Dear Mr. Clark:

The Center for Digital Democracy (“CDD”), by its attorneys, the Institute for Public Representation (“IPR”), joined by American Academy of Child and Adolescent Psychiatry, Berkeley Media Studies Group, Campaign for a Commercial-Free Childhood, Center for Media Justice, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, ChangeLab Solutions, Global Action Project, Media Literacy Project, Privacy Rights Clearinghouse, Public Citizen, Public Health Advocacy Institute, and Rudd Center for Food Policy & Obesity at Yale (collectively, “Children’s Privacy Advocates”), are writing to supplement the record of the COPPA Rule Review with new information about how child-directed websites are using a viral marketing technique known as “refer-a-friend” to place third-party cookies on children’s computers and to collect and store photographs of children. We are also filing five Requests for Investigation of companies that, using refer-a-friend tactics, are collecting personal information from children on child-directed websites without providing notice and obtaining advance parental consent as required by the COPPA Rule.