COPPA

FTC Introduces Novel Ban in Its Settlement with NGL Labs and Scrutinizes AI Representations

By Emily Litka

On July 9, 2024, The Federal Trade Commission (FTC) and the Los Angeles District Attorney’s Office (LA DA) reached a settlement with NGL Labs, the maker of the “NGL: ask me anything” app and its co-founders. The complaint alleged violations of the Federal Trade Commission Act (FTC Act), the Children’s Online Privacy Protection Act (COPPA), the Restore Online Shoppers’ Confidence Act (ROSCA), and similar California state laws. In the complaint, the FTC and LA DA also brought claims against NGL’s cofounders individually. 

Read More

FTC Takes Action Against Education Technology Provider Edmodo

By Amy Lanchester

On May 22nd, 2023, the Federal Trade Commission (FTC) issued a proposed order against Edmodo, LLC (“Edmodo”), a California-based education technology provider, for allegedly violating the FTC’s Children’s Online Privacy Protection Rule (“COPPA Rule") by illegally collecting the information of children and using that information for advertising, and for allegedly violating Section 5 of the FTC Act by unfairly burdening schools and teachers with COPPA-compliance responsibilities. In a first for an FTC order, Edmodo is prohibited from requiring students to hand over more personal data than is reasonably necessary to participate in online educational activities.

Read More

FTC Issues Stern Warning on Ed-Tech and COPPA

By Sheila Sokolowski

On May 19, 2022, the FTC issued a stern warning to ed-tech providers regarding compliance with COPPA suggesting enhanced enforcement in this area. Citing “the steady proliferation of technologies that allow, and business models that depend on, the online collection and monetization of consumers’ personal information” and “the development of ever more sophisticated targeting practices,” the Federal Trade Commission (FTC) voted unanimously to issue a policy statement regarding collection of children’s information by ed tech providers.  The Policy Statement of the Federal Trade Commission on Education Technology and the Children's Online Privacy Protection Act states that the FTC “intends to scrutinize compliance with the full breadth of the substantive provisions of the COPPA Rule and statutory language.” The FTC’s statement highlights COPPA’s limitations on collection, use and retention of children’s personal information and security requirements, all of which apply to COPPA-covered ed-tech companies.

Read More

FTC Issues Enforcement Policy Statement on COPPA and Voice Recordings

By Smriti Chandrashekar

On October 23, 2017, the U.S. Federal Trade Commission (“FTC”) issued guidance on the online collection of certain audio voice recordings from children under the age of 13.  The guidance, in the form of an “enforcement policy statement” discusses the application of the Children’s Online Privacy Protection Act (“COPPA”) to such recordings. 

Read More

FTC updates COPPA Compliance Plan for Businesses

By Carolyn Krol

On June 21, 2017, the U.S. Federal Trade Commission (“FTC”) published an update to the Children’s Online Privacy Protection Rule (“COPPA”) compliance plan for businesses. The FTC Business Blog describes the update as a reflection of the developments in the marketplace, such as internet-connected toys. The compliance plan provides businesses with a step-by-step guide to determine if a business activity is covered by COPPA, and if so, how to comply with COPPA.

Read More