16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503 #561789-00053 

Submission Number:
561789-00053 
Commenter:
Jane Hoffer
Organization:
BrainRewards, Inc.
State:
Pennsylvania
Initiative Name:
16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503

Thank you for the opportunity to comment on the proposed changes to COPPA. As a parent and a cofounder of an application for families and children, I am concerned that some of these changes would make it harder for entrepreneurial developers to make apps for children. I cofounded Ohanarama in 2009 to make a difference in children's online lives and the lives of their families. My vision for Ohanarama is to strengthen family bonds through the creative use of today's technologies. We work hard to ensure that children and their families are given a safe learning environment. As a mother of three and responsible developer, I recognize and applaud the FTC’s actions to protect children from the dangers of the Internet. However, technology is a great tool to educate children and bring families together. I want to be sure, going forward, that developers are able to continue to make and market their own apps. The problem with the proposed changes to COPPA is that it is too broad. In an ideal world, I would turn every idea I have over to an attorney knowledgeable about both mobile apps and COPPA and receive advice on what I can and can’t do. But receiving such advice before even making or publishing a service directed towards kids is cost-prohibitive. The best thing about being an app developer is the low barrier to entry, which means that parents and small business are able to create apps based on ideas gathered from their own families. By adding legal and monetary barriers, COPPA could drive many great current and future developers away from the kid’s app industry. I understand and support the FTC’s goal to protect children, as it is the same goal I have in creating a safe learning environment in my apps. But if I am faced with potential liability under unclear federal regulations and I no longer have the support of third parties, I and other responsible developers like me will think twice before innovating our existing apps or creating new ones. In the end, these vague regulations will hurt app developers and children alike. It would be a shame that regulations aimed at protecting children could end up stifling the educational app industry.