16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503 #561789-00059 

Submission Number:
561789-00059 
Commenter:
Dave Noderer
Organization:
Computer Ways, Inc.
State:
Florida
Initiative Name:
16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503

My name is Dave Noderer and I've been developing custom applications for eighteen years. Custom application and technologies have changed a lot over the past 18 years and I can honestly say there's never been a more exciting time to be a developer. There is a lot going on in the South Florida software developer community and I am very happy to be deeply involved. It's revitalizing the technology industry as well as the business community. Last October, I helped organize South Florida's participation in National GiveCamp. This was a weekend-long event where technology professionals donate their time to provide solutions for non-profit organizations. I was also a sensei at the AT&T Mobile App Hackathon in Miami this past August and I organize and host a free Code Camp each February with over 700 attendees. These events were completely full and there is an excitement for coding I haven't seen in a long time. People choose to spend their weekends with other geeks to make mobile apps! I read the Ars Technica letter about the proposed COPPA law and am very concerned the impact this rule could have on the industry at large. We create innovative tools for consumers. At GiveCamp, we made an app for our local Big Brothers, Big Sisters chapter that helps bigs find local activities to do with their littles. While we made this app for a non-profit and they are exempt from COPPA compliance, I worry about the impact the third party "reason-to-know" standard could have on our industry. These third-party services provide crucial resources to developer that may not have the expertise to make their own crash reporting system or mapping system. It seems as if this COPPA rule may encourage some or all of these third party providers to completely stop servicing kids apps. Not only would entrepreneurs creating a kids app at a hackathon have a disadvantage, the entire kids app ecosystem would be at a disadvantage. I'd hate to see such a vibrant industry be shut out of the marketplace. I encourage the South Florida community to be engaged and active citizens. I've worked to make people aware of COPPA and warned them to keep an eye out for possible changes in the future. I want someone to be able to start a business if they have a good idea that will contribute to the community. I don't want them to decide to not start that business because of a law that, at its core, is meant to keep kids safe. Discouragement is not how we improve our economy. Creating low barriers to entry and creating easy, common sense rules to follow will improve our economy.