|June 2, 2000
Donald S. Clark
Re: CARU Safe Harbor Proposal - Comment P004504
Dear Mr. Clark:
Leo Burnett Worldwide, Inc. welcomes the opportunity to offer our support of the proposed "Safe Harbor" Guidelines submitted by the Children's Advertising Review Unit (CARU) in response to the Federal Trade Commission (FTC) notice for comment. We believe that CARU's proposal fully adheres to the provisions of the Children's Online Privacy Protection Act (COPPA), and should be approved as a safe harbor by the FTC.
Leo Burnett is one of the worlds leading advertising agencies, and has produced some of the industry's most enduring advertising campaigns. These campaigns have helped build more than 500 of the world's leading brands, including five of the seven most valuable brands in the world as ranked by Financial World magazine. Combined billings for Leo Burnett's U.S. and international operations were more than $7 billion in 1999. Headquartered in Chicago, Leo Burnett has 91 full-service offices in 81 markets throughout the world. Leo Burnett employs approximately 8,500 people via a global network encompassing nearly 200 operating units.
Leo Burnett is a staunch supporter of industry self-regulation for advertising and has been a long time supporter of CARU. We strongly endorse the safe harbor proposal submitted by CARU. CARU is a well-respected organization and viewed as the consummate authority on self-regulation for advertising directed to children in the United States and abroad. CARU was the first organization to recognize the challenges of the Internet in 1996 and quickly adopted self-regulatory guidelines that governed the collection of information from children. CARU has also recently revised their guidelines specifically to incorporate the provisions of COPPA. For these reasons, we believe that CARU's safe harbor proposal should be approved as submitted.
Carla R. Michelotti
Leo Burnett Worldwide, Inc.