ARTICLE · 03 DECEMBER 2013

New Jersey AG Continues Privacy Enforcement Efforts

Reed Smith

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On November 13, 2013, California-based mobile app developer, Dokogeo, Inc., entered into a consent order with the New Jersey Attorney General to settle charges of violations of the Children's Online Privacy Protection Act ("COPPA") and New Jersey's Consumer Fraud Act.

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On November 13, 2013, California-based mobile app developer, Dokogeo, Inc., entered into a consent order with the New Jersey Attorney General to settle charges of violations of the Children's Online Privacy Protection Act ("COPPA") and New Jersey's Consumer Fraud Act. The settlement, which was announced on November 22, is the second one entered into between an app developer and the NJ AG over alleged COPPA violations. For our analysis on the previous settlement, please visit here.

According to the consent order, Dokogeo offers a geolocation scavenger hunt app for users to visit new locations and gather photos and notes from people they meet. Users have the option to create a profile, which includes an email address. The NJ AG alleged that the Dokogeo app was directed to children, although the only allegation made was that there was animation on the site. While the presence of animated characters on a site is a factor that the FTC Rule now includes for determining

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