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Re: New Federal Law (COPPA)

  • From: Robert Cannon
  • Date: Mon Apr 24 15:06:38 2000

Someone followed up with the following question:


The FTC has stated the following:  "To determine whether a Web site is
directed to children, the FTC will consider several factors, including the
subject matter; visual or audio content; the age of models on the site;
language; whether advertising on the Web site is directed to children;
information regarding the age of the actual or intended audience; and
whether a site uses animated characters or other child-oriented features. " 
See COPPA Sec 1302(10); 16 CFR  312.2 (Definitions),

If the FTC could make it up as they go along, they would be vulnerable to an
attack that their rules are arbitrary and capricious, a violation of the
Administratove Procedures Act.  As enforcement proceedings take place, the
description above will be further amplified.


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