16 CFR Part 312: Children's Online Privacy Protection Rule Safe Harbor Proposed Self-Regulatory Guidelines; the Entertainment Software Rating Board's COPPA Safe Harbor Program Application to Modify Program Requirements; Project No. P024526 #00004

Submission Number:
00004
Commenter:
James Graves
Organization:
Institute for Public Representation
State:
District of Columbia
Initiative Name:
16 CFR Part 312: Children's Online Privacy Protection Rule Safe Harbor Proposed Self-Regulatory Guidelines; the Entertainment Software Rating Board's COPPA Safe Harbor Program Application to Modify Program Requirements; Project No. P024526
As detailed in the attached document, Campaign for a Commercial-Free Childhood and the Center for Digital Democracy, by their counsel, the Institute for Public Representation, ask the FTC to reject the Entertainment Software Rating Board's ("ESRB's") application to modify its safe-harbor program unless the ESRB amends its proposal.