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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.

Contact: David Monahan, CCFC (david@commercialfreechildhood.org (link sends e-mail); 617-896-9397) Jeff Chester, CDD (jeff@democraticmedia.org (link sends e-mail); 202-494-7100) Will the FTC Weaken Children’s Privacy Rules? Invited Advocates Raise Concerns About Upcoming COPPA Workshop, Plans to Undermine Federal Protections for Kids October 7 D.C. lineup dominated by tech industry supporters WHAT: The Future of the Children’s Online Privacy Protection Act Rule (COPPA): An FTC Workshop (link is external) WHEN: October 7, 2019, 9:00 am ET WHERE: Constitution Center, 400 7th St SW, Washington, DC WORKSHOP PRESENTERS FOR CAMPAIGN FOR A COMMERCIAL-FREE CHILDHOOD (CCFC) AND CENTER FOR DIGITAL DEMOCRACY (CDD): THE CHALLENGE: In 2012, the FTC approved new safeguards to protect children’s privacy in the digital era, heeding the advice of child advocates, consumer groups, privacy experts and health professionals. But now the Commission has called for comments (link is external) on COPPA three years before a new review is mandated by statute. The questions posed by the Commission, as well as public comments made by FTC staff, make privacy advocates wary that the FTC’s goal is to roll back COPPA safeguards rather than strengthen protections for children. Concerns about the FTC creating new loopholes or supporting industry calls to weaken the rules are heightened by the FTC’s speaker list for this workshop, replete with tech and marketing companies and their lawyers and lobbyists, with just a few privacy and children’s advocates at the table. The advocates are also concerned that the FTC is contemplating this action just weeks after its most significant COPPA enforcement action to date—requiring major changes to Google’s data collection practices on YouTube—a move that could result in rules being changed before those new practices have even been implemented. Children and families need increased COPPA enforcement, not weaker rules. The key problems, the advocates note, are the lack of enforcement of the law by the FTC; the failure of the agency to protect children from unfair marketing practices, such as influencers; and the need to maintain the strongest possible safeguards—whether in the home, school or on mobile devices. Speakers at the workshop include: Josh Golin, Executive Director, CCFC Will participate in a panel entitled Scope of the COPPA Rule. Katharina Kopp, Ph.D., Deputy Director, Director of Policy, CDD Will participate in a panel entitled Uses and Misuses of Persistent Identifiers. Laura M. Moy, Associate Professor of Law, Director, Communications & Technology Law Clinic, Georgetown University Law Center Will participate in a panel entitled State of the World in Children’s Privacy. Josh, Katharina, and Laura are available for questions in advance of the workshop, and will also be available to speak with press on site. See video of Future of COPPA Workshop here: https://www.ftc.gov/news-events/audio-video/video/future-coppa-rule-ftc-... (link is external) https://www.ftc.gov/news-events/audio-video/video/future-coppa-rule-ftc-... (link is external) ###

Press Statement Google YouTube FTC COPPA Settlement Statement of Katharina Kopp, Ph.D. Deputy Director Center for Digital Democracy August 30, 2019 It has been reported that Google has agreed to pay between $150 million and $200 million to resolve an FTC investigation into YouTube over alleged violations of a children's privacy law. A settlement amount of $150-200 million would be woefully low, considering the egregious nature of the violation, how much Google profited from violating the law, and given Google’s size and revenue. Google’s unprecedented violation requires an unprecedented FTC response. A small amount like this would effectively reward Google for engaging in massive and illegal data collection without any regard to children’s safety. In addition to assessing substantial civil penalties, the FTC must enjoin Google from committing further violations of COPPA and impose effective means for monitoring compliance; the FTC must impose a 20-year consent decree to ensure Alphabet Inc. acts responsibly when it comes to serving children and parents. ------ In April, 2018, the Center for Digital Democracy (CDD) and the Campaign for Commercial-Free Childhood (CCFC), through their attorneys at Georgetown Law’s Institute for Public Representation (IPR), filed an FTC complaint (link is external) detailing YouTube’s COPPA violations. Twenty-one other privacy and consumer groups signed on to CCFC and CDD’s complaint, which detailed how Google profits by collecting personal information from kids on YouTube, without first providing direct notice to parents and obtaining their consent as required by law. Google uses this information to target advertisements to children across the internet and across devices, in clear violation of COPPA.

FOR RELEASE July 26, 2019 Consumer Privacy Organizations to Challenge Facebook Settlement Statement from Groups --------- “The Settlement Fails to Provide Meaningful Relief to Facebook Users” WASHINGTON, DC – Many of the nation’s leading consumer privacy organizations are urging a federal court in Washington, DC to consider public comments before finalizing a proposed settlement between the Federal Trade Commission and Facebook. “The Facebook settlement is both historic and controversial. Many believe the FTC failed to establish meaningful safeguards for consumer privacy. We believe the court overseeing the case should consider the views of interested parties,” said Marc Rotenberg, President of the Electronic Privacy Information Center. Under the terms of the settlement, Facebook will pay a record-breaking $5 b fine to the United States Treasury, but there will be no significant changes in Facebook’s business practices and the FTC will release all pending complaints against the company. Typically in a proposed FTC settlement, the public would be provided an opportunity to provide comments to the agency before finalizing the deal. But no such opportunity was provided in the Facebook settlement. Many of the organizations that are joining the effort have also filed detailed complaints with the Federal Trade Commission, alleging that Facebook has violated privacy laws, including the Children’s Online Privacy Protection Act. A Freedom of Information Act case revealed that there are more than 26,000 complaints against Facebook currently pending at the Commission. In a similar case in 2012, the privacy group Consumer Watchdog challenged the FTC settlement with Google regarding the Safari hack. In other consumer privacy cases, courts have created opportunities for interested parties to file papers and be heard prior to a final determination on a proposed settlement. The case is In the Matter of Facebook, No. 19-cv-2184 (D.D.C. Filed July 24, 2019) EPIC filed with the court today: https://epic.org/2019/07/epic-challenges-ftc-facebook-s.html (link is external) Statements of Support: Brandi Collins-Dexter, Senior Campaign Director, Color of Change, “Despite the large price tag, the FTC settlement provides no meaningful changes to Facebook’s structure or financial incentives. It allows Facebook to continue to set its own limits on how much user data it can collect and it gives Facebook immunity for unspecified violations. The public has a right to know what laws Facebook violated. Corporations should face consequences for violating the public trust, not be given a rubber stamp to carry out business as usual. This settlement limits the ability of Black users to challenge Facebook’s misuse of their data and force real accountability which is why the courts must review the fairness of this settlement.” Susan Grant, Director of Consumer Protection and Privacy, Consumer Federation of America: “The FTC’s settlement with Facebook sells consumers short by failing to change the company’s mass surveillance practices and wiping away other complaints that deserved to be addressed. It needs to be stronger to truly protect our privacy.” Linda Sherry, Director of National Priorities, Consumer Action: “The FTC’s pending Facebook settlement does not take adequate measures to limit the collection and sharing of consumers’ personal information, but appears to provide the company with extensive protections from even future violations. Consumer Action respectfully urges the court to consider positions from interested parties who have related complaints filed with the FTC to ensure that the most fair and comprehensive agreement is approved.” Sally Hubbard, Director of Enforcement Strategy, Open Markets. “The FTC’s settlement is woefully insufficient in light of Facebook’s persistent privacy violations. The fine is a mere cost of doing business that makes breaking the law worth it for Facebook. Remedies must curb Facebook’s widespread data collection and promote competition. Otherwise Facebook will continue to fortify its monopoly power by surveilling users both on Facebook and off, and users can’t vote with their feet when Facebook violates their privacy. The public must have the opportunity to be heard on this negligent settlement." Robert Weissman, President, Public Citizen: “The FTC's settlement amounts to Facebook promising yet again to adhere to its own privacy policy, while reserving the right to change that policy at any time. That approach will fail to protect users' privacy. The court should reject the settlement and order the FTC to try again and do better.” Josh Golin, Executive Director, Campaign for Commercial-Free Childhood: “Facebook has been exploiting kids for years, and this proposed settlement is essentially a get-out-of-jail-free card. It potentially extinguishes our children's privacy complaints against Facebook, but offers absolutely no protections for kids' privacy moving forward. It also sweeps under the rug a complaint detailing how Facebook knowingly and intentionally tricked kids into spending money on mobile games over several years, sometimes to the tune of thousands of dollars per child.” James P. Steyer, CEO and Founder of Common Sense Media: "On behalf of families across the country, Common Sense fully stands behind EPIC's motion. The proposed settlement is a "get out of jail free" card for Facebook, purporting to absolve Facebook not only of liability for privacy abuses but for other -- completely unaddressed and unexplored -- Section 5 abuses. One such abuse that the FTC is aware of and that court documents confirm includes tricking kids into making in-app purchases that have put families out hundreds and even thousands of dollars —something the company has yet to meaningfully change its policies on to this day. Such a broad release is unprecedented, unjustified and unacceptable." Edmund Mierzwinski, Senior Director for Federal Consumer Programs, U.S. PIRG: "This laughable $5 billion settlement with the category-killer social media giant Facebook makes the much smaller Equifax settlement for sloppy security look harsh. Facebook intentionally collects and shares an ever-growing matrix of information about consumers, their friends and their interests in a mass surveillance business model. It routinely changes its previous privacy promises without consent. It doesn't adequately audit its myriad business partners. The FTC essentially said to Facebook: "Pay your parking ticket but don't ever change. Your fast-and-loose practices are okay with 3 of the 5 of us." Not changing those practices will come back to haunt the FTC, consumers and the world.” Jeff Chester, Executive Director, Center for Digital Democracy: "The 3-2 Facebook decision by the FTC leaves millions of Americans vulnerable to all the problems unleashed by the Cambridge Analytica scandal. The commission adopted a woefully inadequate remedy that does nothing to stem the fundamental loss of its user privacy which led to our original 2009 complaint."

Letter sent on June 3 2019 to Chairman Simons and FTC Commissioners in response to a call made by the Campaign for Commercial-Free Childhood and CDD, represented by our attorneys from the Institute for Public Representation (IPR), Georgetown University Law Center with the commission.

June 25, 2019 The Honorable Joseph Simons The Honorable Noah Phillips Chairman Commissioner Federal Trade Commission Federal Trade Commission 600 Pennsylvania Avenue, NW 600 Pennsylvania Avenue, NW Washington, DC 20580 Washington, DC 20580 The Honorable Rohit Chopra The Honorable Rebecca Slaughter Commissioner Commissioner Federal Trade Commission Federal Trade Commission 600 Pennsylvania Avenue, NW 600 Pennsylvania Avenue, NW Washington, DC 20580 Washington, DC 20580 The Honorable Christine Wilson Commissioner Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 Dear Chairman Simons, Commissioner Phillips, Commissioner Chopra, Commissioner Slaughter, and Commissioner Wilson: The Campaign for a Commercial-Free Childhood (CCFC) and Center for Digital Democracy (CDD) have been encouraged by recent media reports that the Federal Trade Commission is preparing to take action against Google and YouTube for violating the Children’s Online Privacy Protection Act (COPPA). CCFC and CDD, represented by the Institute for Public Representation at Georgetown Law (IPR), are the organizations responsible for drafting the Request to Investigate Google and YouTube filed with the FTC on April 9, 2018. Previously, IPR filed on behalf of CCFC and CDD Requests to Investigate YouTube’s promotion of unfair and deceptive influencer marketing to children (October 21, 2016) and unfair and deceptive marketing practices on YouTube Kids (April 7, and November 24, 2015). As you are aware, YouTube has profited enormously by hosting channels and videos of nursery rhymes, unboxing videos, popular cartoons, and other content specifically designed for children on the main YouTube platform. But instead of getting the verifiable parental consent required before collecting children’s personal information, Google claims that YouTube is not for children under thirteen, and therefore, no consent is required. This defense is outlandish given that YouTube is the number one online destination for kids. In short, Google has profited by violating the law and the privacy of tens of millions of children. For this reason, the FTC must sanction Google at a scale commensurate with the company’s unprecedented and unparalleled violations of COPPA. As we pointed out in our Request to Investigate, the maximum civil penalties should be imposed because: Google had actual knowledge of both the large number of child-directed channels on YouTube and the large numbers of children using YouTube. Yet, Google collected personal information from nearly 25 million children in the U.S over a period of years, and used this data to engage in very sophisticated digital marketing techniques. Google’s wrongdoing allowed it to profit in two different ways: Google has not only made a vast amount of money by using children’s personal information as part of its ad networks to target advertising, but has also profited from advertising revenues from ads on its YouTube channels that are watched by children. [April 9, 2018 Request to Investigate at 26-27 (footnotes omitted)]. Moreover, any consent order must mandate meaningful changes to YouTube’s business practices. For example, all child-directed content should be placed on a separate platform where targeted advertising, commercial data collection, links to other sites or content, and autoplay are prohibited. Google must also live up to its Terms of Service – which stipulate YouTube is only for persons thirteen and older – by removing all kids’ content from the main YouTube platform. By ensuring such changes, the Commission will do a tremendous service to America’s families seeking to provide a healthy media environment for their children, while sending a clear message to all online and mobile operators that no one is above the law. Google’s disregard of children’s welfare is demonstrated not only by the evidence in our complaints, but by numerous reports of violent, sexual and other inappropriate content available to children on both YouTube Kids and on the main YouTube platform. Moreover, the company refused to turn off recommendations on videos featuring young children in leotards and bathing suits even after researchers demonstrated YouTube’s algorithm was recommending these videos to pedophiles. These ongoing and serious issues require that the FTC take strong action. We believe that Google should repay America’s families by creating a truly safe space for kids and fostering the production of quality non-commercial children’s programming. Attached you will find a list of recommended penalties and conditions to be included in a final consent order. We would be happy to meet with you to discuss our proposed remedies in greater detail. Thank you. Sincerely, Jeffrey Chester Executive Director Center for Digital Democracy Josh Golin Executive Director Campaign for a Commercial-Free Childhood Angela J. Campbell Director Institute for Public Representation Georgetown Law Encl.: Proposed Consent Order Penalties and Conditions Proposed Consent Order Penalties and Conditions The FTC should seek a 20-year consent decree which includes the following forms of relief: Injunctive relief Destroy all data collected from children under 13, in all forms in Google’s possession, including inferences drawn from this data, custody, or control of YouTube and all of Alphabet’s subsidiaries engaged in online data collection or commercial uses (e.g. advertising), including, but not limited to, Google Ads, Google Marketing Platform and their predecessors. Immediately stop collecting data from any user known to be under age 13, and any user that a reasonable person would likely believe to be under age 13, including, but not limited to, persons that are viewing any channel or video primarily directed to children, persons who have been identified for targeted ads based on being under 13 or any proxy for under 13 (e.g., grade in school, interest in toys, etc.), or any other factors. Identify, as of the date of this consent order, as well as on an ongoing basis, any users under age 13, and prohibit them from accessing content on YouTube. Prohibit users under age 13 from accessing content on YouTube Kids unless and until YouTube has provided detailed notice to parents, obtained parental consent, and complied with all of the other requirements of COPPA and this consent order. Remove all channels in the Parenting and Family lineup, as well as any other YouTube channels and videos directed at children, from YouTube. YouTube may make such channels and videos available on a platform specifically intended for children (e.g. YouTube Kids) only after qualified human reviewers have reviewed the content and determined that the programming comply with all of the policies for YouTube’s child-directed platform, which must include, but are not limited to: No data collection for commercial purposes. Any data collected for “internal purposes” must be clearly identified as to what is being collected, for what purpose, and who has access to the data. It may not be sold to any third parties. No links out to other sites or online services. No recommendations or autoplay. No targeted marketing. No product or brand integration, including influencer marketing. Consumer education Require Google to fund independent organizations to undertake educational campaigns to help children and parents understand the true nature of Google’s data-driven digital marketing systems and its potential impacts on children’s wellbeing and privacy. Require Google to publicly admit (in advertising and in other ways) that it has violated the law and warn parents that no one under 13 should use YouTube. Record keeping and monitoring provisions Google must submit to an annual audit by a qualified, independent auditor to ensure that Google is complying with all aspects of the consent decree. The auditor must submit their report to the FTC. The FTC shall provide reports to Congress about the findings. All of the annual audits must be publicly available without redaction on the Commission’s website within 30 days of receipt. Google may not launch any new child-directed service until the new service has been reviewed and approved by an independent panel of experts – including child development and privacy experts – to be appointed by the FTC. Google must retain, and make available to the FTC on request, documentation of its compliance with the consent decree. Civil penalties and other monetary relief Google will pay the maximum possible civil penalties – $42,530 per violation. Whether violations are counted per child or per day, the total amount of the penalty must be sufficiently high to deter Google and YouTube from any further violations of COPPA. Google to establish a $100 million fund to be used to support the production of noncommercial, high-quality, and diverse content for children. Decisions about who receives this money must be insulated from influence by Google. In addition, we ask the FTC to consider using its authority under Section 13(b) of the FTC Act to require Google and YouTube to disgorge ill-gotten gains, and to impose separate civil penalties on the management personnel at Google and YouTube who knowingly allowed these COPPA violations to occur.

All Complaints (link is external) filed by Institute for Public Representation on behalf of Campaign for a Commercial-Free Childhood, the Center for Digital Democracy, and others

In response to a call (link is external) for submissions by the UN Committee on the Right of the Child (link is external) on the topic of children’s rights in relation to the digital environment, CDD joins academics and advocates in submitting comments. The group calls on the Committee to recognize the far-reaching harms caused by digital marketing and the personal data extraction on which it is predicated. Many digital marketing practices infringe many rights enshrined in the UN Convention on the Rights of the Child (link is external). The Committee ought to recognize the need to protect children from these harms so children can fully enjoy the opportunities digital environments offer for their development and fulfilment of their rights.

Contact: Josh Golin, CCFC: josh@commercialfreechildhood.org (link sends e-mail); (617) 896-9369 Jeff Chester, CDD: jeff@democraticmedia.org (link sends e-mail); (202) 494-7100 Advocates Demand FTC Investigation of Echo Dot Kids Edition Amazon violates COPPA in many ways, including keeping data that parents believe they deleted BOSTON, MA — May 9, 2019 — Today, a coalition of 19 consumer and public health advocates led by the Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) called on the Federal Trade Commission (FTC) (link is external) to investigate and sanction Amazon for infringing on children’s privacy through its Amazon Echo Dot Kids Edition. An investigation by CCFC and the Institute for Public Representation (IPR) at Georgetown Law revealed that Echo Dot Kids, a candy-colored version of Amazon’s home assistant with Alexa voice technology, violates the Children’s Online Privacy Protection Act (COPPA) in many ways. Amazon collects sensitive personal information from kids, including their voice recordings and data gleaned from kids’ viewing, reading, listening, and purchasing habits, and retains it indefinitely. Most shockingly, Amazon retains children’s data even after parents believe they have deleted it. CCFC and IPR have produced a video (link is external) demonstrating how Amazon ignores the request to delete or “forget” a child’s information it has remembered. The advocates’ FTC complaint also say Amazon offers parents a maze of multiple privacy policies, which violate COPPA because they are confusing, misleading and even contradictory. “Amazon markets Echo Dot Kids as a device to educate and entertain kids, but the real purpose is to amass a treasure trove of sensitive data that it refuses to relinquish even when directed to by parents,” said Josh Golin, CCFC’s Executive Director. “COPPA makes clear that parents are the ones with the final say about what happens to their children’s data, not Jeff Bezos. The FTC must hold Amazon accountable for blatantly violating children’s privacy law and putting kids at risk.” Amazon Echo Dot Kids Edition comes with a one-year subscription to FreeTime Unlimited, which connects children with entertainment like movies, music, audiobooks, and video games. The always-on listening device is often placed in the child’s bedroom, and kids are encouraged to interact with it as if Alexa was a close friend. Kids can download “skills,” similar to apps, to add functionality. In clear violation of COPPA, Amazon disavows responsibility for the data collection practices of Alexa skills for kids and tells parents to check the skill developers’ privacy policies. To make matters worse, 85% of skills for kids have no privacy policy posted. Amazon does not verify that the person consenting to data collection is an adult, let alone the child’s parent. The advocates also say the Echo Dot has a “playdate problem”: a child whose parents have not consented will have their conversations recorded and sensitive information retained when visiting a friend who owns the device. “We spent months analyzing the Echo Dot Kids and the device’s myriad privacy policies and we still don’t have a clear picture of what data is collected by Amazon and who has access to it,” said Angela Campbell, a CCFC Board Member and Director of IPR’s Communications and Technology Clinic at Georgetown Law, which researched and drafted the complaint. “If privacy experts can’t make heads or tails of Amazon’s privacy policy labyrinth, how can a parent meaningfully consent to the collection of their children’s data?” “By providing misleading tools that don’t actually allow parents to delete their children’s data, Amazon has made a farce of parents’ difficult task of protecting their children’s privacy,” said Lindsey Barrett, Staff Attorney and Teaching Fellow at IPR. “COPPA requires companies to allow parents to delete their children’s personal information, and Amazon is breaking the law— not to mention breaking parents’ trust.” “It’s shameful that Amazon is ensnaring children and their valuable data in its race to market dominance,” said Jeff Chester of CDD. "COPPA was enacted to empower parents to have control over their children’s data, but at every turn Echo Dot Kids thwarts parents who want to limit what Amazon knows about their child. The FTC must hold Amazon accountable to make clear that voice-activated, always-on devices must respect children’s privacy." Organizations which signed today’s complaint were the Campaign for a Commercial-Free Childhood, Center for Digital Democracy, Berkeley Media Studies Group, Color of Change, Consumer Action, Consumer Federation of America, Defending the Early Years, Electronic Privacy Information Center, New Dream, Open MIC (Open Media and Information Companies Initiative), Parents Across America, Parent Coalition for Student Privacy, Parents Television Council, Peace Educators Allied for Children Everywhere (P.E.A.C.E.), Public Citizen, Raffi Foundation for Child Honouring, Story of Stuff, TRUCE (Teachers Resisting Unhealthy Childhood Entertainment), and U.S. PIRG. In May 2018, CCFC and CDD issued a warning (link is external), supported by experts like Drs. Sherry Turkle, Jenny Radesky, and Dipesh Navsaria, that parents should steer clear of Echo Dot Kids. The advocates cautioned that Echo Dot endangers children’s privacy, and by encouraging young children to spend more time with and form “faux relationships” with digital devices, it threatens their healthy development. Added Josh Golin: “Echo Dot Kids interferes with children’s healthy development and relationships and threatens their privacy. Parents should resist Amazon’s efforts to indoctrinate children into a culture of surveillance, and say ‘no’ to Echo Dot Kids.” The investigation by CCFC and IPR was made possible by a generous grant from the Rose Foundation for Communities and the Environment (link is external).