HIGHLIGHTS:
- The FTC announced settlements with an online video platform operator and a robot toy maker resolving allegations that they violated the FTC Act and FTC's COPPA Rule.
- The online video platform operator allegedly failed to designate certain child-directed videos as "made for kids," enabling targeted advertising and collection of children's personal information without parental notice or consent.
- The robot toy maker allegedly collected children's geolocation data through its companion mobile app without providing notice to parents or obtaining verifiable parental consent.
- Both proposed stipulated orders impose permanent injunctions, civil penalties, compliance programs, and long-term monitoring obligations.
CASE SUMMARY:
On September 2, 2025, the Federal Trade Commission ("FTC") filed complaints and proposed stipulated orders against two companies for alleged violations of Section 5 of the FTC Act and the FTC's Children's Online Privacy Protection Act ("COPPA") Rule.
The first case involves a large entertainment company that operates online video channels and uploads child-directed videos to a video sharing platform. According to the complaint, the company allegedly failed to properly mark certain videos as child-directed. This practice allowed the collection of children's personal information without parental notice or consent, contrary to COPPA requirements. As a result, in some cases, children received targeted advertisements. The proposed stipulated order requires the company to implement a robust audience designation program to ensure videos are correctly identified as "made for kids," provide direct notice to parents, and obtain verifiable parental consent before collecting, using, or disclosing children's personal information.
The second case involves a technology company that develops programmable toy robots marketed to children ages 6 to 14. The company requires the use of a companion mobile app to control and program the toy. The FTC alleged that the company's Android app collected precise geolocation data from children without parental notice or consent. The proposed stipulated order requires the company to delete unlawfully collected data, implement clear and conspicuous parental notice practices, obtain verifiable parental consent before collecting children's personal information, and comply with recordkeeping and reporting obligations for ten years.
Both settlements include permanent injunctions and civil penalty judgments, $10 million and $500,000 respectively, underscoring the FTC's focus on ensuring children's privacy is protected across online content platforms.
RESOURCES:
You can review all of the relevant administrative filings and press releases at the FTC's Enforcement Page.
