CARU Submits Comments on the FTC COPPA Rule Review

The Federal Trade Commission (“FTC” or “Commission”) recently requested public comment on its implementation of the Children's Online Privacy Protection Act (“COPPA”), through the Children's Online Privacy Protection Rule (“COPPA Rule” or “the Rule”).

The Commission generally reviews its Rules every ten years to ensure that they have kept up with changes in the marketplace, technology, and business models. Although the Commission's last COPPA Rule review ended in 2013, the Commission decided to conduct its ten-year review early because of questions that have arisen about the Rule's application to the educational technology sector, to voice-enabled connected devices, and to general audience platforms that host third-party child-directed content. In addition to requesting comment on these issues, the Commission requested comments on the costs and benefits of the Rule, as well as on whether certain sections should be retained, eliminated, or modified.

After thoughtful consideration, the Children's Advertising Review Unit filed its comments online. To learn more about CARU,  please visit our website. To view a copy of our comments in full click here.