This page is about a market more than a record. It describes the trade in introductions between companies willing to license their internal records and the firms that buy them.
The record
What is bought and sold is a working company's internal history: email, chat, shared drives, the customer database, the accounting ledger, support tickets, call recordings and code. The buyer takes a copy under licence, strips out names and personal details, and either passes the result to an AI lab or builds practice tasks from it.
Around that sale a second trade has formed. A referrer finds an owner who is prepared to license a copy, and introduces the owner to a buyer. The buyer pays the owner for the records and pays the referrer a fee. The referrer never holds any data.
A worked example, from terms the buyers publish. micro1's referral page offers "up to $50K" for each company referred, depending on its size 1. Its written terms say that where no amount is listed, the fee is 7.5% of what the buyer pays for the licence or purchase 2. Handshake's page says "Refer a company, get $10K", paid "when their deal closes" 3. In each case the referrer is paid only after the owner's deal has closed.
Why it might matter for training AI
Data vendors' pages show labs asking for the records of ordinary companies, and the buyers are advertising for them. micro1 announced in October 2026 that it would commit US$1 billion over twelve months to acquiring company data 4. That is the company's own statement.
Confirmed prices are much smaller or not yet final. SimpleClosure, which sells the records of closing startups, says more than 350 companies have listed and forecasts returning more than US$10 million to them by the end of 2026 5. In the bankruptcy of Spirit Airlines, three firms have bid for the airline's records: Google US$10 million and Mercor US$7.5 million at auction 6, and micro1 US$12.5 million in a later notice 7. The court has approved none of them.
Nobody was found who could be shown, publicly, to have been paid a referral fee. The promises are written down; proof of payment is not.
Who holds it and who may share it
The records belong to the company that operates. Hosts such as Microsoft, Google and Slack merely store them. Only the company can license them, through an officer with authority to sign. micro1's terms require the referrer to have the consent of "an authorized representative of the Company" before submitting it 2.
Owning the records is not the same as being free to sell them. A law firm's note from October 2026 says: "A company that holds data does not necessarily have the right to sell it. Email and chat contain other companies' confidential information, often covered by NDAs" 8. In the Spirit case a software supplier objected that, under its contract, data generated by its service belongs to the supplier and not the airline 6.
Responsibility stays with the seller. Tonic.ai, which strips personal data for such sales, puts it this way: "The legal liability does not transfer with the dataset" 9.
Who is already there
The market is crowded at every layer.
- Buyers with published referral terms: micro1, Handshake. The General Data Company says only that "terms are agreed case by case" 10.
- Buyers with a referral button and no published amount: a third-party survey found Mercor had "no published company-data referral terms as of 7 October 2026" 11.
The terms settle how firmly the fee is owed. micro1's say it may "withhold, delay, reduce, condition, set off against, or refuse to make any Referral Payout... for any reason or for no reason", and may "require you to repay any Referral Payout already made" if a deal is unwound 2.
What would have to be stripped
The law firm's note lists what an owner has to think about before selling: other companies' confidential material, legally privileged advice, and staff messages 8. It says California's privacy law treats a paid transfer of workplace data as selling personal information, unless the data fits that law's definition of de-identified, and that staff messages about pay and conditions may be protected under American labour law whether or not the staff are unionised 8. Those are the firm's readings; the statutes were not opened.
The Spirit case shows the argument in practice. The flight attendants' union objected that the sale would convey "substantially the entire employment and workplace record" 12.
What stands in the way
- At the largest buyer the referral fee is payable at the buyer's discretion and can be taken back.
- No paid referral has been publicly shown.
- The only confirmed prices are small, or are bids a court has not approved.
- Buyers advertise directly to the same owners. Credit depends on a tracked link.
- An owner's lawyers may refuse, most of all where staff belong to a union or work in California.
- The Spirit hearing was moved to 6 November 2026, according to one press report 13. No order has been made. The ruling, or action by a regulator, could change the market quickly.
- If a sale goes badly for an owner, the blame falls on whoever made the introduction.