IPR asks FTC to investigate child-directed mobile apps

In December 2012, IPR filed two Requests for Investigation with the Federal Trade Commission on behalf of the Center for Digital Democracy.  Both allege that mobile apps directed at children were collecting personal information in violation of the Children’s Online Privacy Protection Act.

2013-01-18 15.38.29The request filed on December 11, concerns Mobbles , a  mobile game that lets children “catch” virtual pets based on their real location. IPR’s filing, which was drafted by IPR student Jessica Wang, alleged that Mobbles failed to comply with COPPA’s requirement to post clear and understandable notice of its privacy practices regarding children on its home page and at each area of the service that collected information from children. Mobbles also did not comply with COPPA’s requirement to obtain verifiable parental consent before collecting information like email addresses from children.

2013-01-18 15.40.43The request filed on December 17 alleges that Nickelodeon and Playfirst are represent that SpongeBob Diner Dash collects personal data from users “in accordance with applicable law, such as COPPA,” when in fact the app neither provides the type of notice required by COPPA, nor makes any attempt to obtain prior, verifiable parental consent required by COPPA.  This request was drafted by IPR student Jordan Blumfeld.

These requests highlight the systemic disregard for COPPA by mobile apps targeting children. Indeed, the FTC’s report released December 1o, 2012, surveyed 400 popular children’s apps and found that 59% shared information like unique device IDs, email addresses, and phone numbers without notifying or seeking parental consent.   Only 20% of children’s apps provided any privacy disclosures to users.

There has been a great deal of press interest in both the FTC report on on the requests for investigation.  IPR Director Angela Campbell IPR Director Angela Campbell was interviewed for NPR’s All Things Considered and participated in a discussion of children’s privacy on the Diane Rehm show.  For additional press coverage, see below.

New Concerns Over Apps for Children, New York Times, Dec. 11, 2012.

FTC looks at mobile apps firms over child privacy concerns, Washington Post, Dec. 10, 2012.

Privacy group files complaint against kids’ mobile game maker, PC World, Dec. 11, 2012.

Advocacy Group Asks FTC to Proble Virtual-Pet, Online Media Daily, Dec. 11, 2012.

Developer temporarily pulls kids app accused of privacy violations, c/net, Dec. 11, 2012.

Nickelodeon plans to resubmit ‘SpongeBob’ game app to App Store, The Hill, Dec. 19, 2012 (quoting IPR Graduate Fellow Laura Moy)

Group Asks FTC to Investigate SpongeBob App, BNA Electronic Commerce and Law Report, Jan. 9, 2012.


About Angela Campbell

Angela Campbell has directed the Media Law and Policy program at the Institute for Public Representation since 1988. She is also a full-time tenured Professor at Georgetown Law.
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