November 30, 2001

Secretary
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue NW
Washington, D.C. 20580

RE: Children's Online Privacy Protection Rule Amendment - Comment, P994504

Thank you for the opportunity to comment on the proposed amendment to the Children’s Online Privacy Protection Rule. The amendment would extend the time period during which a sliding scale approach to parental consent is available. The sliding scale allows Web site operators who are using personal information collected from children for internal purposes only to use an e-mail message from the parent, coupled with additional steps, as verifiable parental consent.

Circle 1 Network, the publisher of KidsCom, KidsCom Jr. and ParentsTalk, has a long-standing commitment to protect children and provide safe places for them to learn and play online. KidsCom, established in 1995, is the longest running "edutainment" site on the Internet for children. KidsCom Jr. offers games and activities designed specifically for children age three through seven, including the Internet Safety Game. ParentsTalk is an online community for moms and dads to learn more about parenting and share their opinions and insights on being a parent. Both KidsCom and KidsCom Jr. are fully compliant with the Children’s Online Privacy Protection Act (COPPA).

We oppose the amendment at this time. The time period during which the sliding scale approach to parental consent is available should not be extended beyond the original April 2002 deadline.

First, we believe that the principles and purpose behind COPPA are no less vital today than they were two years ago when the directive was launched. Second, we believe the conditions of the Internet make the principles of COPPA even more vital to establish without delay. For example:

• A growing visibility of pornography and other potentially negative influences
• The decrease in recognized kids sites (for example, Freezone, Nikolai and YOW are gone)
• A reduction of options for kids on remaining sites (Zeeks has dropped chat and staff cuts at other sites has reduced the frequency of content updates)
• An increase in the number of kids online and the hours they spend there (Future of the Internet According to Kids Study, SpectraCom Inc., October 2001)

Finally, many children’s sites have proven that is it possible to make the necessary adjustments – and investments – within the window originally provided by the Rule. Extending the deadline only rewards those companies that chose to ignore the intent and requirements of COPPA.

For these reasons we believe the sliding scale should expire as scheduled. It would be unconscionable to make children and their families wait any longer.

Respectfully submitted,