November 30, 2001
Donald S. Clark
Dear Mr. Clark:
Leo Burnett Worldwide, Inc. welcomes the opportunity to offer our support of the proposed two-year extension period during which Web sites directed to children can use an e-mail message from a parent, coupled with additional steps, to obtain verifiable parental consent for the collection of personal information from children.
By way of introduction, Leo Burnett Worldwide is one of the world's leading advertising agencies, and has produced some of the industry's most enduring advertising campaigns. We are responsible for creating the advertising for more than 250 brands on behalf of our 30 U.S. Clients which include the McDonald's Corporation, Allstate Insurance Companies, Morgan Stanley Dean Witter, Keebler Company, the U.S. Army, Kellogg Company, Walt Disney World, Procter & Gamble, Hallmark Cards, and General Motors to name a few.
We believe the proposed amendment to the Rule to extend the sliding scale mechanism for an additional two years is a wise one. We understand the Commission anticipated that the sliding scale was necessary only in the short term because more reliable methods of obtaining verifiable parental consent would be widely available and affordable through new technology. We believe the sliding scale mechanism has been very effective, and should be utilized until the time when the appropriate technology is available.
For these reasons, we believe that the proposed amendment to the Rule to extend the sliding scale mechanism for an additional two years should be approved as submitted.