My COPPA Comment to the FTC

I know the FTC doesn’t really care, but hopefully someone does. Here is my comment on the website where the FTC is “listening” to comments on the updates to COPPA.

The new COPPA regulations and the FTC specifically are unfairly targeting content creators and YouTube Channel owners because the owners of the platform on which they operate, that being, were fined for collecting information via digital persistent identifiers, activity on the platform, and other personally identifying digital information of users of the platform. They knowingly collected this information on children. They broke the law. The YouTube Channel owners and content creators did not collect this information. They did not encourage the collection of this information. They do not get access to this information to use it for their own benefit nor to sell it to third parties. collected this information and used it specifically to target ads to users, some of whom were children, as YouTube admits it was aware.

The FTC has stated that it is going to go after content creators and YouTube Channel owners litigiously for falling into the arbitrary category of “children’s content.” The FTC through COPPA has not defined what is and is not “children’s content” to the point that a content creator can know for certain how to purposely create content FOR KIDS or NOT FOR KIDS. The FTC has also demonstrated, through the current draft of COPPA that they are unaware of the user base for certain types of media including videos games, sports, cartoons, animation, movies, as well as types of graphic and multimedia design principles including fast paced or upbeat music, jump cut video editing, loud sound effects, flashy and colorful graphics. They have also shown their discontent for Internet culture by deeming such things as described as childish in nature; also including short format video productions from the likes of TikTok, as well as trending, relatable graphical jokes based on social gatherings and public figures also known as “memes.”

Furthermore, the FTC has shown their face as one that is not concerned with the individual American’s Constitutional rights. They show malcontent for YouTube Channel owners and content creators to such a disturbing level that they plan to restrict media productions unless the content creator follows their “laws” on what they can and cannot say, whether it’s through spoken language, the language of multimedia design principles, or the supposed “body language” of the content creator. They show no remorse in tearing down communities of legal adults in order to appease lobbying groups who claim to be watching out for the safety of children on the Internet, yet do not take proper steps to educate parents and children alike as to safe practices when using any digital medium. Nor do these lobbying groups fight for fair and purposeful modifications to websites and services such as in order to keep communities intact, but rather infringe on the right of these individuals (the content creators) to provide for themselves and their families a living performing a task or job that they do very well. It seems that the FTC and these lobbying groups would much rather content creators perform the kinds of jobs THEY want done, rather than let the content creators have the freedom to do the job they are most suited.

To end, it should be noted that no content creator has taken the stance in favor of collecting information on children in order to use that information for financial gain NOR do they desire to use such information for indoctrination. The content creators are making videos and other forms of digital media to build community, teach information, and make a living. Their freedom to live how they choose and pursue happiness has not crossed any moral lines. Those lines were crossed by the executives and management of and it is they who should face the penalties. Content creators who make videos that just so happen to include children’s content, see children as a secondary market, use media and editing choices that the FTC sees as “child friendly”, and just so happen to be family friendly content does not imply unlawfulness, nor should it. Especially when the content creators and YouTube Channel owners have no say in how the owners of the platform choose to conduct their business.

-David Morris

-Diggs out

P.S. – I feel like one of those teenagers who say things like “gee, knowing all that stuff about parallelograms sure will come in handy this parallelogram season… taxes? what’s that?” But, damn if this isn’t a bunch of old white dudes who don’t understand Internet culture or today’s culture in general, then I’m a panda.

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