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Hello. Thank you for permitting me to briefly comment on the COPPA review. I will simply bulletize my comments: *Age Application: The age of the definition of a "Child" should be raised to "Under 16" *Parental Consent: It is just that. Parents or Legal Guardians of children should and always be the only source of valid consent. In the field of technology or specifically educational technology, final consent relating to the use or application of said technology, if it involves the collection and use of personal information must remain in the parental domain. *Voice Recordings: I recommend voice recordings that request/acquire a child's personal information, also conform with appropriate parental consent parameters. With the continual growth of digital technology, the "source" or "collection" of data comes in many ways now... computer keyboard entry, touch-tone phone entry, smartphone apps, voice recordings, biometrics, etc. The protection of our children must always be the first priority. *General Audience Websites: A very large "gray" area exists in the marketing/target audience of websites. Clearly, some organizations specifically target children as the consumer. However, what about situations where "general audience" websites target adults and children? Example: movie ticket sales. They would be marketing to adults, teens, and children. This is a situation I believe COPPA should apply. That is a somewhat clear example. But what about an organization that markets lamps or lighting fixtures? They might sell lamps for living rooms, dining rooms, and bedrooms. Perhaps some child themed lamps or lighting. I think this is a situation where a "reasonableness" test must be adopted. Where, under the circumstances, it could be "reasonably" conceived that a business or organization is undertaking an affirmative, conscious effort to market, gather or process a child's personal information. In the latter example, I would likely say it is not, if they are engaging in general, home sales where the conscious effort is to market to adults. *"Personal Information": The definition should be expanded to include genetic data, fingerprints, retinal patterns, or other biometric data, or information that is inferred, but not collected directly from, children. Regards,Leonard R. Rivera, Esq.

FTC Rule, could affect the websites or online services directed to children, this is positive as the young generation is of more importance to us. Further it helps the parents to have assurance on the content and products their children are browsing or purchasing on line. in the long run producing a better society!

FTC should include, the websites that is without child oriented activities but is largely visited by high number of child users, once identified.

Check fraud help please smashhitz

Good Rule Thanks

As a parent, it's very sad to see a law intended to protect children doing the complete opposite. This will only lead to "kid friendly" YouTube channels shifting to an older age while the audience will remain the same. My children will now be subject to adult content because kid friendly content will be drastically diminished. In addition, threatening the average content creator with a $42,000 fine per video is absolutely insane. Many content creators have hundreds or even thousands of videos. YouTube has been forcing creators to become kid friendly over the last 5 years and now you are going to fine the creators life changing amounts of money because they did what they were told. People will lose their homes, cars, and livelihoods, all because they make content that parents WANT their kids to watch. This NEEDS to be changed.

Please stop about this COPPA, I love YouTube and channel all people who love a YouTube, and other's really work hard on upload to channel, but i'll never forgive u, I understand about made a kids, and also kids are favor YouTube Channel such love other's Gaming, teach them a Cooking, Making up, News, Music, Movies, Sports, And Who favor Channel YouTube, And now we'll YouTube Rewind 2019-2020 PEOPLE WHO LOVE YOUTBE CHANNEL IN THE WORLDS

On the surface this law seems like a "no-brainer" but I am extremely concerned with how this is being executed. By penalizing the individual content creators making kid friendly content online we run the risk of creators either shifting their content to a more mature nature or ceasing to create content at all. Kids however will not stop watching online content. Less kid friendly channels with the same audience will undoubtedly lead to kids watching more mature content. Please consider revising this law because its current state is leading down a dark path that is putting children in danger.

This is more harm than good do not go through with the law. As it is way too vague BE MORE SPECIFIC

This is a poorly designed idea made by people who do not fully understand the internet. In order to do this right, one will have to fully understand the situation. This is not understanding the situation.

On the surface this looks like a great law, but as a parent of three, I fear this will cause much more harm than good for my girls. By penalizing content creators for making kid friendly content on websites like YouTube you will be effectively removing kid friendly videos on the platform. What you won't be removing is the large presence of children on the internet. So my kids won't be getting personalized ads, but instead they will be watching mature content because all of the child friendly creators have been thrown out of a job. I am also not concerned about targeted ads. At least I know they will be ads appropriate for my kids as opposed to the thousands of alcohol and condom commercials I notice on the internet. Please revise this law because I am fearful for the path this is taking currently.

Fantastic

What is going on is COPPA going to ruin youtube on January 2020???

I believe that content creators on youtube should not be held liable for YouTube and Google’s actions, and thus should not be fined for making content that appeals to people of all ages such as games, cartoons, and animals

I protest these changes that put to penalty on the content creator. The content creator did not break the regulation. YouTube violated the regulation not the content creator.

To be honest just by the way things have went for me these past 14 months.I think its the parents at fault for whatever it may be with COPPA rule to where the children are being used as a scape goat so they can try to get away with wrong doings on there part!

I am a YouTube creator. My videos while historical in nature are regularly viewed by people of all ages. This new rule will do nothing to protect children. It only hurts content creators and makes it more likely that content will be unlawfully censored. I ask you not to enact theses new rules.

Dear FTC members, I am a content creator (A.K.A. YouTuber). I would urge you to rethink the current rules and how vague they are. Just because a percentage of the children watching a genre are children doesn't mean you have an obligation to remove all forms of personalization. Watching this content, I would prefer targeted ads that show my actual interests rather than random car or horror film ads. Leave the parenting to parents who make the decision to give their child access to YouTube. If this decision goes through, family-friendly content on YouTube will suffer and families will suffer for it. Content creators do their best to create great content and threatening legal action against individuals over the opinion of "child appealing" is excessive. Please don't ruin one of the most important websites on the internet to me.

I'm having trouble accessing the COPPA public comment page. Is it only viewable in the US or is the site down?

Children definitely need to be protected but the way this is going about is not the way. Creators who are animation or gaming focused usually and mostly aren't directed to kids, despite what you might believe. For most of these channels they aren't made for kids and just do what they love. Gaming may seem only something under 13 would like to watch but in reality it's not under 13 who is supposed to watch. With new laws in place any one deemed 'kid friendly' can be fined which is very unfair. New creators will not come to the platform because not only will no one see their content but they can't afford to pay if their video gets flagged. No one can. Any child friendly content will change or move to another platform because they won't be able to live off what the get paid. Channels will be forced to change their videos. Soon all that's left will be videos that only above certain ages will be able to watch as anything suitable will be made elsewhere. You must be over 13 to watch or made anything but I understand that people put down fake ages. It's generally the parents who should be in charge of that. People who violate the terms shouldn't mean that creators get punished.

i myself am self am a fellow youtuber i am very concerned because even tho i am very small i do not wan to get sued 42k for each video as i do not know what is considered kids content or not kids content please help P.S. i have watched the video published by youtube it still does not help

Hello FTC/COPPA I'm regarded to about You tubers you shouldn't punish a category just because you thinks it's for kids because technically it's not it's for everyone to watch You tube is a place for everyone to be them selves without You tube Viewers/Content creators would be stressed out everyday when coming back from a stressful day from work / school so if you're going to punish somebody Google for it not us because we didn't do anything wrong but you can add a ''KIDS MODE" what this will do is its kind of like restricted mode but protects by make their a password to log them out of kids mode.

Though the rule is intended to protect children I believe it will also be used in more nefarious ways to crush content creators on many platforms. The interpretation of this law seems to be so broad that it serves to stamp out creators & push them further away to other platforms that could be susceptible to having as many protections. Youtube in particular seems to be a platform that is inherently designed to have as much creativity as possible but should the creators on this site be forced to bear the burden of their mistakes I'm afraid this will push not only creators to find a different model for their businesses but intended uses of a site like youtube will leave it vulnerable to only having one type of content and thus further pushing potential bad actors to exploit it even further. No one wants to see children be exposed to harmful material, but punishing creators who clearly do not have bad intentions on their channels will push this medium & this platform to be further exploited. No one goes to CBS, ABC, or FOX for Saturday morning cartoon anymore...they go online, and if you take out all the good actors on a given platform only the bad ones will remain to try to further pervert our system even further. Listen to creators...they are the first line of defense.

Dear FTC, As someone who grew up with youtube and now an adult, I would say that this law has major flaws that can uproot the economy and possibly destroy our country. First, the $42,000 fine would drive hundreds even millions of people who upload content or already uploaded content to the streets or even in prison, due to this the kid-friendly grey area. Sure this may stop the small percentage manipulators but for those who create mature-rated animation, casual commentators who bring up topical issues, side hobbyists who play games or make animation and appeal to the fellowship of the adult working-class, voiceover artists who publish their reels to garner a reputation for acting companies, educational/historic content that students young and old require, Both brand and indie companies of every known field that use youtube to post information about upcoming projects, studies, events the list is infinite. As for the parents who are concerned, they also lose in this regard as well. Both content creating parents and surprisingly children who are uploading content could get their family fined. Youtube bots are inaccurate in what they can scan as child-friendly content and so uploading anything will become a game of Russian roulette. As stated earlier kids have ways to get around this so the problem lies in the fact that now children will be guaranteed to encounter mature content on the internet thus undermining the concept of this law. Security would be ensured short term however long term could make the youth more violent If this law is not fixed, adjusted, or regulated; in the near future millions might sue, more children will find ways around these laws and more will be corrupted by the 100% mature content, The economy that the newer adults use that is in this grey area will collapse. Sure videos can still be uploaded but the inaccurate bots and ambiguity of COPPA will turn everyone away as one wrong move would impact them for the rest of their financial life, This law will become a threat to our freedom of speech. So I stand here among the populace to ensure that our future country will not collapse.

a few days ago when i logged onto youtube i saw a video about how coppa would be "observing" videos on youtube because the parents of children under the age of 13 where on youtube and all i want to say is that it is the parents fault that they allowed their children on to youtube because they knew the consequences of logging on to a app of website that was not made for their children's age group and not on to a like youtube kids i mean they could choose between youtube or youtube kids they choose youtube non kids so i think that its not the fault of the creator but the parents

Hello to all who read this, either at a federal agency or online. This small paragraph of sorts is in response, as requested, to the new rules to be implemented on the social media platform’YouTube’. Recently, I have heard that there is a option ( as I am using now) to voice my opinion and frankly I believe the wrong decision is being made, as far as I’m aware. I do not believe that restrictions should be made on the platform or the content creators for the following reasons; first, this will not aid anyone financially. As it is my understanding of the matter the creators will have lost targeted advertising for the videos categorized as ‘children’s videos’ and will face a fine if Miscategorised. this will undoubtedly discourage new creators from ever arising, and will severely hurt current creators and definitely remove some from the platform. Along with removing what is many people’s sole source of income, it will also hurt any business that are running targeted ads; as a child I definitely watched videos on topics such as mechanics ( car related) and computer technologies. Does that make it children’s content because a child watched it? I don’t believe so. As a teenager who also is a content creator (granted a lackluster one) i have some people who watch who are very young, (7,8) and they see ads. I also have older people (16,17,18+) who watch, and the content is allowed to be unrestricted and creative. If everyone was restricted to the newer set of rules, then the platform will undoubtedly lose money, lose users, and lose the creators who bring in new users. Now I’m not saying it should be unrestricted, the platform should be actively policed for harmful content. I also believe there is a small solution to this; google should do Something to prevent those without a google account from getting it unless they prove that they are of age Or can prove that there is parental consent. The majority of people on YouTube are here to become enlightened or educated or entertained, and what’s so bad in that? This actually bring me to my second and last point, that there is nothing bad about that. Sure, some videos should be removed for obvious reasons, be it too sexual, offensive, or otherwise damaging mentally or physically to someone. But kids today have access to technology from a very early age, and as I was and many others of my generation, we were taught internet safety. It’s even taught in schools. The older rules were for older times, and I believe they should be re written for the modern age, where children are more technologically connected, and allow people to have their rightful freedoms. -Elijah Farmer COPPA Rule Review, 16 CFR part 312, Project No. P195404

COPPA will harm kids because if there are no kids videos in the recommendations then they will not be able find the kids videos and so they will have to watch adult videos.

I'm all for protecting children from too mature content but this is not the way to go about it. Since there are too many grey areas for example using characters from movies like Frozen too create mature content. That should not be targeted to kids and if this goes through you could recommending really mature content to children. Another thing is you are promoting darker more mature content. Kids will still go on YouTube even though they are not allowed to and they will see the dark, mature content. The fine for labeling every video wrong could people on the streets or in serious debt that could never fully pay. There are better ways to keep children away from that. Here are some examples around that that don't effect the content creators make; you enter password every time you want to use YouTube. This can allow parents to have a password that their child has to ask for to go on and if the parent does not like the content can change the password or not tell them it. Another way is to promote YouTube Kids way more. YouTube Kids has never really been promoted and if you can promote it more and make it appeal to kids they may in fact start using that more. The last thing is to have a rating system that a parent can chose. These are picked by the creator who know what their content is and who should be watching them. Channels like Dollightful who is a doll customizing channel is a PG channel but channels like Shane Dawson and Jeffree Star are PG-13 channels. Parents would be able to set what type of video rating their child sees. For example only seeing just rated G things, just PG-13, or G through PG-13. This would allow parents to keep kids from seeing PG-13 things when they only ant their child to see G through Pg content. But this would also allow teenagers to see PG or G content if they enjoy their channels. When someone wants to change the rating of what they see, they have to enter a password. This will keep children from changing the ratings behind their parents back. I do hope you considerate my and everyone else's options on the matter and make the best decision that everyone can agree on.

According to this section of COPPA all sites fall under COPPA law for each child user even if the site is not “kid directed” 14.  Will the amended COPPA Rule prevent children from lying about their age to register for general audience sites or online services whose terms of service prohibit their participation? No.  COPPA covers operators of general audience websites or online services only where such operators have actual knowledge that a child under age 13 is the person providing personal information.  The Rule does not require operators to ask the age of visitors.  However, an operator of a general audience site or service that chooses to screen its users for age in a neutral fashion may rely on the age information its users enter, even if that age information is not accurate.  In some circumstances, this may mean that children are able to register on a site or service in violation of the operator’s Terms of Service.  If, however, the operator later determines that a particular user is a child under age 13, COPPA’s notice and parental consent requirements will be triggered.   labeling videos as kid directed does not satisfy COPPA This law needs amended before it destroys family friendly content.

I am against this law because it assume that a human life stage is child then adult when in reality this is not true. The sage of life is not that. There is a in between.

Remove coppa! Please

Why?

All ages options are needed. I FULLY support you keeping children online safe but, I think you can make an ‘all ages’ choice thanks!

Hi! I don't think it's a good idea for this law called COPPA becaus a lot of youtubers are losing their hobby ... Somehow they should look for another solution!

Well, hello, I came to express my opinion, deep and strong. Youtube has always been a strong platform, but the COPPA law is ruining it, and content creators are caught running away from this platform. I don't want to leave this platform. An unknown, non-existent person would enact this law. Next year in January. Done, thanks for listening to me :)

I think you should change COPPA. Because let's be honest, kids are gonna go on their parent's account. It's the internet! Things like this is always gonna happen. And everyone is gonna be "not for kids" because they want to get money for YouTube, they want comments, and other stuff. And you know what that child is gonna see? Sex videos, swearing, etc. That's way worse than having that happen without COPPA and all those rules. I'm not trying to be all disrespectful, but this is an awful idea. Instead, you should either; make parents take their children to YouTube Kids, or let kids on YouTube and if they are 13 and under make all bad videos not viewable to them. And to make sure they are children or adults, they need a phone number, or credit card or something only a adult has. I'm super sorry if I was disrespectful. I'm just disappointed that you would ruin YouTube because of a few irresponsible parents. Thank you for the time you took to write this.

Not child relate only adult

Delete COPPA pls