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The Internet Association Letter to FTC on COPPA

Excerpt:  The Internet Association and our members share the Commission’s strong commitment to protecting children’s online privacy.  We are writing to express concern, however, that a recently added COPPA Frequently Asked Questions (“FAQs”) has created uncertainty that could make full compliance by the July 1, 2013, effective date unrealistic.  In particular, COPPA FAQ D.5, which attempts to provide industry guidance in applying the “actual knowledge” standard for purposes of the COPPA Rule, is inconsistent with the text of the statute and the COPPA Rule and is causing more confusion than clarity.

To read the Internet Association’s letter, click here.