December 10, 2019
By Electronic Filing
Ms. April Tabor
Federal Trade Commission
Office of the Secretary, Room H-113 (Annex E) 600 Pennsylvania Avenue, NW
Washington, DC 20580
RE: COPPA Rule Review, 16 CFR part 312, Project No. P195404
Dear Secretary Tabor:
The Entertainment Software Association (“ESA”) files these comments to explain
whether and how evolving technology and business practices should affect the Commission’s enforcement of the Children’s Online Privacy Protection Act (“COPPA”) and its administration of the accompanying COPPA Rule.
