Submission Number: 547597-00042
Received: 6/30/2010 9:44:56 PM
Commenter: Mark Moran
Organization: Dulcinea Media. Imc.
State: New York
Agency: Federal Trade Commission
Initiative: 2010 Children's Online Privacy Protection Act Rule Review
Attachments: No Attachments
I am the founder & CEO of Dulcinea Media, Inc., whose mission is to provide free content and tools that help educators teach students how to use the Internet effectively, efficiently, safely and responsibly. I am also the father of 3 children. I attend educational conferences around the country every month, visit educators and students in schools (both in person and via Skype), and speak at every opportunity with educators about how they have integrated the Internet into their curriculum. In response to Question A.B.2., YES, COPPA imposes significant "costs" on children, and educators. I consistently hear a great deal of frustration from educators that many services they wish to have their students use have established "over 13 only" policies. Faced with the potential of being deemed a site directed at children and thus forced to comply with COPPA, many Websites have decided to simply ban children. Teachers then must choose between not using a useful tool in their classroom, or directing students to lie about their age. Many are seriously concerned that they'll one day be arrested and charged with violating COOPA, even though it applies only to Websites. Over COPPA's ten years, there have been only 15 enforcement actions, and only 3 since October 2006. And the cost of these 15 actions is tens of thousands of frightened educators and millions of students either unable to use services their teachers feel useful, or being directed by their teachers or parents to lie about their age. Children are kept away from services that their teachers would enhance their educational experience to "protect their privacy." In the meantime, on their own, 4% or more of them have engaged in "sexting," and nearly all of them have divulged information about themselves online in a manner previously unimaginable to me and everyone reading this comment. I don't necessarily advocate trashing COPPA entirely, but serious consideration needs to be given to how COPPA can be amended to allow Web publishers to feel comfortable amending their terms of service to permit the use by children under 13.