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ARTICLE · 12 JANUARY 2016

App Developers Pay $360,000 To Settle COPPA Charges

Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
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Frankfurt Kurnit Klein & Selz PC

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Two app developers recently paid a total of $360,000 to settle charges by the Federal Trade Commission ("FTC") that they violated the Children's Online Privacy Protection Act ("COPPA") Rule.

United StatesPrivacy
S. Gregory Boyd
S. Gregory Boyd
Jeremy Goldman
Jeremy Goldman
Rayna Lopyan
Rayna Lopyan
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Two app developers recently paid a total of $360,000 to settle charges by the Federal Trade Commission ("FTC") that they violated the Children's Online Privacy Protection Act ("COPPA") Rule. The cases make clear that children's privacy online remains an FTC focus. Here's what happened.

The FTC alleged that LAI Systems, LLC and Retro Dreamer had created apps directed to children, including My Pizza Shop, Marley the Talking Dog, and Ice Cream Jump, among others, and allowed third-party advertisers to collect personal information in the form of persistent identifiers. Persistent identifiers are pieces of data tied to a particular user or device. The COPPA Rule expressly includes persistent identifiers in the definition of "personal information." Contrary to COPPA guidance, the companies allowed their advertisers to collect persistent identifiers without providing notice to or getting verifiable consent from the parents for collecting and using the information to serve

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