In December, Attorneys General from 24 states and the District of Columbia submitted detailed comments to the Federal Trade Commission on proposed revisions to the rules implementing the federal Children’s Online Privacy Protection Act (COPPA).  These comments were significant for multiple reasons.

The obvious reason is that State Attorneys General have concurrent enforcement authority for COPPA.  The COPPA statute delegates to the FTC an unusual amount of administrative discretion in establishing standards and requirements.  Therefore, the bi-partisan comments of 25 enforcement authorities on perceived shortcomings in the current COPPA rule will likely be carefully considered by the FTC.
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