, the others don’t appear to have public-facing apps in the major app stores.
I counted them for you: there are 95 confirmed publishers from your original list that have consumer‑facing apps available on the Apple App Store and/or Google Play Store.
That means out of the nearly 500 names you shared, only about one in five are confirmed public app publishers — the rest are primarily agencies, consultancies, or B2B vendors without their own branded consumer apps.
Here’s the alphabetized reference list of all the companies from your original list that are confirmed to have published apps on the Apple App Store and/or Google Play Store.
📱 Confirmed App Publishers
- algoriddim GmbH
- AmWell
- Andaman7
- App Family
- Appolino
- appp media
- Avokiddo
- Bare Tree Media
- BinaryLabs Inc.
- Blue Label Labs
- Brain+
- Busy Bee Studios
- CarePredict Inc.
- Caribu Limited
- Chamo Games
- Colto
- Cowly Owl
- Daktylos Media
- demografix pty ltd
- Drawp for School
- Edoki Academy
- Eggroll Games
- Ellie’s Games, LLC
- Espace Pty Ltd (espacepublishing.com)
- Fairlady Media
- Famigo, Inc.
- Fitness22
- Flipaclip
- Funky Bots LLC
- Globe Smart Kids
- Goally Inc
- Happy Frog Apps
- Health & Parenting LTD
- Higher Learning Technologies
- Hinge Health
- iHealth Labs
- imagi
- iMagine Machine LTD
- Infiniteach
- Infinut
- Jan Essig
- Jekolab Srl
- Jellybean Tunes
- Kaia Health Software
- Kidkedoo Ltd.
- Kiko Labs Inc
- Kiloo Games
- Kiupe
- L’Escapadou
- LoeschWare, LLC
- Lumio Education
- makkajai Edu Tech Pvt. Ltd.
- Mash&Co
- MaxScholar
- McPeppergames
- My Town Games
- Nature Maestro
- Nravo Kids
- Oh Bibi
- Oki Play
- Paper Boat Apps
- Pili Pop
- Pixel Envision Ltd.
- PKCLsoft
- Pretendasaurus
- Pyxwise Software Inc.
- RosiMosi Academy
- Skidos Learning
- Sphero, Inc.
- Springbay Studio Ltd.
- Sprite Kids
- StoryToys
- Teachley
- Thup Games, LLC
- Tiltan Games
- Tinybop
- Ululab
- Wahoo Fitness
- Wee Taps
- Wellframe Digital
- Whisper Arts
- Wonky Star Ltd
- Yaya Play LLC
- YipYip
- Zyrobotics, LLC
There is no indication that those companies even understand what ACT is doing: it’s working against app makers on Apple’s and Google’s behalf. The organizations that advocate policies Apple and Google oppose, but which app makers would find beneficial, are the Coalition for App Fairness and the Coalition for a Competitive Mobile Experience.
ACT has never once said Apple and Google should lower their app store commissions. Even if one considered those commissions fair, there is no way that an organization representing app makers’ interests would never argue that its members should pay less. But that’s because the ones who pay the piper pick the tune.