SAVE Family-Friendly Content on YouTube
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YouTube viewers and creators petition the Federal Trade Commission (FTC) to clarify and reconsider the new Children’s Online Privacy Protection (COPPA Rule) regulations on YouTube creators. Shutting off personalized ads on creators’ content will cause more harm than good, especially for children. Quality family-friendly content will shrink, while more mature content will grow — yet kids will still be watching.
The FTC should not expand COPPA regulations for content creators. Broadening the definition of “child-directed” to include “child-attractive” would force many more creators to turn off personalized ads. As a result, even more quality content will dry up, and more mature and extreme content will fill the platform.
The free YouTube Kids app is a better solution than regulation targeting family-friendly creators. YouTube Kids removes privacy concerns around personalized ads. Parents buy devices and allow their children to watch YouTube Main. Many parents prefer to use YouTube Main because it has more features and less barriers. Creators should not be punished when parents choose not to use YouTube Kids. COPPA is about putting parents in control of protecting their children’s personal information online. The FTC should not use COPPA to remove parents from the process in regulating content and online advertising.
While large corporations will survive these changes, small business creators face terminating employees, changing their business model, or shutting down production altogether. These regulations will particularly hurt young underserved audiences who participate in YouTube communities on topics like special needs, faith, and minority groups. Limiting quality free content for kids expands the digital divide. Turning off personalized ads on kids’ content also encourages increased product placement and brand deals within kids’ content.
Creators face COPPA fines up to $42,530 per video, yet the regulation and definition of “child-directed” is vague. The FTC needs to provide creators with enforcement clarity.
We ask the FTC to:
1. Provide an enforcement statement for creators
2. Clarify the definition of “child-directed,” and not expand it to cover “child-attractive” content
3. Delay enforcement against creators until the FTC concludes its review of COPPA
4. Allow parents to use YouTube Kids or YouTube Main, without forcing creators to turn off personalized ads when parents choose to use YouTube Main
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