At a press conference on August 11, 2022, the Federal Trade Commission (FTC or Commission) announced an Advance Notice of Proposed Rulemaking (ANPR), which was published, along with a fact sheet, to explore potential new rules governing what the FTC characterizes as prevalent “commercial surveillance” and “lax data security practices.” The FTC issued the
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WW International to Pay $1.5 Million Civil Penalty for Alleged COPPA Violations


In 2014, with childhood obesity on the rise in the United States, tech company Kurbo, Ltd. (Kurbo) marketed a free app for kids that, according to the company, was “designed to help kids and teens ages 8-17 reach a healthier weight.” When WW International (WW) (formerly Weight Watchers) acquired Kurbo in 2018, the app was…
Could COPPA Safe Harbor Changes Be in Store?


The Federal Trade Commission (FTC) took the unprecedented step of removing one of the approved Safe Harbor organizations under the Children’s Online Privacy Protection Act (COPPA) for failing to provide effective monitoring and assessment of its member companies’ websites, as required under the COPPA Rule. Earlier this year, Commission staff warned Aristotle International, Inc., whose…
CARU Issues Updated Guidelines for Children’s Advertising

The Children’s Advertising Review Unit (CARU), a division of BBB National Programs, recently updated its Self-Regulatory Guidelines for Children’s Advertising. Important updates include:
- To align with the Children’s Online Privacy Protection Act (COPPA), the Guidelines now apply to national advertising primarily directed to children under the age of 13 instead of under 12, regardless
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CPSC Review Leaves Certification Rules for Children’s Products Unchanged

After completing its review of testing and labeling regulations for children’s products, staff of the Consumer Product Safety Commission (CPSC) recommended leaving the current product testing and component part testing regulations as is. The CPSC carried out this review of the “Testing and Labeling Regulations Pertaining to Product Certification of Children’s Products, Including Reliance on…
FTC Staff Perspective Paper Offers Key Takeaways on Loot Box Workshop


More than 160 million Americans play video games. Originally designed as single-use purchases for consoles or computers, video games are now downloadable, making them more accessible to consumers than ever. One important development for the video game industry has been the creation of “micro purchases” – in-game transactions such as “loot boxes” that players can…
Washington State AG Settles with Online Platform Over Alleged COPPA Violations


Protecting the online privacy of children by enforcing the Children’s Online Privacy Protection Act (COPPA) continues to be of paramount importance to federal and state regulators. In addition to the Federal Trade Commission (FTC), several state attorneys general (AGs) have brought COPPA actions recently, including the New Mexico and California AGs, and, most notably, the…
FTC COPPA Settlement with App Developer Highlights Penalty Policy Considerations


A recent Federal Trade Commission (FTC) settlement with an online game company that allegedly tracked children illegally highlights some important questions, namely, how should the FTC assess the penalties it imposes for privacy violations, and what is the most effective way to both deter and punish companies for such violations?
The complaint in question was…
UK ICO Finalizes Rules for Children’s Content


The UK Information Commissioner’s Office (ICO) recently finalized its Age-appropriate design: a code of practice for online services (the code). The code applies to any “relevant information society services which are likely to be accessed by children” (by which the ICO means minors under age 18), whether designed for kids or general audiences. The new…