16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503 #561789-00057 

Submission Number:
561789-00057 
Commenter:
Ahmed Siddiqui
State:
California
Initiative Name:
16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503

My name is Ahmed Siddiqui and I am the developer behind Go Go Mongo, the set of apps featuring a chubby little monster that inspires kids to eat healthy things.Prior to becoming a developer, I was a business manager at a large technology firm but always wanted to start my own business. When my cousin was learning English, I had an idea for an app to help her learn some new words. When Go Go Mongo was launched I was thinking my app would teach kids English but, shortly after launch, I started receiving emails from parents praising the app for inspiring their kids to ask for thinks like cauliflower and broccoli. A healthy eating app was born. I’ve always wanted to be an entrepreneur and found the app economy a great place to launch a business. The constant experimenting, evolving business models, and the ability to quickly bring a product to market is a thrilling way to work. I hope, on behalf of myself and other aspiring entrepreneurs, the FTC takes steps to ensure this industry’s ability to change and grow for many years to come. One of the first steps the FTC can take is to offer developers clear and concise rules. When starting out, I did not have the ability or capital to hire an expensive COPPA expert. The vast majorities of entrepreneurial app developers take risks when starting out including forgoing a consistent salary, leaving behind six figure incomes, and putting a strain on their financial future. While the rewards are often great, risks still remain. I worry about the projected cost of this latest proposed rule to be nearly $10,000 for each operator. I doubt I would have gotten past the concept stage for Go Go Mongo. I’d also encourage the FTC to acknowledge the importance of the third parties to small business app developers. Many developers choose to use third parties to do the tasks because they do not have the capacity to do things on their own. Some developers use this for things like optimizing apps for other devices or receiving anonymous crash reports. However, the most obvious example of this is the stores where I sell my apps. If, because of this rule, they decide to disallow apps for kids on their platforms, my business will cease to exist. I am completely behind the FTC’s goal of protecting children and offer my continued support to your efforts to protect children and foster the small businesses educating children through technology. Thank you for the opportunity to comment.