The FTC’s COPPA Conundrum: Ambiguities in the Rule and a Death of Authoritative Guidance Leave the Agency Vulnerable to Legal Challenges

This article was originally published by the ABA’s ANTITRUST magazine in its Summer 2022 issue.

The Children’s Online Privacy Protection Act (COPPA) and the Federal Trade Commission’s COPPA-enforcing rule have increasing relevance for all businesses that interact directly with consumers online—including companies that do not regard themselves as marketing directly to children. Both the FTC and state Attorneys General are active in enforcing COPPA, and companies can often be caught off guard by government inquiries scrutinizing their compliance. (more…)

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Sean Royall

Dallas, Washington, D.C.

sroyall@sidley.com