Among the companies that had complaints filed against them are
McDonald's, for its HappyMeal.com website, General Mills' for the ReesesPuffs.com and TrixWorld.com sites, Doctor's Associates for SubwayKids.com,
Viacom for Nick.com and Turner Broadcasting's CartoonNetwork.com.
The coalition -- which includes Center for Digital Democracy,
the Consumer Federation of America, Center for Science in the
Public Interest and the Privacy Rights Clearinghouse, among others
-- is asking the FTC to update its kids privacy rules to protect
kids against data collection and behavioral targeting, including
The chief concern for the coalition seems to be the use of
peer-to-peer viral marketing, or tell-a-friend campaigns. Common
practice in the marketing world when targeting teens and adults,
the coalition said that such tactics are "inherently unfair and
deceptive when aimed at children, who often aren't aware that they
are being asked to generate advertising messages." The websites in
question offer games or activities in which kids are encouraged to
share their experiences with their friends and are asked to provide
email addresses of friends, who are then sent emails encouraging
them to go to the website, the coalition said.
But a spokesman for General Mills, which
had not been contacted by the organizations, said the company
believes "they have mischaracterized or misunderstood" the issue.
COPPA, he added, "permits 'send-to-friend emails, provided the
sending friend's email address or full name is never collected and
the recipient's email address is deleted following the sending of
The coalition is also concerned with the practice of marketers
asking kids to upload photos of themselves, and the use of code to
track kids' online behavior. "All of this is done on these
child-directed websites without obtaining the express and
verifiable consent of either sets of parents -- a clear violation
of COPPA," said the Center for Digital Democracy on
"The companies identified in these complaints are clearly trying
to circumvent privacy safeguards for children," said Kathryn C.
Montgomery, a professor of communication at American University who
led the campaign in the 1990s for passage of COPPA, in the
statement. "They are also enlisting kids and their friends in
deceptive marketing schemes disguised as play -- in some cases for
junk foods and other unhealthy products -- completely under the
radar of parents." COPPA defines kids as individuals under the age
At least one marketer appears to have been caught blindsided by
the complaint. Danya Proud, spokeswoman at McDonald's, said in
a statement: "This alleged complaint(s) was shared with members of
the media under embargo. McDonald's was not provided the
opportunity to review in advance. As such, it would be
inappropriate to comment or speculate."
Nickelodeon said in a statement: "We take our compliance with
children's privacy rules very seriously, and the allegations made
by these groups are absolutely incorrect. Nick.com does not retain
any personal information as part of our 'Send to a Friend'
function, which simply allows kids to share their favorite online
games with one another in full compliance with COPPA."
Cartoon Network said in a statement: "Cartoon Network takes its
compliance with the Children's Online Privacy Protection Act very
seriously. We will review any allegations closely."
"Subway Restaurants takes online privacy seriously and is COPPA
and CARU compliant," a Subway spokesperson told Ad Age .