CDD

CDD Filings

  • CDD and Advocates Call on the FTC to Begin Rulemaking to Prohibit Surveillance AdvertisingJanuary 26, 2022Federal Trade CommissionOffice of the Secretary600 Pennsylvania Avenue NWWashington, DC 20580Re: Comment on Petition for Rulemaking by Accountable Tech, FTC-2021-0070  INTRODUCTIONCenter for Digital Democracy, Common Sense, Fairplay, Parent Coalition for Student Privacy and ParentsTogether strongly support the Petition for Rulemaking to Prohibit Surveillance Advertising filed by Accountable Tech1. We agree that this action is necessary to stop the exploitation of children and teens2.Surveillance advertising, also known as behavioral or targeted advertising, has become the standard business model for a wide array of online platforms with companies utilizing this practice to micro-target all consumers, including children and teens. Surveillance advertising involves the collection of vast amounts of personal data of online users, their demographics, behaviors, preferences, characteristics, and the production of inferences. To create detailed advertising profiles from this data, users are  tracked across websites and devices; they are classified, sorted, and even discriminated against via targeting and exclusion; and ultimately are left vulnerable to manipulation and exploitation.Young people are especially susceptible to the risks posed by surveillance advertising, which is why leading public health advocates like the American Academy of Pediatrics have called for a ban on surveillance advertising to children under 18 years old3. Children’s and teens’ online experiences are shaped by the affordances of surveillance marketing, which entrap them in a complex system purposefully designed to manipulate their behaviors and emotions, while leveraging their data in the process. Young people are a significant audience for the real-time ad profiling and targeting apparatus operated through programmatic platforms and technologies, which poses fundamental risks to their privacy, safety and well-being.  Surveillance advertising is harmful to young people in several ways. First, young people are already more susceptible to advertising’s negative effects and surveillance advertising allows marketers to manipulate children and teens even more effectively. Second, surveillance advertising allows advertisers to target children’s individual vulnerabilities. Third, surveillance advertising can exacerbate inequities by allowing advertisers to target (or abstain from targeting) marginalized communities. Fourth, behavioral advertising is the driving force behind a complex system of data collection and surveillance that tracks all of children’s online activity, undermining young people’s privacy and wellbeing. Finally, the Children’s Online Privacy Protection Act has failed to effectively protect children under thirteen from surveillance advertising and a more expansive prohibition is needed to protect the youngest and most vulnerable users online.For these reasons, we urge the Commission to protect children and teens by prohibiting surveillance advertising.......Please read the full petition, see PDF below......____________________________________________186 Fed. Reg. 73206 (Dec. 27, 2021).2Pet’n for Rulemaking at 32-33.3Jenny Radesky, Yolanda (Linda) Reid Chassiakos, Nusheen Ameenuddin, Dipesh Navsaria, Council on Communications and Media; Digital Advertising to Children. Pediatrics July 2020; 146 (1): e20201681. 10.1542/peds.2020-1681.childrens_coalition_survadv_1-26-22.pdf
  • Contact: Jeff Chester, CDD jeff@democraticmedia.org (link sends e-mail); 202-494-7100David Monahan, CCFC, david@commercialfreechildhood.org (link sends e-mail)Advocates say Google Play continues to disregard children’s privacy law and urge FTC to act BOSTON, MA and WASHINGTON, DC — March 31, 2021—Today, advocacy groups Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) called on the Federal Trade Commission (FTC) to investigate Google’s promotion of apps which violate the Children’s Online Privacy Protection Act (COPPA). In December 2018, CCFC and CDD led a coalition of 22 consumer and health advocacy groups in asking the FTC to investigate these same practices. Since then Google has made changes to the Play Store, but the advocates say these changes fail to address the core problem: Google is certifying as safe and appropriate for children apps that violate COPPA and put children at risk. Recent studies found that a significant number of apps in Google Play violate COPPA by collecting and sharing children’s personal information without getting parental consent. For instance, a JAMA Pediatrics study found that 67% of apps used by children aged 5 and under were transmitting personal identifiers to third parties.Comment of Angela Campbell, Chair of the Board of Directors, Campaign for a Commercial-Free Childhood, Professor Emeritus, Communications & Technology Law Clinic, Georgetown University Law Center:“Parents reasonably expect that Google Play Store apps designated as ‘Teacher approved’ or appropriate for children under age 13 comply with the law protecting children’s privacy. But far too often, that is not the case. The FTC failed to act when this problem was brought to its attention over two years ago. Because children today are spending even more time using mobile apps, the FTC must hold Google accountable for violating children’s privacy.”Comment of Jeff Chester, executive Director of the Center for Digital Democracy:"The Federal Trade Commission must swiftly act to stop Google’s ongoing disregard of the privacy and well-being of children. For too long, the Commission has allowed Google’s app store, and the data marketing practices that are its foundation, to operate without enforcing the federal law that is designed to protect young people under 13. With children using apps more than ever as a consequence of the pandemic, the FTC should enforce the law and ensure Google engages with kids and families in a responsible manner."###
  • Contact: Jeff Chester, CDD (jeff@democraticmedia.org (link sends e-mail); 202-494-7100) David Monahan, CCFC (david@commercialfreechildhood.org (link sends e-mail);) Statement from Campaign for a Commercial-Free Childhood and Center for Digital Democracy on Comments filed with FTC regarding Endorsement Guides WASHINGTON, DC and BOSTON, MA—June 23, 2020—Advocacy groups Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) filed comments on Monday in response to the FTC’s request for public comment (link is external) on its Endorsement Guides. Jeff Chester, executive director, Center for Digital Democracy: "Influencer marketing should be declared an unfair and deceptive practice when it comes to children. The FTC is enabling so-called ‘kidfluencers,’ ‘brand ambassadors,’ and other ‘celebrity’ marketers to stealthily pitch kids junk food, toys and other products, despite the known risks to their privacy, personal health and security. Kids and teens are being targeted by a ‘wild west’ influencer marketing industry wherever they go online, including when they watch videos, play games, or use social media. It's time for the FTC to place the interests of America's youth before the manipulative commercial activities of influencers." Josh Golin, Executive Director, Campaign for a Commercial-Free Childhood: “The FTC’s failure to act has helped create an entire ecosystem of unfair and deceptive influencer marketing aimed at children. It’s past time for the Commission to send a strong message to everyone – platforms, brands, ad agencies and the influencers themselves – that children should not be targets for this insidious and manipulative marketing.” Angela J. Campbell, Director Emeritus of the Institute for Public Representation’s Communications and Technology Clinic at Georgetown Law, currently chair of CCFC’s Board, and counsel to CCFC and CDD: "Influencer videos full of hidden promotions and sometimes blatant marketing have largely displaced actual programs for children. The FTC must act now to stop these deceptive and unfair practices." ###
  • Press Release

    Groups Tell FTC to Investigate TikTok’s Failure to Protect Children’s Privacy

    TikTok gathers data from children despite promise made to commission

    Contact: Jeff Chester, CDD (jeff@democraticmedia.org (link sends e-mail); 202-494-7100) David Monahan, CCFC (david@commercialfreechildhood.org (link sends e-mail);) Advocates Say TikTok In Contempt of Court Order More kids than ever use the site due to COVID19 quarantine, but TikTok flouts settlement agreement with the FTC WASHINGTON, DC and BOSTON, MA—May 14, 2020—Today, a coalition of leading U.S. child advocacy, consumer, and privacy groups filed a complaint (link is external) urging the Federal Trade Commission (FTC) to investigate and sanction TikTok for putting kids at risk by continuing to violate the Children’s Online Privacy Protection Act (COPPA). In February 2019, TikTok paid a $5.7 million fine for violating COPPA, including illegally collecting personal information from children. But more than a year later, with quarantined kids and families flocking to the site in record numbers, TikTok has failed to delete personal information previously collected from children and is still collecting kids’ personal information without notice to and consent of parents. Campaign for a Commercial-Free Childhood (CCFC), the Center for Digital Democracy (CDD), and a total of 20 organizations demonstrated in their FTC filing that TikTok continues to violate COPPA by: failing to delete personal information related to children under 13 it obtained prior to the 2019 settlement order; failing to give direct notice to parents and to obtain parents’ consent before collecting kids’ personal information; and failing to give parents the right to review or delete their children’s personal information collected by TikTok. TikTok makes it easy for children to avoid obtaining parental consent. When a child under 13 tries to register using their actual birthdate, they will be signed up for a “younger users account” with limited functions, and no ability to share their videos. If a child is frustrated by this limited functionality, they can immediately register again with a fake birthdate from the same device for an account with full privileges, thereby putting them at risk for both TikTok’s commercial data uses and inappropriate contact from adults. In either case, TikTok makes no attempt to notify parents or obtain their consent. And TikTok doesn’t even comply with the law for those children who stick with limited “younger users accounts.” For these accounts, TikTok collects detailed information about how the child uses the app and uses artificial intelligence to determine what to show next, to keep the child engaged online as long as possible. The advocates, represented by the Communications & Technology Law Clinic in the Institute for Public Representation at Georgetown Law, asked the FTC to identify and hold responsible those individuals who made or ratified decisions to violate the settlement agreement. They also asked the FTC to prevent TikTok from registering any new accounts for persons in the US until it adopts a reliable method of determining the ages of its users and comes into full compliance with the children’s privacy rules. In light of TikTok’s vast financial resources, the number and severity of the violations, and the large number of US children that use TikTok, they asked the FTC to seek the maximum monetary penalties allowed by law. Josh Golin, Executive Director of Campaign for a Commercial-Free Childhood, said “For years, TikTok has ignored COPPA, thereby ensnaring perhaps millions of underage children in its marketing apparatus, and putting children at risk of sexual predation. Now, even after being caught red-handed by the FTC, TikTok continues to flout the law. We urge the Commission to take swift action and sanction TikTok again – this time with a fine and injunctive relief commensurate with the seriousness of TikTok’s serial violations.” Jeff Chester, Executive Director of the Center for Digital Democracy, said “Congress empowered the FTC to ensure that kids have online protections, yet here is another case of a digital giant deliberately violating the law. The failure of the FTC to ensure that TikTok protects the privacy of millions of children, including through its use of predictive AI applications, is another reason why there are questions whether the agency can be trusted to effectively oversee the kids’ data law.” Michael Rosenbloom, Staff Attorney and Teaching Fellow at the Institute for Public Representation, Georgetown Law, said “The FTC ordered TikTok to delete all personal information of children under 13 years old from its servers, but TikTok has clearly failed to do so. We easily found that many accounts featuring children were still present on TikTok. Many of these accounts have tens of thousands to millions of followers, and have been around since before the order. We urge the FTC to hold TikTok to account for continuing to violate both COPPA and its consent decree.” Katie McInnis, Policy Counsel at Consumer Reports, said "During the pandemic, families and children are turning to digital tools like TikTok to share videos with loved ones. Now more than ever, effective protection of children's personal information requires robust enforcement in order to incentivize companies, including TikTok, to comply with COPPA and any relevant consent decrees. We urge the FTC to investigate the matters raised in this complaint" Groups signing on to the complaint to the FTC are: Campaign for a Commercial-Free Childhood, the Center for Digital Democracy, Badass Teachers Association, Berkeley Media Studies Group, Children and Screens: Institute of Digital Media and Child Development, Consumer Action, Consumer Federation of America, Consumer Reports, Defending the Early Years, Electronic Privacy Information Center, Media Education Foundation, Obligation, Inc., Parent Coalition for Student Privacy, Parents Across America, ParentsTogether Foundation, Privacy Rights Clearinghouse, Public Citizen, The Story of Stuff, United Church of Christ, and USPIRG. ###
  • Washington, December 11, 2019 In comments filed today in response to the Federal Trade Commission’s review of COPPA, the Center for Digital Democracy, the Campaign for a Commercial-Free Childhood, the American Academy of Pediatrics, and a total of 19 advocacy groups faulted the FTC for failing to engage in sufficient enforcement and oversight of the children’s privacy law. The groups suggested how COPPA can better protect children’s privacy, and urged the Commission not to weaken the law to satisfy industry’s thirst for more data about kids. The advocates also urged the FTC first to investigate the children’s “kid tech” market before it proposes any changes in how to implement its rules. The following can be attributed to Jeff Chester, Executive Director, Center for Digital Democracy: “Children are at greater risk today of losing their digital privacy because the FTC has failed to enforce COPPA. For years, the Commission has allowed Google and many others to ignore the landmark bipartisan law designed to protect children under 13. It’s time for the FTC to stand up to the big data companies and put the interests of young people and families first.” The following can be attributed to Josh Golin, Executive Director, Campaign for a Commercial-Free Childhood: “This is a critical moment for the future of children’s online privacy. The ink is barely dry on the FTC’s first major COPPA enforcement, and already industry is mobilizing to weaken the rules. The FTC should not make any changes to COPPA until it uses its authority to learn exactly how Big Tech is collecting and monetizing our children’s data.” The following can be attributed to Kyle Yasuda, MD, FAAP, President, American Academy of Pediatrics: “Keeping children safe and healthy where they learn and grow is core to what pediatricians do every day, and today more than ever before that extends to the digital spaces that children inhabit. The Children’s Online Privacy Protection Act is a foundational law that helps hold companies accountable to basic standards of safety when it comes to children’s digital privacy, but it’s only as effective as its enforcement by the Federal Trade Commission. Before any major changes are made to COPPA, we must ensure that the FTC is doing its part to keep children safe wherever they engage online.” The following can be attributed to Laura Moy, Associate Professor of Law, Director of the Communications and Technology Law Clinic, Institute for Public Representation at Georgetown University Law Center: “A recent survey showed that the majority of Americans feel that ‘the threat to personal privacy online is a crisis.’ We are at a critical point in our nation’s history right now—when we are deciding whether or not to allow companies to track, profile, and target us to an extent that compromises our ability to be and make decisions for ourselves. At the forefront of that discussion are children. We must protect the next generation from inappropriate tracking so that they can grow up with privacy and dignity. To make good on that, the FTC must thoroughly investigate how companies are collecting and using children’s data, and must enforce and strengthen COPPA.”
  • Press Release

    Leading child advocacy, health, and privacy groups call on FTC to Investigate Children’s Digital Media Marketplace Before Proposing any Changes to Privacy Protections for Children

    Threats to young people from digital marketing and data collection must be analyzed to ensure meaningful safeguards under the Children’s Online Privacy Protection Act (COPPA).

    EMBARGOED UNTIL DECEMBER 5, 2019 AT 12:01 AM Contact: Jeffrey Chester, CDD, jeff@democraticmedia.org (link sends e-mail), (202) 494-7100 Josh Golin, CCFC, josh@commercialfreechildhood.org (link sends e-mail); 617-896-9369 Leading child advocacy, health, and privacy groups call on FTC to Investigate Children’s Digital Media Marketplace Before Proposing any Changes to Privacy Protections for Children Threats to young people from digital marketing and data collection must be analyzed to ensure meaningful safeguards under the Children’s Online Privacy Protection Act (COPPA). WASHINGTON, DC and BOSTON, MA – December 5, 2019 – A coalition of 31 advocacy groups is urging the Federal Trade Commission to use its subpoena authority to obtain information from leading digital media companies that target children online. In comments filed today by the Institute for Public Representation at Georgetown and organized by Center for Digital Democracy (CDD) and the Campaign for a Commercial-Free Childhood (CCFC), the coalition explained the opaque data and digital marketing practices targeting kids. The comments are filed with the FTC as part of its early review of the rules protecting children under the Children’s Online Privacy Protection Act (COPPA). The advocates’ call was supported by Sesame Workshop, the leading producer of children’s educational programming, in a separate filing. To better assess the impacts on children from today’s digital data-driven advertising system, and features such as cross-device tracking, artificial intelligence, machine learning, virtual reality, and real-time measurement—the advocates urge the commission to gather and analyze data from leading companies that target children. Any proposed changes to COPPA must be based on empirical data, which is consistent with calls by Commissioners Wilson, Phillips, and Simons that rulemaking must be evidence-based. In their comments, the organizations ask the FTC to use its authority under rule 6(b) to: - Examine today’s methods of advertising to children and their impact, including their discriminatory effects - Examine practices concerning data collection and retention - Illuminate children’s presence on “general audience” platforms and those platforms’ awareness of children’s presence - Identify how the data of children is being used by contemporary data platforms, including “marketing clouds,” “identity management” systems, in-house data management platforms, and data brokers - Illuminate the efficacy—or lack thereof—of safe harbors Groups that have signed the comments are Campaign for a Commercial-Free Childhood; Center for Digital Democracy; American Academy of Pediatrics; Badass Teachers Association; Berkeley Media Studies Group; Center for Science in the Public Interest; Children and Screens; Color of Change; Common Sense Media; Consumer Action; Consumer Federation of America; Consumer Federation of California; Consumer Reports; Consumer Watchdog; Corporate Accountability; Defending the Early Years; Electronic Frontier Foundation; Electronic Privacy Information Center; Obligation, Inc.; Parent Coalition for Student Privacy; Parents Across America; Parents Television Council; P.E.A.C.E. (Peace Educators Allied For Children Everywhere) (link is external); Privacy Rights Clearinghouse; Public Citizen; Public Knowledge; The Story of Stuff; TRUCE (Teachers Resisting Unhealthy Childhood Entertainment); UnidosUS; United Church of Christ; and U.S. Public Interest Research Group (U.S. PIRG). …. The following can be attributed to Kyle Yasuda, MD, FAAP, President, American Academy of Pediatrics: “As children become more digitally connected, it becomes even more important for parents, pediatricians and others who care for young children to understand how digital media impacts their health and development. Since digital technology evolves rapidly, so must our understanding of how data companies are engaging with children’s information online. As we pursue the promise of digital media for children’s development, we must design robust protections to keep them safe based on an up-to-date understanding of the digital spaces they navigate.” The following can be attributed to Josh Golin, Executive Director of Campaign for Commercial-Free Childhood: As kids are spending more time than ever on digital devices, we need the full power of the law to protect them from predatory data collection -- but we can't protect children from Big Tech business models if we don't know how those models truly work. The FTC must use its full authority to investigate opaque data and marketing practices before making any changes to COPPA. We need-to-know what Big Tech knows about our kids." The following can be attributed to Katharina Kopp, Director of Policy, Center for Digital Democracy (CDD): “Children are being subjected to a purposefully opaque ‘Big Data’ digital marketing system that continually gathers their information when they are online. The FTC must use its authority to understand how new and evolving advertising practices targeting kids really work, and whether these data practices are having a discriminatory, or other harmful impact, on their lives.” The following can be attributed to James P. Steyer, CEO and Founder of Common Sense: "Kids and families have to be the priority in any changes to COPPA and in order to do that, we must fully understand what the industry is and isn’t doing when it comes to tracking and targeting kids. Tech companies are never going to be transparent about their business practices which is why it is critical that the FTC use its authority to look behind the curtain and shed light on what they are doing when it comes to kids so that if any new rules are needed, they can be smart and well-informed." The following can be attributed to Katie McInnis, Policy Counsel, Consumer Reports: "We’re glad the FTC is asking for comments on the implementation of COPPA through the 2013 COPPA rule. But the Commission should have the fullest possible picture of how children's personal information is being collected and used before it considers any changes. It’s well-documented that compliance with COPPA is uneven among apps, connected toys, and online services. The FTC must fully understand how kids’ personal information is treated before the 2013 rule can be modified, in order to ensure that children and their data are protected.” The following can be attributed to Marc Rotenberg, President, Electronic Privacy Information Center (EPIC): “The FTC should complete its homework before it proposes changes to the regulations that safeguard children’s privacy. Without a clear understanding of current industry practices, the agency’s proposal will be ill-informed and counterproductive." The following can be attributed to Lindsey Barrett, Staff Attorney and Teaching Fellow, Institute for Public Representation, Georgetown Law: The FTC should conduct 6(b) studies to shed light on the complex and evolving profiling practices that violate children’s privacy. Children are being monitored, quantified, and analyzed more than ever before, and the Commission cannot make informed decisions about the rules that protect them online based on limited or skewed information about the online ecosystem. The following can be attributed to Robert Weissman, President, Public Citizen: “The online corporate predators are miles ahead of the FTC, employing surveillance and targeting tactics against children that flout the protections enshrined in COPPA. The first thing the FTC should do is invoke its investigative powers to get a firm grasp on how Big Tech is systematically invading children’s privacy.” The following can be attributed to Cheryl A. Leanza, Policy Advisor, UCC OC Inc.: “In the modern era, our data are our lives and our children’s lives are monitored and tracked in more detail than any previous generation to unknown effect. Parents seek to pass on their own values and priorities to their children, but feel subverted at every turn by unknown algorithms and marketing efforts directed to their children. At a minimum, the FTC must collect basic facts and trends about children and their data privacy.” The following can be attributed to Eric Rodriguez, Senior Vice President, UnidosUS: “All children should have the right to privacy and live free from discrimination, including in digital spaces. Latino children are targeted by digital marketing efforts and with real consequences to their health and wellbeing. UnidosUS urges the Commission to use its authority and study how children of color operate in the digital space, what happens to their personal data, and how well they are protected by COPPA. Only then can the Commission take effective and objective action to strengthen COPPA to protect an increasingly diverse youth population.”
    Jeff Chester
  • Most parents can tell you the most popular website for kids is YouTube. But for years, while Google made millions luring children to YouTube, vacuuming up their sensitive information, and using it to target them with ads, Google told the Big Lie: “YouTube is not for kids. It says so right in our terms of service.” That has now changed, thanks to the advocacy of Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) and the support of a coalition of advocacy groups. Google deliberately developed YouTube as the leading site for children with programming and marketing strategies designed to appeal directly to kids. But it ignored the only federal law addressing commercial privacy online—the Children’s Online Privacy Protection Act (COPPA). Their behavior sent a message that a corporation as powerful and well-connected corporation as Google is above the law—even laws designed to protect young people. CCFC, CDD, and our attorneys at the Institute for Public Representation (link is external) (IPR) at Georgetown University Law Center, with a broad coalition of consumer, privacy, public health and child rights groups, began filing complaints at the Federal Trade Commission (FTC) in 2015 concerning Google’s child-directed practices on YouTube and the YouTube Kids app. We kept up the pressure on the FTC, with the help of Congress and the news media. After we filed a complaint (link is external) in April 2018 describing YouTube’s ongoing violations of COPPA, the FTC, under the leadership of Chairman Joe Simons, finally decided to take action. The result was the FTC’s September decision (link is external)—which in many ways is both historic and a major step in the direction of protecting children online. Google was fined $170 million for its violations of children’s privacy, a record amount for a COPPA-connected financial sanction. The FTC’s action also implemented important new policies (link is external) protecting children, most of which will go into effect by January 2020: Children will no longer be targeted with data-driven marketing and advertising on YouTube programming targeted to kids: This is the most important safeguard. Google will no longer conduct personalized “behavioral” marketing on YouTube programming that targets children. In other words, they will stop the insidious practice of using kids’ sensitive information in order to target them with ads tailored for their eyes. Google will require video producers and distributors to self-identify that their content is aimed at kids; and will also employ its own technology to identify videos that target young audiences. Google will substantially curtail the data they collect from children watching YouTube videos. Since the main YouTube site has no age gate, they will limit data collection and tracking of viewers’ identities for anyone watching child-directed content there to only the data “needed to support the operation of the service.”. The same limitation will apply to videos on YouTube Kids. Google is taking steps to drive kids from the main YouTube site to YouTube Kids, where parental consent is required. Google launched the YouTube Kids app in 2015. But the app never rivaled the main YouTube platform’s hold on children, and was plagued with a number of problems, such as inadequate screening of harmful content. As a result of the FTC investigation, Google has launched a YouTube Kids website, and when kids watch children’s content on the main YouTube site they get a pop-up suggesting they visit YouTube Kids. Google says it will more effectively curate different programming that will appeal to kids aged 4 through 12. This is a positive development because, while a number of concerns remain about YouTube Kids, children are better off using the Kids site rather than the Wild West of the main YouTube platform. Google created a $100 million fund for “quality kids, family and educational content.” CCFC and CDD had proposed this, and we are gratified Google acknowledged it bears responsibility to support programing that enriches the lives of children. This is to be a three-year program to spur “the creation of thoughtful, original children’s content.” Google has made changes to make YouTube a “safer platform for children:” The company is proactively promoting “quality” children’s programming on YouTube by revising the algorithm used to make recommendations. It is also not permitting comments and notifications on child-directed content. Google has told CCFC and CDD it will make these changes regarding data collection and targeted marketing worldwide. Other questions remain to be answered. How will it treat programming classified as “family viewing”—exempt it from the new data targeting safeguards? (It should not be permitted to do so.) Will the new $100 million production fund commit to supporting child-directed non-commercial content (instead of serving as a venture for Google to expand its marketing to kids)? Will Google ensure that its other child-directed commercial activities—such as its Play Store—also reflect the new safeguards the company has adopted for YouTube? Google also permits the targeting of young people via “influencers,” including videos where toys and other products are unboxed. When such videos are child-directed, Google should put an end to them. CCFC, CDD and our allies intend to play a proactive role holding Google, its programmers, advertisers and the FTC accountable to make sure that these new policies are implemented effectively. Our work in bringing about this change and the work we will do to make other companies follow suit is part of our commitment to ensuring that young people around the world grow up in a media environment that respects and promotes their health, privacy, and well-being.