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Jun. 14, 2023

Xbox and Alexa COPPA Case Lessons: Negotiating With the FTC Over Algorithms and Remedies

  • Matt Fleischer-Black
    Cybersecurity Law Report
Over the last three weeks, the FTC has been on a Children’s Online Privacy Protection Act Rule enforcement run, announcing settlements with Microsoft, Amazon and educational technology company Edmodo for a total of $51 million in penalties. These settlements provide case studies for negotiating with the FTC over algorithm disgorgement, remedial privacy programs and data minimization – now all top regulatory issues. This first article in a two-part series, including insights from former FTC officials at BakerHostetler and Wilson Sonsini, discusses the implications of the settlements and lessons for negotiating with the FTC. Part two will cover new FTC expectations around COPPA compliance and other related enforcement trends. See “How to Approach CCPA’s Under-16 Opt-In Consent” (Feb. 12, 2020).

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