Children's Advertising Review Unit of the Council of Better Business Bureaus, Inc.
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
November 10, 2011 Federal Trade Commission Office of the Secretary Room H-113 (Annex W) 600 Pennsylvania Avenue, N.W. Washington, D.C. 20580 RE: Request for Extension for Submission of Comments on COPPA Rule Review,16 CFR Part 312, Project No. P-104503. Dear Secretary Clark: The Children’s Advertising Review Unit of the Council of Better Business Bureaus, Inc. (CARU) appreciates this opportunity to comment on the FTC’s COPPA Rule Review,16 CFR Part 312, Project No.P-104503. CARU is the children's arm of the advertising industry's self-regulation program and evaluates child-directed advertising in all media to advance truthfulness, accuracy and consistency with its Self-Regulatory Program for Children's Advertising and relevant laws. CARU also reviews websites for online privacy practices as they affect children including compliance with COPPA and was the first Safe Harbor program to be accepted by the FTC. CARU respectfully requests a 45 day extension within which to submit comments. The proposed changes are lengthy and will have, in some cases, major effects upon the present system. CARU needs additional time to explore and analyze the proposed modifications and their possible impact upon the administration of its self-regulatory program. The requested extension will allow CARU time to digest the proposals and provide a meaningful response. Thank you in advance for your time and consideration of this request. Very truly yours, Wayne J. Keeley Director, Children’s Advertising Review Unit Vice President, CBBB