2010 Children's Online Privacy Protection Act Rule Review #547597-00065 

Submission Number:
Kevin Brook
Initiative Name:
2010 Children's Online Privacy Protection Act Rule Review
I call upon the FTC to reject the suggestion of Common Sense Media and the Electronic Privacy Information Center to extend COPPA's coverage to people between the ages of 13 and 17. Today's teenagers actively participate in message boards, blogs, email, video games, instant messaging, social networking sites, and much more. Expanded COPPA regulations might lock them out of some forms of participation, or cause some of them to falsify their age. Currently, many 12 year olds pretend to be 13 in order to join Internet services that set a minimum age of 13 to avoid having to comply with COPPA's parental consent rule. 13-17 year olds are perfectly capable of constructively engaging in online discussions and activities without parental consent. According to current psychological and scientific research, some of which is discussed in Dr. Robert Epstein's books "The Case Against Adolescence: Reversing the Artificial Extension of Childhood, Rediscovering the Adult in Every Teen" and "Teen 2.0: Saving Our Children and Families from the Torment of Adolescence", in many ways teenagers are mentally more like adults than children under 11 or 12. It is therefore appropriate for 13-17 year olds to be treated like adults when it comes to Internet privacy, Internet advertising, and Internet access. This is particularly true of 17 year olds, many of whom have already graduated from high school and begun their university educations away from home. I personally began using services on computer networks (such as FidoNet and CompuServe) at the age of 14 and found them to be valuable learning tools as well as ways to meet new people and exchange ideas with them. Young people were allowed, and sometimes encouraged, to contribute writings and artwork, to chat with people, and to play computerized games on these precursors to the World Wide Web. On many of the pioneering services there were no age restrictions and no requests for parental consent although some limited young people's access to sexual material. I am sure that most of the teenagers who used these services turned out just fine. The accelerating infantilization of teenagers in today's America runs contrary to the legal and social framework in past centuries that treated teenagers as young adults rather than as children. In historical times, Americans in their early to mid teen years were granted more rights as well as responsibilities than is common today. Many graduated from school earlier, had meaningful or well-paying apprenticeships or jobs, became entrepreneurs, spent long periods of time unsupervised by their parents, and even got married. Walling off teenagers from full participation on the Internet by means of a government mandate that would encourage companies to raise their minimum sign-up ages from 13 to 18 will not be helpful for the development of future generations of Americans. Without meaningfully interacting with adults in any setting, online or offline, many of these teenagers would be socially and intellectually stunted by the time they turned 18. They would also feel frustrated at not being able to express their thoughts online - a basic right of all Americans - or even being able to register a free email account to communicate with relatives and friends from school. Instead of adopting the ideas of Common Sense Media, I would instead urge serious consideration of the ideas expressed and filed by members of the Progress and Freedom Foundation, the Electronic Frontier Foundation, the Center for Democracy and Technology, and the Berkman Center for Internet & Society at Harvard University.