CDD Filings Digital Youth

WASHINGTON, DC – October 18, 2017—A number of brands of “smartwatches” intended to help parents monitor and protect young children have major security and privacy flaws which could endanger the children wearing them. A coalition of leading U.S. child advocacy, consumer, and privacy groups sent a letter to the Federal Trade Commission (FTC) today, asking the agency to investigate the threat these watches pose to children. Smartwatches for children essentially work as a wearable smartphone. Parents can communicate with their child through the mobile phone function and track the child’s location via an app. Some product listings recommend them for children as young as three years old. Groups sending the letter to the FTC are the Electronic Privacy Information Center (EPIC), the Center for Digital Democracy (CDD), the Campaign for a Commercial-Free Childhood (CCFC), the Consumer Federation of America, Consumers Union, Public Citizen, and U.S. PIRG. The advocacy groups are working with the Norwegian Consumer Council (NCC), which conducted research (link is external) showing that watches sold in the U.S. under the brands Caref and SeTracker have significant security flaws, unreliable safety features, and policies which lack consumer privacy protections. In the EU, groups are filing complaints in Belgium, Denmark, the Netherlands, Sweden, Germany, the UK, and with other European regulators. “By preying upon parents’ desire to keep children safe and, these smart watches are actually putting kids in danger,” said CCFC’s Executive Director Josh Golin. “Once again, we see Internet of Things products for kids being rushed to market with no regard for how they will protect children’s sensitive information. Parents should avoid these watches and all internetconnected devices designed for kids.” The NCC’s research showed that with two of the watches, a stranger can take control of the watch with a few simple steps, allowing them to eavesdrop on conversations the child is having with others, track and communicate with the child, and access stored data about the child’s location. The data is transmitted and stored without encryption. The watches are also unreliable: a geo-fencing feature meant to notify parents when a child leaves a specified area, as well as an “SOS” function alerting parents when a child is in distress, simply do not work. The manufacturers’ data practices also put children at risk. Some devices have no privacy policies at all, and the policies that do exist lack basic consumer protections, including seeking consent for data collection, notifying users of changes in terms, and allowing users to delete stored data. "The Trump Administration and the Congress must bring America’s consumer product safety rules into the 21st century,” said Jeff Chester of the Center for Digital Democracy. “In the rush to make money off of kids’ connected digital devices, manufacturers and retailers are failing to ensure these products are truly safe. In today’s connected world that means protecting the privacy and security of the consumer—especially of children. Both the FTC and the Consumer Product Safety Commission must be given the power to regulate the rapidly growing Internet of Things marketplace.” The Caref (branded Gator in Europe) and SeTracker smartwatches are available online through Amazon. The groups have asked the FTC to act quickly to investigate these products, and they advise parents to refrain from buying the products because of the danger they could pose to children. The NCC, which conducted the testing of the watches, advises consumers who have already purchased the watches to stop using them and uninstall the app. “The Federal Trade Commission must be proactive in protecting consumers—especially vulnerable young children—from harmful products that abuse technology for the sake of profit,” said Kristen Strader, Campaign Coordinator for Public Citizen. “Smartwatches and similar devices must be absolutely safe and secure before they are released to the public for sale.” Ed Mierzwinski, Consumer Program Director at U.S. PIRG, said, "Companies making any internet-connected devices, but especially for children, need to ensure that privacy and security are more than breakable — or worse, hackable — promises." Katie McInnis, technology policy counsel for Consumers Union, said, “When a company sells a smartwatch aimed at children, it must ensure the product is safe and secure. The FTC should launch an investigation into the privacy and security concerns surrounding these products to make sure families are safe.” The same trans-Atlantic coalition persuaded government authorities and retailers last December (link is external) that the internet-connected dolls Cayla and i-Que Robot were spying on children and threatening their welfare, and retailers removed the toys from store shelves. The FBI subsequently issued a warning to consumers (link is external) that internet-connected toys could put the privacy and safety of children at risk. --- For more information, please see the following: Letter to FTC by coalition of leading U.S. child advocacy, consumer, and privacy groups (link below) Press Release by US coalition of leading U.S. child advocacy, consumer and privacy groups (link below) #WatchOut Report by Norwegian Consumer Council (link below) Press Release by Norwegian Consumer Council (link below) #WatchOut English - YouTube (http://bit.ly/2ghNoD1 (link is external)) #WatchOut - longer video explainer on security flaws 4:30 mins - YouTube (http://bit.ly/2xLYSVv (link is external))

Washington, DC (March 6, 2017): The Center for Digital Democracy (CDD), Campaign for a Commercial-Free Childhood, Common Sense Kids Action, Consumer Action and the Electronic Privacy Information Center (EPIC) called on the Federal Communications Commission (FCC) to reject industry requests to rescind the FCC’s broadband privacy rules, as this would leave parents effectively without any tools to protect their children’s privacy on broadband Internet Service Provider networks (ISPs). The groups warned that any attempts to modify the privacy rule would significantly weaken the privacy protections for children. The filing to the FCC was drafted by the Institute for Public Representation at Georgetown University Law Center (IPR). In October 2016, the Federal Communications Commission adopted ground-breaking privacy rules protecting the personal information of broadband internet service customers, including children. The FCC rules set limits on what internet service providers may do with the highly sensitive data that they collect in the course of providing internet service. These rules were intended to give consumers and parents the tools they need to make informed decisions about how their information, or the information of their children, is used by their ISP. Most significantly, the rules require ISPs to obtain opt-in approval for use and sharing of sensitive customer personal information for purposes other than providing broadband service. “Sensitive” information includes precise geo-location, financial information, health information, children’s information, social security numbers, web browsing history, app usage history and the content of communications. In their filing, the advocates oppose petitions filed by ISPs, including Comcast, Verizon and Time Warner, that ask the FCC to reconsider its broadband privacy Order. The advocates explain in their filing with the FCC: Treating children’s information as sensitive and requiring notice and opt-in consent is necessary to protect children and is consistent with the FTC’s practices. This aspect of the rules is necessary, although not sufficient to protect children’s privacy. All web browsing and application usage histories must be treated as sensitive information because children's information is mixed with that of adults. In order to protect children from targeted advertising, all users' browsing and application histories must receive protection as such histories reveal traits, characteristics, likes, and dislikes. Marketers, who are intensely interested in targeting children and adolescents, would have a much greater ability to take unfair advantage of children, without these rules in place. The FCC should retain opt-in requirements for use of all categories of sensitive information, such as for web browsing and application usage histories. Since this data is inextricably intertwined with adult activities, any required additional sorting of this data into sensitive and non-sensitive data would inevitably lead to further erosion of privacy of all ISP users. Most Americans are oblivious to modern day big data practices and to the resulting potential risks to themselves or society at large. When it comes to vulnerable children it must be the obligation of ISPs to make a convincing case to parents that opting into the ISP’s data practices is in the best interest of their children. The following can be attributed to Katharina Kopp, Deputy Director, Center for Digital Democracy: The FCC Privacy Rules protect the fundamental rights of children to enjoy privacy and freedom from age-inappropriate commercial exploitation. Any attempts to weaken these rules is an attempt to leave parents and their children defenseless against powerful corporate interests. Digital food marketing of unhealthy foods to children and teens, for example, has contributed to an obesity epidemic that harms us all. This is unfair, unjust and not in the public interest. We call on the FCC to implement the Privacy Order in its entirety without any delay. The following can be attributed to Josh Golin, Executive Director, Campaign for a Commercial-Free Childhood This is a crucial test for the FCC. Will the Commission insist that parents have a right to protect their children’s privacy online? Or will the FCC aid and abet the ISP’s efforts to build digital marketing profiles of vulnerable children? We call on the Commission to do the right thing and implement the Privacy Order. The following statement can be attributed to Linda Sherry, Director of National Priorities, Consumer Action: Consumer Action opposes efforts to rescind the FCC’s broadband privacy rules, which would jeopardize the privacy of all internet service customers and strip them of the right to assert control over their sensitive information including geo-location, financial, health, etc. We join the Center for Digital Democracy in highlighting the potential harm to children, a highly vulnerable and defenseless population that has gained important new rights under the rule, which specifically recognizes the sensitivity of children’s information. The Center for Digital Democracy is a leading nonprofit organization focused on empowering and protecting the rights of the public in the digital era. The Campaign for a Commercial-Free Childhood support parents’ efforts to raise healthy families by limiting commercial access to children. Consumer Action empowers low- and moderate-income and limited-English-speaking consumers nationwide to prosper through education and advocacy. EPIC is a public interest research center in Washington, DC, established in 1994 to focus public attention on emerging privacy and civil liberties issues and to protect privacy, freedom of expression, and democratic values in the information age.

WASHINGTON, DC – December 6, 2016 – The growing popularity of “smart” Internet-connected toys poses significant privacy, security, and other risks to children, according to a complaint filed today (link is external) by leading child advocacy, consumer, and privacy groups at the Federal Trade Commission (FTC). My Friend Cayla and I-Que Intelligent Robot, dolls marketed to both young girls and boys, collect and use personal information from children in violation of the Children’s Online Privacy Protection Act (COPPA) and FTC rules prohibiting unfair and deceptive practices. The complaint calls upon the FTC to investigate and take action against Genesis Toys, the maker of My Friend Cayla and I-Que, and Nuance Communications, which provides third-party voice recognition software for the toys. Groups filing the complaint are the Campaign for a Commercial Free Childhood (CCFC), the Center for Digital Democracy (CDD), Consumers Union, and the Electronic Privacy Information Center (EPIC).When companies collect personal information from children through the Internet, they incur serious legal obligations to protect children’s privacy. COPPA reflects a general understanding that the collection and use of information about young children should be treated with care and avoided when possible. Yet, the complaint charges, “Both Genesis Toys and Nuance Communications unfairly and deceptively collect, use, and disclose audio files of children’s voices without providing adequate notice or obtaining verified parental consent.” The complaint also takes issue with Genesis' failure to take reasonable security measures to prevent unauthorized Bluetooth connections with the toys. As a result, Genesis fails to prevent strangers and predators from covertly eavesdropping on children's private conversations, which "creates a substantial risk of harm because children may be subject to predatory stalking or physical danger."“With the growing Internet of Things, American consumers face unprecedented levels of surveillance in their most private spaces, and young children are uniquely vulnerable to these invasive practices,“ said Claire T. Gartland, Director, EPIC Consumer Privacy Project. “The FTC has an obligation here to step in and safeguard the privacy of young children against toys that spy and companies that exploit their very voices for corporate gain.”According to the complaint, the list of privacy violations by these “spy toys” is lengthy. For example, the packaging for My Friend Cayla has no mention of privacy, and locating the doll's Terms of Service is a major challenge. Once a parent does locate Cayla’s Privacy Policy and Terms of Use, these documents shed little light on what information is actually collected from children, how it’s used, or where it ends up. In one of the most serious legal violations, Genesis fails to get parents’ consent before collecting children’s voice recordings and other personal data. Children’s voice recordings from the dolls are also sent to Nuance, a company that may use them for its law enforcement and military intelligence products.“Genesis and Nuance are completely disregarding their legal and ethical obligations when it comes to kids’ privacy,” Gartland said. “Instead, they have chosen to exploit children’s sensitive voice recordings and private conversations for corporate profit. It is extremely alarming that what a child says to her ‘trusted’ friend could end up in a voice biometrics database sold to law enforcement and intelligence agencies.”Today’s FTC complaint is part of an unprecedented, coordinated, transatlantic legal action involving consumer and privacy groups in the US and Europe. Leading European consumer organizations filed a series of formal complaints with EU regulators, and with data protection, consumer protection, and product safety agencies in France, the Netherlands, Belgium, Ireland, and Norway. The combined US and European advocacy effort was triggered by groundbreaking research from the Norwegian Consumer Council, which conducted an in-depth legal and technical analysis of three Internet-connected toys (link is external). The Council’s “Toyfail” report examined Cayla, I-Que, and Mattel’s interactive Hello Barbie doll, all of which are produced and distributed by multinational companies and targeted at children.These products are part of a new generation of digital playthings – known as the “Internet of Toys” – which are growing in popularity, with consumers spending an estimated $2.8 billion on them last year (link is external). The toys use WiFi, Bluetooth, or mobile apps, and offer “smart” features such as cameras, microphones, and sensors that can record and respond to children’s interactions.Consumer groups on both sides of the Atlantic have raised serious concerns about the threats that Internet-connected toys pose to children’s privacy, security, and safety, as well as potential harms to children’s psychosocial development.Researchers who analyzed the Cayla doll discovered that it had been pre-programmed with dozens of phrases that reference Disneyworld and Disney movies. This product placement is not disclosed to users and would be difficult for young children to recognize as advertising. “Children form friendships with dolls and toys with ‘personalities,’ and confide intimate details about their lives with them,” said CCFC’s Executive Director Josh Golin. “It is critical that the sensitive data collected by these toys be subject to the most stringent protections and not be used for manipulative and sneaky marketing.”Katie McInnis, technology policy counsel for Consumers Union, said, “As more toys are connected to the Internet, we have to ensure that children's privacy and security are protected. When a toy collects personal information about a child, families have a right to know, and they need to have meaningful choices to decide how their kids' data is used. We strongly urge the FTC to investigate these companies, stop the deceptive practices, and hold them accountable."“Children today are growing up immersed in a digital world, where mobile devices, games, apps, and now a new generation of Internet-toys are profoundly shaping their social interactions, personal experiences, and behaviors,” commented Kathryn Montgomery, Professor of Communication at American University and consultant to CDD. “Regulators need to ensure that children will be able to reap the benefits of these digital technologies without being subjected to harmful practices that undermine their privacy, safety, and wellbeing.”As Montgomery, who led the campaign for passage of COPPA, also noted: “This will be a crucial test of the new FTC under the Trump Administration. Now more than ever, we must ensure that children’s needs are high on the policy agenda for the Big Data era.”The full FTC complaint from CCFC, CDD, Consumers Union, and EPIC is available at https://epic.org/privacy/kids/EPIC-IPR-FTC-Genesis-Complaint.pdf (link is external).The full Toyfail report is available at http://www.forbrukerradet.no/siste-nytt/connected-toys-violate-consumer-laws (link is external).A short video demonstrating the toys’ vulnerabilities can be viewed at https://www.youtube.com/watch?v=lAOj0H5c6Yc (link is external).

The Center for Digital Democracy (CDD), which works to empower and protect consumers in the digital marketplace, endorses the Federal Communications Commission’s (FCC) important proposal to provide both choice and competition in the provision of navigational devices for video and related content. CDD strongly believes that the FCC should proceed with its plan to allow third parties to build and sell navigational devices. We support giving these developers/providers access to the information proposed in the NPRM, including Service Discovery, Entitlement, and Content Delivery data. For decades, a handful of powerful cable—and now also telephone—companies have held a monopoly over the design, availability, and use of set-top boxes. This has resulted in greater costs to subscribers, including an especially unfair burden on low- or limited-income consumers. The set-top stranglehold has impaired competition and programming diversity, and has undermined consumer privacy. --- Full PDF of filing attached.

Washington, DC–Tuesday, November 24, 2015 –Two leading child advocacy groups filed new complaints today at the Federal Trade Commission (FTC), urging the Commission to stop Google from engaging in unfair and deceptive practices toward children on its YouTube Kids app for kids five and younger. In two related FTC filings submitted today, Campaign for a Commercial-Free Childhood (CCFC) and Center for Digital Democracy (CDD) also called on the FTC to broaden its investigation of YouTube Kids to include Google’s relationships with multichannel video programmers; food, beverage and toy companies; its major YouTube advertising and “unboxing” video partners; and companies that specialize in “influencer” and product placement marketing on YouTube.“Our new complaints underscore why the FTC needs to stop Google from engaging in what are nothing less than harmful, unethical, and irresponsible practices that target America’s youngest children,” explained Jeff Chester, Executive Director of the Center for Digital Democracy. “The Commission now has ample evidence that Google’s actions are unfair and deceptive and violate Section 5 of the FTC Act. We call on Chairwoman Ramirez and the other Commissioners to complete their investigation and commence legal action against Google so that children and their parents will be protected when they use YouTube Kids.”In one of the complaints (link is external) filed today, CCFC and CDD urge the Commission to hold 17 food and beverage manufacturers accountable for violating the self-regulatory pledges they made as members of the Children’s Food and Beverage Advertising Initiative (CFBAI). A review of YouTube Kids by CCFC and CDD found hundreds of commercials and promotional videos for products these companies had publicly pledged not to market to children under the age of 12. For example, even though the Coca-Cola Company has pledged to not market any beverages to children under 12, CCFC and CDD found 47 television commercials and 11 longer promotional videos for Coke and Coke Zero on YouTube Kids. Similarly, Mondelez International has pledged not to market Oreos to children, but CCFC and CDD found 31 TV commercials and 21 product placements for Oreos on YouTube Kids. In one 11-minute video, the YouTube star Evan of “EvanTubeHD” and his sister compete to identify 12 different flavors of Oreos. [Evan HD is distributed by the Walt Disney Company’s Maker Studios division].“Far from being a safe place for kids to explore, YouTube Kids is awash with food and beverage marketing that you won’t find on other media platforms for young children,” said CCFC’s Josh Golin. “The Commission should investigate why Google’s algorithms aren’t configured to keep junk food marketing off of YouTube Kids, and hold food and beverage companies accountable for violating their pledges not to target their most unhealthy products to children.” “Food companies and Google have teamed up for an end run around America's parents,” said Dale Kunkel, Professor of Communication at University of Arizona. “YouTube Kids delivers hundreds of junk food video promotions while Google claims it allows no food advertising on the app, and food companies promise the FTC they won't advertise products like Snickers and Oreos to children. It’s hard to believe this is all happening in broad daylight.”The second FTC complaint (link is external) filed today significantly expands upon the groups’ initial complaint filed on April 7, 2015 (link is external). It documents that many videos on YouTube Kids appear to result from relationships and payments between advertisers, YouTube creators, and various intermediaries, including multichannel video programmers and advertising agencies that specialize in “influencer” marketing. Because these relationships are not disclosed on YouTube Kids as required by the FTC’s Endorsement Guide, CCFC and CDD call on the FTC to investigate the contractual and other business connections between Google and its YouTube commercial partners and affiliates.The second complaint also explains how changes made by Google to YouTube Kids do not alleviate the problems raised in the original complaint—that YouTube Kids targets children with deceptive and unfair advertisements, and Google markets YouTube Kids to parents in a deceptive manner. “When Google launched YouTube Kids in February, it falsely told parents that ‘all advertisements in the YouTube Kids app must comply’ with its Ad Policy prohibiting ads for certain products, including food and beverages,” said Professor Angela Campbell of Georgetown University’s Institute for Public Representation, counsel for CCFC and CDD. “Instead of enforcing its Ad Policy, Google changed its policy so that it does not apply to traditional TV commercials or longer promotional videos. This is a major disservice to children and parents alike.”----See complaints attached.

Washington, DC - September 14,th 2015 - The Center for Digital Democracy (CDD) filed comments at the Federal Trade Commission (FTC) in response to an application from Jest8 Limited (trading as Riyo) for a new verifiable parental consent (VPC) method that purports to be in compliance with the Children’s Online Privacy Protection Act (COPPA). That act requires the operators of websites directed at children under 13 to obtain verifiable parental consent before collecting any personal information from a child. But as CDD’s detailed filing makes clear, Jest8’s system, which attempts to match a photo of a parent with a photo of that parent’s ID, fails on three fundamental counts: (1) it does not ensure that the person submitting the photographic evidence is, in fact, the parent; (2) it does not satisfactorily demonstrate that its facial recognition algorithms are sufficiently reliable to be deployed in the sensitive area of children’s privacy; and (3) it poses a severe risk to the consumer data that it collects in the process of undertaking its “Face Match to Verified Photo Identification,” with no assurance that it it will promptly delete such data as promised. The filing also raises questions about the applicant’s lack of any background on privacy issues, especially those that address the needs of children.“The FTC must ensure that a parent is actually authorizing the collection of their child’s data,” explained CDD executive director Jeff Chester. “Jest8 fails to provide any serious guarantee that a child’s privacy will be protected, and that their parent or guardian has made an informed decision.”CDD (through its predecessor, the Center for Media Education) spearheaded the campaign that led to the passage of COPPA in 1998. More recently, CDD successfully organized the effort to update and strengthen the COPPA rules in 2012, working with a coalition of consumer, child advocacy, and health organizations.A copy of CDD’s FTC filing is available at www.democraticmedia.org.The CDD's comments on Jest8's application, attached below.

Washington, DC – Tuesday, May 19 – Two leading child and consumer advocacy groups have filed an important update to their Federal Trade Commission complaint against Google’s YouTube Kids app for false and deceptive marketing. In a letter sent to the Commission today, the groups charged that Google is deceiving parents by marketing YouTube Kids as a safe place for children under five to explore when, in reality, the app is rife with videos that would not meet anyone’s definition of “family friendly.” A review by the Campaign for a Commercial-Free Childhood (CCFC) and Center for Digital Democracy (CDD) has found a significant amount of content that would be extremely disturbing and/or potentially harmful for young children to view, including: Explicit sexual language presented amidst cartoon animation Videos that model unsafe behaviors such as playing with lit matches, shooting a nail gun, juggling knives, tasting battery acid, and making a noose A profanity-laced parody of the film Casino featuring Bert and Ernie from Sesame Street Graphic adult discussions about family violence, pornography, and child suicide Jokes about pedophilia and drug use Advertising for alcohol products CDD and CCFC provided a video (link is external) to the FTC today documenting an array of inappropriate content that can found on YouTube Kids. “Federal law prevents companies from making deceptive claims that mislead consumers," said Aaron Mackey, the coalition’s attorney at Georgetown Law's Institute for Public Representation. "Google promised parents that YouTube Kids would deliver appropriate content for children, but it has failed to fulfill its promise. Parents rightfully feel deceived by YouTube Kids." Google claims that YouTube Kids was “built from the ground up with little ones in mind” and is “packed full of age-appropriate videos.” The app includes a search function that is voice-enabled for easy use for preschool children. Google says it uses “a mix of automated analysis, manual sampling, and input from our users to categorize and screen out videos and topics that may make parents nervous.” Google also assures parents that they “can rest a little easier knowing that videos in the YouTube Kids app are narrowed down to content appropriate for kids.” But, as the complaint explains: Google does not, in fact, “screen out the videos that make parents nervous” and its representations of YouTube Kids as a safe, child-friendly version of YouTube are deceptive. Parents who download the app are likely to expose their children to the very content they believed they would avoid by using the preschool version of YouTube. In addition to the unfair and deceptive marketing practices we identified in our initial request for an investigation, it is clear that Google is deceiving parents about the effectiveness of their screening processes and the content on YouTube Kids. “In the rush to expand its advertising empire to preschoolers, Google has made promises about the content on YouTube Kids that it is incapable of keeping,” said Josh Golin, Associate Director of CCFC. “As a parent, I was shocked to discover that an app that Google claims is safe for young children to explore includes so much inappropriate content from the Wild West of YouTube.” Today’s letter is an update to the advocates’ April 7, 2015 FTC complaint that charged Google with engaging in unfair and deceptive practices towards children and their parents. That complaint detailed how YouTube Kids featured ads and other marketing material that took advantage of children’s developmental vulnerabilities. It also noted that the “blending of children’s programming content with advertising material on television has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” The complaint also called on the FTC to address the failure by Google to disclose that many makers of so-called “user-generated” videos featuring toys and candy have relationships with those product's manufacturers. “The same lack of responsibility Google displayed with advertising violations on YouTube Kids is also apparent in the content made available on the app,” observed Dale Kunkel, Professor of Communication at University of Arizona. “There is a serious risk of harm for children who might see these videos. It’s clear Google simply isn’t ready to provide genuinely appropriate media products for children.” Added Jeff Chester, executive director of CDD, “Google gets an 'F' when it comes to protecting America’s youngest kids. The failure of the most powerful and technologically advanced media company to create a safe place for America’s youngest kids requires immediate action by the FTC.” Today’s letter to the FTC is available below. The coalition’s original FTC complaint is available at http://bit.ly/1LeQHCN. The compilation of YouTube Kids video clips can be viewed at https://vimeo.com/127837914 (link is external).

Washington, DC – Tuesday, April 7 – A coalition of prominent children’s and consumer advocacy groups filed a complaint with the Federal Trade Commission (FTC) today requesting an investigation of Google, charging the company with unfair and deceptive practices in connection with its new YouTube Kids app. The complaint (link is external) details a number of the app’s features that take advantage of children’s developmental vulnerabilities and violate long-standing media and advertising safeguards that protect children viewing television. Among the specific practices identified in the complaint are: Intermixing advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two; Featuring numerous “branded channels” for McDonald’s, Barbie, Fisher-Price, and other companies, which are little more than program-length commercials; Distributing so-called “user-generated” segments that feature toys, candy, and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTC’s Endorsement Guidelines. When it launched the YouTube Kids app in February, Google described it as “the first Google product built from the ground up with little ones in mind.” As the complaint points out, however, the company appears to have ignored not only the scientific research on children’s developmental limitations, but also the well-established system of advertising safeguards that has been in place on both broadcast and cable television for decades. Those important policies include (1) a prohibition against the host of a children’s program from delivering commercial messages; (2) strict time limits on the amount of advertising any children’s program can include; (3) the prohibition of program-length commercials; and (4) the banning of “product placements” or “embedded advertisements.” Such “blending of children’s programming content with advertising material on television,” the group’s complaint declares, “has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” The complaint also charges that Google is violating its own advertising policies for YouTube Kids. For example, while the company promises that food and beverage ads will not appear on the app, advertising and promotions for junk food are prominently featured throughout. “YouTube Kids is the most hyper-commercialized media environment for children I have ever seen,” commented Dale Kunkel, Professor of Communication, University of Arizona. “Many of these advertising tactics are considered illegal on television, and it's sad to see Google trying to get away with using them in digital media.” “There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” added Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. “YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming. Furthermore, YouTube Kids' advertising policy is incredibly deceptive. To cite just one example, Google claims it doesn't accept food and beverage ads but McDonald's actually has its own channel and the 'content' includes actual Happy Meal commercials.” Angela J. Campbell of the Institute for Public Representation at Georgetown Law, who serves as counsel to the coalition, called on the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products. The FTC’s Endorsement Guides require disclosure of any such relationships so that consumers will not be misled." “In today’s digital era, children deserve effective safeguards that will protect them regardless of the ‘screen’ they use,” explained Jeff Chester, Executive Director of the Center for Digital Democracy. “In addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, new policies will be required to address the growing arsenal of powerful digital marketing and targeting practices that are shaping contemporary children’s media culture – on mobile phones, social media, gaming devices, and online video platforms.” Organizations signing the complaint include: the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, Consumers Union, Corporate Accountability International, and Public Citizen