Takeaways From 2018 COPPA Developments and a Forward-Thinking Approach to Compliance

Websites, apps, toys that merge with the physical world and video-sharing sites continue to draw intense scrutiny from the FTC and state Attorneys General under the Children’s Online Privacy Protection Act (COPPA), one of the most aggressively enforced laws in the United States. If 2018 and the recent Musical.ly settlement are any indication, COPPA enforcement is likely to continue unabated in 2019. In this guest article, Goodwin attorneys Karen L. Neuman and Eric DiIulio survey significant 2018 COPPA developments, highlight key takeaways from these actions and offer insight on compliance with this law. In a subsequent issue, the Cybersecurity Law Report will cover the implications of the FTC’s recent $5.7-million settlement with Musical.ly. See also Lessons and Trends From FTC’s 2017 Privacy and Data Security Update: Enforcement Actions (Part One of Two)” (Jan. 31, 2018); Part Two (Feb. 14, 2018); and “Focus on Children’s Privacy by FTC and Plaintiffs Calls for Prioritizing COPPA” (Sep. 13, 2017).

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