RE: COPPA Rule Review, Project No. P195404
Dear Secretary Christie:
The Entertainment Software Association (“ESA”)1 and its members strongly support COPPA’s goals of “enhancing parental involvement in a child’s online activities in order to protect the privacy of children” while also “preserving the interactivity of children’s experience on the Internet” and “children’s access to information in this rich and valuable medium.”2 The video game industry has made and continues to make significant investments in developing innovative solutions to promote privacy, safety, and parental involvement in children’s online video game experiences.
ESA and its members urge the FTC to approach the COPPA rulemaking with an eye towards the existing state of technology, the limitations of the statute, and the perspectives of operators seeking to provide valuable experiences to children online. The FTC should ensure that any changes to the Rule improve the online experience for children and their parents while providing clear, administrable standards for operators that are consistent with previous FTC guidance. While the landscape of children’s online experiences continues to evolve, the FTC must respect the limits of its statutory rulemaking authority.
