16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00006 

Submission Number:
00006 
Commenter:
Mark Williams
State:
Outside the United States
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503

I agree wholeheartedly with the principle of this move but I must strongly object to the open-ended nature of the wording and by extension, the efficacy of this strategy as a whole. In terms of a 'measure' or 'procedure', I'd like to know: 1. what is 'reasonable' and 2. by whom is it to be defined? 4 examples from paragraphs 4 & 6 of the original article: 1. take reasonable measures 2. reasonable procedures to protect 3. as is reasonably necessary 4. taking reasonable measures Whom does this protect? it looks, to me, very much like a legal argument which will be paid for by the hour, after the fact. Why can everybody not be reading from the same page? Surely a clear distinction between what is legal and what is not is a necessity here? Regards, Mark Williams