i-SAFE, Inc. Application for Safe Harbor
As a law student concerned with online privacy, I am responding to the Federal Trade Commission's Notice Announcing Submission of Proposed "Safe Harbor" Guidelines and Requesting Public Comment on the application of i-SAFE, Inc. ("i-SAFE"), 75 Fed. Reg. 1734 (Jan. 13, 2010). The FTC will approve self-regulatory guidelines only if they "provide the same or greater protections for children as those contained in §§ 312.2 through 312.9" of the FTC's Children's Online Privacy Protection Rule ("COPPR"). 16 C.F.R. § 312.10(b). I would like to direct the FTC's attention to two ways in which i-SAFE's proposed guidelines, as written, fail to provide the required level of protection. My complete comments on this matter are attached.