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Federal Internet Law & Policy
An Educational Project

Children's Online Privacy Protection Act

Dont be a FOOL; The Law is Not DIY
COPPA
  Who Must Comply
  What is Required
    Notice
    Parental Consent
    Sliding Scale
    Parental Review
    Data Security
  "Personal Info"
  Exceptions
  Giving Away Stuff
  Safeharbors
  Enforcement
  Checklist
  Reference

- Privacy
- Fair Info Practices
- 4th Amendment
- - ECPA
- - FISA
- - Patriot Act
- - Expectation
- - Cybersecurity
- - Anonymity
- FTC
- - ID Theft
- - Spyware
- - Children's Privacy
- - COPPA
- - Cookies
- - Social Networks
- - Advertising
- - Online Profiling
- - Privacy Policies
- - Enforcement
- FCC
- - CPNI
- - Cable
- - CALEA
Dept of Commerce
- - NTIA
- - NIST
- - EU Safe Harbors
- The Feds
- - Pri.Protection Act
- - Privacy Act
- - Pri. Impact Statements
- - Info Law
- - The Press
- Geolocation
- - Location Based Services
- Reference


Enforcement

"The FTC monitors the Internet for compliance with the Rule and brings law enforcement actions when appropriate to deter violations. Parents and others may submit complaints to the FTC through the FTC website, www.ftc.gov , and toll free number, (877) FTC-HELP. Consumer groups, industry members, Commission-approved COPPA safe harbor programs, and other members of the public also may provide information concerning website operators that may not be in compliance with the Rule."

"A court can hold website operators who violate the Rule liable for civil penalties of up to $11,000 per violation. The amount of penalties the court assesses may turn on a number of factors, including the egregiousness of the violation, the number of children involved, the amount and type of personal information collected, how the information was used, whether it was shared with third parties, and the size of the company."

" COPPA gives states and certain federal agencies authority to enforce compliance with the Act itself (not the Rule) with respect to entities over which they have jurisdiction. For example, the Office of the Comptroller of the Currency handles compliance by national banks and the Department of Transportation handles air carriers. " - FTC COPPA FAQs

Remember that compliance with COPPA means two things: first, the creation of the COPPA privacy policy; second, acting on the policy. Creating a policy but failing to comply with it is just as problematic as not creating the policy at all.

COPPA Sec. 1304; 16 CFR § 312.9.

See FTC Children's Privacy: Enforcement

10/20/09 Iconix Brand Group, Inc.,

  • Complaint For Civil Penalties, Injunction, and Other Relief [ PDF ]
  • Exhibit A [ PDF ]
  • Exhibit B [ PDF ]
  • Exhibit C [ PDF ]
  • Exhibit D [ PDF ]
  • Complaint For Civil Penalties, Injunction, and Other Relief [Complete File-Stamped Copy] [ PDF ]
  • Consent Decree and Order [ PDF ]
  • Appendix A [ PDF ]
  • Appendix B [ PDF ]
  • News Release
  • 12/11/08 Sony BMG Music Entertainment

  • Complaint For Civil Penalties, Injunction, and Other Relief [ PDF ]
  • Exhibits A-J [ PDF ]
  • Consent Decree and Order for Civil Penalties, Injunction, and Other Relief [ PDF ]
  • Appendix A [Federal Trade Commission:  Children's Online Privacy Protection Rule, 16 C.F.R. Part 312] [ PDF ]
  • Appendix B [Federal Trade Commission Guide:  How To Comply With The Children's Online Privacy Protection Rule] [ PDF ]
  • News Release
  • 1/30/08 Imbee.com

  • Press Release
  • Complaint [ PDF ]
  • Consent Decree and Order for Civil Penalties, Injunction, and Other Relief [ PDF ]
  • 9/7/06 Xanga

  • Press Release
  • Complaint [ PDF ]
  • Consent Decree and Order for Civil Penalties, Injunction, and Other Relief [ PDF ]
  • 2/18/04 UMG

  • Press Release
  • Complaint, Exhibits
  • 2/18/04 Bonzi

  • Press Release
  • Complaint, Exhibits
  • 2/27/03 Hershey Foods Corporation

  • Press Release
  • Complaint
  • Consent Decree and Order
  • Reasons For Settlement
  • 2/27/03 Mrs. Fields Famous Brands, Inc., Mrs. Fields' Holding Company, Inc., Mrs. Fields' Original Cookies, Inc.

  • Press Release
  • Complaint
  • Consent Decree and Order
  • Reasons For Settlement
  • 4/22/02 The Ohio Art Company (Etch-A-Sketch)

  • Press Release
  • Complaint
  • Consent Decree and Order
  • Reasons For Settlement
  • 2/14/02 American Pop Corn Company (Jolly Time)

  • Press Release
  • Complaint [ PDF ]
  • Exhibits [ PDF ]
  • Consent Decree and Order [ PDF ]
  • 10/2/01 Lisa Frank, Inc.

  • Press Release
  • Complaint [ PDF ]
  • Exhibits [ PDF ]
  • Consent Decree and Order [ PDF ]
  • 4/19/01 Looksmart Ltd.

  • Press Release
  • Complaint [ PDF ]
  • Exhibits [ PDF ]
  • Consent Decree and Order [ PDF ]
  • 4/19/01 Monarch Services, Inc., et al. (Girls' Life)

  • Press Release
  • Complaint [ PDF ]
  • Exhibits [ PDF ]
  • Consent Decree and Order [ PDF ]
  • 4/19/01 Bigmailbox.com, Inc.

  • Press Release
  • Complaint [ PDF ]
  • Exhibits [ PDF ]
  • Consent Decree and Order [ PDF ]
  • 7/21/00 Toysmart.com

  • Press Release
  • Complaint
  • Exhibits [ PDF ]
  • Pre-COPPA Children's Privacy Cases

    8/12/99 Liberty Financial Companies, Inc.

  • Complaint [ PDF ]
  • Exhibit to Complaint [ PDF ]
  • Decision and Order [ PDF ]
  • Agreement Containing Consent Order
  • Analysis of Proposed Consent Order to Aid Public Comment
  • Press Release (5/6/99) 
  • 2/12/99 GeoCities

  • Complaint
  • Exhibits to Complaint [ PDF ]
  • Decision and Order
  • Concurring Statement of Commissioner Swindle
  • Agreement Containing Consent Order
  • Analysis of Proposed Consent Order to Aid Public Comment
  • Press Release (8/13/98)
  • FTC Receives Largest COPPA Civil Penalties to Date in Settlements with Mrs. Fields Cookies and Hershey Foods, FTC 2/28/03
  • FTC Announces Settlements with Web Sites That Collected Children's Personal Data Without Parental Permission, FTC 4/19/01
  • FTC v Ohio Art Company Complaint, FTC 4/24/02
  • FTC v Ohio Art Company Consent Decree, FTC 4/24/02
  • FTC v Ohio Art Company reasons for Settlement, FTC 4/24/02
  • FTC Protecting Children's Privacy Online, FTC 4/22/02
  • Looksmart Ltd. ($35,000 fine), and Bigmailbox.com, Inc. ($35,000 fine) for alleged COPPA violations).
  •  

    News

  • FTC Fines COPPA Violators, Internet News 2/20/2004
  • Three Kids' Sites Settle Web Privacy Charges, Reuters 4/19/01
  • Three Kids' Sites Settle Web Privacy Charges, Reuters 4/19/01
  • U.S. Sues Three Data-Mining Tech Firms, Newsfactor 4/19/01
  • FTC Sues Online "Information Brokers", CW 4/19/01
  • FTC COPPA Compliance Checklist

    The FTC created the following checklist for COPPA Compliance. This checklist was published as a part of the guide FTC, You, Your Privacy Policy and COPPA <www.ftc.gov/bcp/conline/edcams/coppa/index.html>.

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