16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503 #561789-00061 

Submission Number:
561789-00061 
Commenter:
Karen Robertson
Organization:
Treasure Bound Books Pty Ltd
State:
Texas
Initiative Name:
16 CFR Part 312, Children’s Online Privacy Protection Rule, Supplemental Notice of Proposed Rulemaking, Project No. P104503

My name is Karen Robertson and I'm the author and creator of an award winning book app for kids and I teach other writers and illustrators how to turn their books into book apps. I started writing in 2007 to create a new kind of interactive book to motivate my dyslexic sons to read. In 2010, one picked up the iPad for the first time and chose book apps over games so I knew I had to turn my book into a book app. Not only does the book app format engages kids with reading a new way, it also gives independent writers access to a global market in an affordable way. I foresee the app marketplace as a valuable place for parents and teachers to go and experiment with new learning tools for their kids. When I saw that it may cost upwards of $10,000 to comply with the proposed COPPA rules, I was shocked. Why would a federal rule effectively shut out the new small businesses that may not have the same level of funding as the large players in the industry? I fear for the industry and for the kids finding learning successes through apps. What if the only apps to come out were based on major cartoon characters that did not necessarily have an educational bend to them? This is not the way I want kids apps to go. I chose not to include third-party tools like analytics in my apps. This was partly due to uncertainty with COPPA. I can see the benefits analytics could have for the internal purposes of my apps. Things like crash reports and anonymous reports on what features people are using within the apps are important when improving the educational nature of Treasure Kai and Zak the Yak. A little more clarity in the rules would be hugely beneficial to my small business. Thank you very much for your time.