Yeah, but the difference I believe is the FCC publishes the entire question pools to prevent third parties from selling a "dump". Ideally the pools are far lar

Yeah, but the difference I believe is the FCC publishes the entire question pools to prevent third parties from selling a "dump". Ideally the pools are far larger than the questions you'd receive on the actual exam so trying to memorize the right answers is actually harder than engaging with the material. These test providers could do the same thing. They should expand their test pools to be extremely large by tweaking the values in each question so that one Q becomes 10. Prior to the federal government publishing question pools (I believe FAA does too), testing groups would send in folks to sit for the exam, memorize the questions then run outside and record what they saw. Do that enough times and the question pools emerged in their records and then they grew a big business selling that "dump". I can't imagine managing large question pools manually, but with digital tools it's become trivial in edtech circles. Why these test providers don't end it is beyond me. (Probably because the federal "cert" game status quo is plenty lucrative.)