[28298] in North American Network Operators' Group

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Re: New Federal Law (COPPA)

daemon@ATHENA.MIT.EDU (Robert Cannon)
Mon Apr 24 15:05:07 2000

Message-ID: <384909686.956602753923.JavaMail.root@web142-mc.mail.com>
Date: Mon, 24 Apr 2000 14:59:13 -0400 (EDT)
From: Robert Cannon <rmcannon@mail.com>
To: nanog@merit.edu
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Someone followed up with the following question:

HOW DO YOU DETERMINE WHICH SITES TARGET CHILDREN:

The FTC has stated the following:  "To determine whether a Web site is
directed to children, the FTC will consider several factors, including the
subject matter; visual or audio content; the age of models on the site;
language; whether advertising on the Web site is directed to children;
information regarding the age of the actual or intended audience; and
whether a site uses animated characters or other child-oriented features. "=
=20
See COPPA Sec 1302(10); 16 CFR =A7 312.2 (Definitions),

If the FTC could make it up as they go along, they would be vulnerable to a=
n
attack that their rules are arbitrary and capricious, a violation of the
Administratove Procedures Act.  As enforcement proceedings take place, the
description above will be further amplified.

-B
www.cybertelecom.org

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