The Federal Trade Commission (“FTC”) on December 20, 2023[1] proposed a set of revisions to its rules implementing the Children’s Online Privacy Protection Act (“COPPA Rule”).[2] The COPPA Rule, which became effective in 2000, and was amended in 2013, serves as the FTC’s primary means to enforce the Children’s Online Privacy Protection Act of 1998 (“COPPA”), the principal regulation protecting children (and their personal information) online. At a high level, the COPPA Rule requires operators of websites online services (i) directed to children[3] or (ii) when not directed to children, that have actual knowledge that they are collecting personal information online from a child;
