To: FTC: Office of the Secretary

Date: Friday June 11, 1999

Subject: Comments about the proposed rule designed to protect the privacy

of children who surf the Internet

FROM: Jorian Clarke, President Circle 1 Network, publisher of KidsCom.com

http://www.KidsCom.com

The last three years have seen much work on the part of the FTC and others

all sharing the common goal of providing the best and safest Internet experience for our nation's children. In our experiences with the FTC we have been impressed by the dedication of the people involved in understanding the complexity of the issues and their diligent work in finding solutions to the issues surrounding the protection of children's privacy online. It is key to find balance between protecting privacy and not limiting access to sites providing content for children and their families.

We agree thoroughly with the need to bring parent involvement into their children's online experience and we have pioneered and continue to explore how best to reach this goal. Early on we moved beyond theories into actual practices to address online concerns. We provide monitoring of all user-posted content areas of our site. We inform parents of a child's registration. We use many different avenues to continually encourage parents to get involved. And we require snail mailed or faxed parental permission for a child's inclusion in our online pen pal program. We also continue to do research with families (parents and children) to better understand the issues and how to solve them. We were among the first to provide a privacy policy online and two child-recognizable help seals: one for the distinction between advertising and editorial content, the second to indicate the safe collection of personally identifiable information. Without listing them all here, we have taken many more steps to promote online safety and privacy and responsible advertising to children.

As a company with a Web site that began in 1995, we also represent the pioneers who saw the potential of the Internet. We are small-business entrepreneurs; independent publishers of educational and entertaining content. We hope that presence is not a part of the Internet that will be forced into extinction.

One of the challenges of the Internet is that it moves at such blinding speed. It encourages leaps of logic and demands fast-paced action even before that action has been thoroughly examined and tested. While this issue of online

Comments from Jorian Clarke/Circle 1 Network continued:

privacy demands action, we believe there are two aspects that have not yet received enough attention: 1. making parental consent verifiable and alternatives to when parental consent is unattainable. 2. determining the impact of these costs on small businesses that provide enriching online experiences for children.

Do not misunderstand what we are saying; we believe strongly that the protection of children's online privacy is vital, and our site attests to our commitment to this goal. We thoroughly understand that strong privacy protection measures are essential for a children’s site. This is important not only for children but for their parents as well. However, before this proposed rule goes into effect, we respectfully request additional discussion and review of alternatives and consideration of the short-term impact on publishers who provide children's content on the Internet and the long-term impact it will make on users of the Internet.

Thank you for the opportunity to respond and for your continued efforts on the behalf of progress on this important issue.

Respectfully submitted,

Jorian Clarke
President, Circle 1 Network
Publisher of KidsCom.com