The methodology here is worth calling out separately from the findings.

Every piece of evidence comes from passive recon: CT logs, Shodan, DNS, unauthenticated files served by Persona’s own web server. No credentials, no exploitation, no access. The legal notice isn’t throat-clearing — it’s a precise citation of Van Buren v. US (2021) and hiQ v. LinkedIn to preempt CFAA overreach before it happens. That’s the same legal framework researchers have been fighting to establish for years.

The substantive finding that doesn’t get enough attention: openai-watchlistdb.withpersona.com has 27 months of certificate transparency history. That means this integration predates most public awareness of Persona’s role in OpenAI’s verification stack by a significant margin.

The field name in the source — SelfieSuspiciousEntityDetection — is the tell. That’s not age verification language. That’s watchlist screening language. Age verification and watchlist screening are different products with different regulatory frameworks, different legal authorities, and different implications for the people being checked. Running them on the same pipeline, under the same ‘identity verification’ umbrella, collapses a distinction that actually matters.

The CEO correspondence angle in the addendum is interesting. Publishing the full exchange is the right call — it either produces answers or produces a documented non-answer, and both are useful.