The FTC introduced a novel ban on offering an online service to children and teens under 18 years old when it announced its settlement with California-based app developer NGL Labs and two of its co‑founders. NGL, short for “not gonna lie,” is an app that enables its users to receive anonymous messages. The settlement showcases the FTC’s willingness to use the Children’s Online Privacy Protection Act and other federal laws to protect teens as well as younger children. This two-part series on the significant aspects of the case featured insights from Covington, Hunton Andrews Kurth, Orrick, ZwillGen and Alston & Bird. The first article examined the key violations and settlement terms as well as what the resolution signals about the FTC’s children’s privacy enforcement. Part two covered the FTC’s application of the substantial injury standard, enforcement coordination trends and compliance lessons.