Publishings Digital Youth

Groups say FIFA: Ultimate Team preys on children’s vulnerability with loot boxes, “funny money" Contact:David Monahan, Fairplay david@fairplayforkids.orgJeff Chester, CDD jeff@democraticmedia.org; 202-494-7100Advocates call on FTC to investigate manipulative design abuses in popular FIFA gameGroups say FIFA: Ultimate Team preys on children’s vulnerability with loot boxes, “funny money”BOSTON and WASHINGTON, DC – Thursday, June 2, 2022 – Today, advocacy groups Fairplay and Center for Digital Democracy (CDD) led a coalition of 15 advocacy groups in calling on the Federal Trade Commission (FTC) to investigate video game company Electronic Arts (EA) for unfairly exploiting young users in EA’s massively popular game, FIFA: Ultimate Team. In a letter sent to the FTC, the advocates described how the use of loot boxes and virtual currency in FIFA: Ultimate Team exploits the many children who play the game, especially given their undeveloped financial literacy skills and poor understanding of the odds of receiving the most desirable loot box items.Citing the Norwegian Consumer Council’s recent report, Insert Coin: How the Gaming Industry Exploits Consumers Using Lootboxes, the advocates’ letter details how FIFA: Ultimate Team encourages gamers to engage in a constant stream of microtransactions as they play the game. Users are able to buy FIFA points, a virtual in-game currency, which can then be used to purchase loot boxes called FIFA packs containing mystery team kits; badges; and player cards for soccer players who can be added to a gamer’s team. In their letter, the advocates noted the game’s use of manipulative design abuses such as “lightning round” sales of premium packs to promote the purchase of FIFA packs, which children are particularly vulnerable to. The advocates also cite the use of virtual currency in the game, which obscures the actual cost of FIFA packs to adult users, let alone children. Additionally, the actual probability of unlocking the best loot box prizes in FIFA: Ultimate Team is practically inscrutable to anyone who is not an expert in statistics, according to the advocates and the NCC report. In order to unlock a specific desirable player in the game, users would have to pay around $14,000 or spend three years continuously playing the game. “By relentlessly marketing pay-to-win loot boxes, EA is exploiting children’s desire to compete with their friends, despite the fact that most adults, let alone kids, could not determine their odds of receiving a highly coveted card or what cards cost in real money. The FTC must use its power to investigate these design abuses and determine just how many kids and teens are being fleeced by EA.” Josh Golin, Executive Director, Fairplay“Lootboxes, virtual currencies, and other gaming features are often designed deceptively, aiming to exploit players’ known vulnerabilities. Due to their unique developmental needs, children and teens are particularly harmed. Their time and attention is stolen from them, they're financially exploited, and are purposely socialized to adopt gambling-like behaviors. Online gaming is a key online space where children and teens gather in millions, and regulators must act to protect them from these harmful practices.” Katharina Kopp, Deputy Director, Center for Digital Democracy“As illustrated in our report, FIFA: Ultimate Team uses aggressive in-game marketing and exploits gamers’ cognitive biases - adults and children alike - to manipulate them into spending large sums of money. Children especially are vulnerable to EA’s distortion of real-world value of its loot boxes and the complex, misleading probabilities given to describe the odds of receiving top prizes. We join our US partners in urging the Federal Trade Commission to investigate these troubling practices.” Finn Lützow-Holm Myrstad, Digital Policy Director, Norwegian Consumer Council"The greed of these video game companies is a key reason why we're seeing a new epidemic of child gambling in our families. Thanks to this report, the FTC has more than enough facts to take decisive action to protect our kids from these predatory business practices." Les Bernal, National Director of Stop Predatory Gambling and the Campaign for Gambling-Free Kids“Exploiting consumers, especially children, by manipulating them into buying loot boxes that, in reality, rarely contain the coveted items they are seeking, is a deceptive marketing practice that causes real harm and needs to stop. TINA.org strongly urges the FTC to take action.” Laura Smith, Legal Director at TINA.orgAdvocacy groups signing today's FTC complaint include Fairplay; the Center for Digital Democracy; Campaign for Accountability; Children and Screens: Institute of Digital Media and Child Development; Common Sense Media; Consumer Federation of America; Electronic Privacy Information Center (EPIC); Florida Council on Compulsive Gambling, Inc.; Massachusetts Council on Gaming and Health; National Council on Problem Gambling; Parent Coalition for Student Privacy; Public Citizen; Stop Predatory Gambling and the Campaign for Gambling-Free Kids; TINA.org (Truth in Advertising, Inc.); U.S. PIRG### lootboxletter_pr.pdf, lootboxletterfull.pdf

60 leading advocacy organizations say unregulated Big Tech business model is “fundamentally at odds with children’s wellbeing”Contact:David Monahan, Fairplay david@fairplayforkids.org(link sends e-mail)Jeff Chester, Center for Digital Democracy, jeff@democraticmedia.org(link sends e-mail), 202-494-7100Diverse coalition of advocates urges Congress to pass legislation to protect kids and teens online60 leading advocacy organizations say unregulated Big Tech business model is “fundamentally at odds with children’s wellbeing”BOSTON, MA and WASHINGTON, DC - March 22, 2022 – Congressional leaders in the House and Senate were urged today to enact much needed protections for children and teens online. In a letter to Senate Majority Leader Chuck Schumer, Senate Minority Leader Mitch McConnell, House Speaker Nancy Pelosi and House Minority Leader Kevin McCarthy, a broad coalition of health, safety, privacy and education groups said it was time to ensure that Big Tech can no longer undermine the wellbeing of America’s youth. The letter reiterated President Biden’s State of the Union address call for increased online protections for young people.In their letter, the advocates outlined how the prevailing business model of Big Tech creates a number of serious risks facing young people on the internet today, including mental health struggles, loss of privacy, manipulation, predation, and cyberbullying. The advocates underscored the dangers posed by rampant data collection on popular platforms, including algorithmic discrimination and targeting children at particularly vulnerable moments.  The reforms called for by the advocates include:Protections for children and teens wherever they are online, not just on “child-directed” sites;Privacy protections to all minors;A ban on targeted advertising to young people;Prohibition of algorithmic discrimination of children and teens;Establishment of a duty of care that requires digital service providers to make the best interests of children a primary design consideration and prevent and mitigate harms to minors;Requiring platforms to turn on the most protective settings for minors by default;Greater resources for enforcement by the Federal Trade Commission.United by the desire to see Big Tech’s harmful business model regulated, the advocates’ letter represents a landmark moment for the movement to increase privacy protections for children and teenagers online, especially due to the wide-ranging fields and focus areas represented by signatories. Among the 60 signatories to the advocates’ letter are: Fairplay, Center for Digital Democracy, Accountable Tech, American Academy of Pediatrics, American Association of Child and Adolescent Psychiatry, American Psychological Association, Center for Humane Technology, Common Sense, Darkness to Light, ECPAT-USA, Electronic Privacy Information Center (EPIC), National Alliance to Advance Adolescent Health, National Center on Sexual Exploitation, National Eating Disorders Association, Network for Public Education, ParentsTogether, Public Citizen, Society for Adolescent Health and Medicine, and Exposure Labs, creators of The Social Dilemma.Signatories on the need for legislation to protect young people online:“Congress last passed legislation to protect children online 24 years ago – nearly a decade before the most popular social media platforms even existed. Big Tech's unregulated business model has led to a race to the bottom to collect data and maximize profits, no matter the harm to young people. We agree with the president that the time is now to update COPPA, expand privacy protections to teens, and put an end to the design abuses that manipulate young people into spending too much time online and expose them to harmful content.” – Josh Golin, Executive Director, Fairplay.“It’s long past time for Congress to put a check on Big Tech’s pervasive manipulation of young people’s attention and exploitation of their personal data. We applaud President Biden’s call to ban surveillance advertising targeting young people and are heartened by the momentum to rein in Big Tech and establish critical safeguards for minors engaging with their products.” – Nicole Gill, Co-Founder and Executive Director, Accountable Tech.“Digital technology plays an outsized role in the lives of today’s children and adolescents, exacerbated by the dramatic changes to daily life experienced during the pandemic. Pediatricians see the impact of these platforms on our patients and recognize the growing alarm about the role of digital platforms, in particular social media, in contributing to the youth mental health crisis. It has become clear that, from infancy through the teen years, children’s well-being is an afterthought in developing digital technologies. Strengthening privacy, design, and safety protections for children and adolescents online is one of many needed steps to create healthier environments that are more supportive of their mental health and well-being.”– Moira Szilagyi, MD, PhD, FAAP, President, American Academy of Pediatrics.“Children and teens are at the epicenter of a pervasive data-driven marketing system that takes advantage of their inherent developmental vulnerabilities. We agree with President Biden: now is the time for Congress to act and enact safeguards that protect children and teens.  It’s also long overdue for Congress to enact comprehensive legislation that protects parents and other adults from unfair, manipulative, discriminatory and privacy invasive commercial surveillance practices.”  – Katharina Kopp, Ph.D. Policy Director, Center for Digital Democracy."President Biden's powerful State of the Union plea to Congress to hold social media platforms accountable for the ‘national experiment’ they're conducting on our kids and teens could not be more important. It is clear that young people are being harmed by these platforms that continue to prioritize profits over the wellbeing of its youngest users. Children and teens' mental health is at stake. Congress and the Administration must act now to pass legislation to protect children’s and teens' privacy and well-being online." – Jim Steyer, Founder and CEO, Common Sense.“Online protections for children are woefully outdated and it's clear tech companies are more interested in profiting off of vulnerable children than taking steps to prevent them from getting hurt on their platforms. American kids are facing a mental health crisis partly fueled by social media and parents are unable to go it alone against these billion dollar companies. We need Congress to update COPPA, end predatory data collection on children, and regulate design practices that are contributing to social media addiction, mental health disorders, and even death.”– Justin Ruben, Co-Founder and Co-Director, ParentsTogether."A business model built on extracting our attention at the cost of our well being is bad for everyone, but especially bad for children. No one knows this better than young people themselves, many of whom write to us daily about the ways in which Big Social is degrading their mental health. Left unregulated, Big Social will put profits over people every time. It's time to put our kids first. We urge Congress to act swiftly and enact reforms like strengthening privacy, banning surveillance advertising, and ending algorithmic discrimination for kids so we can begin to build a digital world that supports, rather than demotes child wellbeing." – Julia Hoppock, Partnerships Director, The Social Dilemma, Exposure Labs.# # #press_release_letter_to_congress_updated_embargo_to_3_22.pdf, letter_to_congress_re_children_online_3_22_22.pdf

Groups urge Congress to stop Big Tech’s manipulation of young people BOSTON – Thursday, December 2, 2021 – Today a coalition of leading advocacy groups launched Designed With Kids in Mind, a campaign demanding a design code in the US to protect young people from online manipulation and harm. The campaign seeks to secure protections for US children and teens similar to the UK’s groundbreaking Age-Appropriate Design Code (AADC), which went into effect earlier this year. The campaign brings together leading advocates for child development, privacy, and a healthier digital media environment, including Fairplay, Accountable Tech, American Academy of Pediatrics, Center for Digital Democracy, Center for Humane Technology, Common Sense, ParentsTogether, RAINN, and Exposure Labs, creators of The Social Dilemma. The coalition will advocate for legislation and new Federal Trade Commission rules that protect children and teens from a business model that puts young people at risk by prioritizing data collection and engagement.The coalition has launched a website that explains how many of the most pressing problems faced by young people online are directly linked to platform’s design choices. They cite features that benefit platforms at the expense of young people’s wellbeing, such as: Autoplay: increases time on platforms, and excessive time on screens is linked to mental health challenges, physical risks like less sleep, and promotes family conflict.Algorithmic recommendations: risks exposure to self-harm, racist content, pornography, and mis/disinformation.Location tracking: makes it easier for strangers to track and contact children.Nudges to share: leads to loss of privacy, risks of sexual predation and identity theft.The coalition is promoting three bills which would represent a big step forward in protecting US children and teens online: the Children and Teens’ Online Privacy Protection Act S.1628; the Kids Internet Design and Safety (KIDS) Act S. 2918; and the Protecting the Information of our Vulnerable Children and Youth (PRIVCY) Act H.R. 4801. Taken together, these bills would expand privacy protections to teens for the first time and incorporate key elements of the UK’s AADC, such as requiring the best interest of children to be a primary design consideration for services likely to be accessed by young people. The legislation backed by the coalition would also protect children and teens from manipulative design features and harmful data processing. Members of the coalition on the urgent need for a US Design Code to protect children and teens:Josh Golin, Executive Director, Fairplay:We need an internet that helps children learn, connect, and play without exploiting their developmental vulnerabilities; respects their need for privacy and safety; helps young children disconnect at the appropriate time rather than manipulating them into spending even more time online; and prioritizes surfacing high-quality content instead of maximizing engagement. The UK’s Age-Appropriate Design Code took an important step towards creating that internet, and children and teens in the US deserve the same protections and opportunities. It’s time for Congress and regulators to insist that children come before Big Tech’s profits.Nicole Gill, Co-Founder and Executive Director of Accountable Tech:You would never put your child in a car seat that wasn't designed for them and met all safety standards, but that's what we do every day when our children go online using a network of apps and websites that were never designed with them in mind. Our children should be free to learn, play, and connect online without manipulative platforms like Facebook and Google's YouTube influencing their every choice. We need an age appropriate design code that puts kids and families first and protects young people from the exploitative practices and the perverse incentives of social media.Lee Savio Beers, MD, FAAP, President of the American Academy of Pediatrics:The American Academy of Pediatrics is proud to join this effort to ensure digital spaces are safe for children and supportive of their healthy development. It is in our power to create a digital ecosystem that works better for children and families; legislative change to protect children is long overdue. We must be bold in our thinking and ensure that government action on technology addresses the most concerning industry practices while preserving the positive aspects of technology for young people.Jeff Chester, Executive Director, Center for Digital Democracy:The “Big Tech” companies have long treated young people as just a means to generate vast profits – creating apps, videos and games designed to hook them to an online world designed to surveil and manipulate them. It’s time to stop children and teens from being victimized by the digital media industry. Congress and the Federal Trade Commission should adopt commonsense safeguards that ensure America’s youth reap all the benefits of the online world without having to constantly expose themselves to the risks.Randima Fernando, Executive Director, Center for Humane Technology:We need technology that respects the incredible potential – and the incredible vulnerability – of our kids' minds. And that should guide technology for adults, who can benefit from those same improvements.Irene Ly, Policy Counsel, Common Sense:This campaign acknowledges harmful features of online platforms and apps like autoplay, algorithms amplifying harmful content, and location tracking for what they are: intentional design choices. For too long, online platforms and apps have chosen to exploit children’s vulnerabilities through these manipulative design features. Common Sense has long supported designing online spaces with kids in mind, and strongly supports US rules that would finally require companies to put kids’ well-being first.Julia Hoppock, The Social Dilemma Partnerships Director, Exposure Labs:For too long, Big Social has put profits over people. It's time to put our kids first and build an online world that works for them.Dalia Hashad, Online Safety Director, ParentsTogether: From depression to bullying to sexual exploitation, tech companies knowingly expose children to unacceptable harms because it makes the platforms billions in profit. It's time to put kids first.Scott Berkowitz, President of RAINN (Rape, Abuse & Incest National Network):Child exploitation has reached crisis levels, and our reliance on technology has left children increasingly vulnerable. On our hotline, we hear from children every day who have been victimized through technology. An age-appropriate design code will provide overdue safeguards for children across the U.S.launch_-_design_code_to_protect_kids_online.pdf

Press Statement, Center for Digital Democracy (CDD) and Campaign for a Commercial-Free Childhood (CCFC), 12-14-20 Today, the Federal Trade Commission announced (link is external) it will use its to 6(b) authority to launch a major new study into the data collection practices of nine major tech platforms and companies: ByteDance (TikTok), Amazon, Discord, Facebook, Reddit, Snap, Twitter, WhatsApp and YouTube. The Commission’s study includes a section on children and teens. In December, 2019, the Campaign for a Commercial-Free Childhood (CCFC), Center for Digital Democracy (CDD) and their attorneys at Georgetown Law’s Institute for Public Representation urged the Commission to use its 6(b) authority to better understand how tech companies collect and use data from children. Twenty-seven consumer and child advocacy organizations joined that request. Below are statements from CDD and CCFC on today’s announcement. Josh Golin, Executive Director, CCFC: “We are extremely pleased that the FTC will be taking a hard look at how platforms like TikTok, Snap, and YouTube collect and use young people’s data. These 6(b) studies will provide a much-needed window into the opaque data practices that have a profound impact on young people’s wellbeing. This much-needed study will not only provide critical public education, but lay the groundwork for evidence-based policies that protect young people’s privacy and vulnerabilities when they use online services to connect, learn, and play.” Jeff Chester, Executive Director, CDD: "The FTC is finally holding the social media and online video giants accountable, by requiring leading companies to reveal how they stealthily gather and use information that impacts our privacy and autonomy. It is especially important the commission is concerned about also protecting teens— who are the targets of a sophisticated and pervasive marketing system designed to influence their behaviors for monetization purposes." For questions, please contact: jeff@democraticmedia.org (link sends e-mail) See also: https://www.markey.senate.gov/news/press-releases/senator-markey-stateme... (link is external)

October 9, 2020 Susan Wojciki CEO YouTube 901 Cherry Avenue San Bruno, CA 94006 Dear Ms. Wojciki: We commend Google/YouTube’s plan to create a $100 million investment fund for children’s content, announced in 2019 following the FTC settlement to address YouTube’s violations of COPPA. This fund has the potential to stamp an imprint on children’s online content which will have influence for years to come. We ask that YouTube adopt policies to ensure this fund will operate in the best interests of children worldwide. The programming supported by the fund should: Reflect the perspectives and interests of children from different countries and cultures Underwrite content makers who are diverse and independent, with at least 50% of funding dedicated to historically underrepresented communities Promote educational content and content which reflects the highest values of civil society, including diversity Not support content which promotes commercialism Facilitate union representation of creators of scripted and nonfiction content for YouTube Be advised by a team of leading independent experts who can ensure programming is commissioned that truly serves the educational, civic, and developmental needs of young people. As the leading global online destination for many millions of children, as well as the most powerful digital marketing entity, Google should be at the forefront of providing financial resources for quality content that is innovative, takes creative risks, and supports emerging program makers from many different backgrounds. For example, programming supported by the fund should reflect a major commitment to diversity by commissioning producers from around the world who represent diverse cultures and perspectives. The fund is also an opportunity for Google to make a significant contribution to the development of a distinct programming vision for young people that is primarily driven to foster their wellbeing. We urge Google to only fund programming free of commercial content, including influencer marketing, product and brand integration, and licensed characters or products. In addition, each program or series should have a robust release window that provides access to all children without being required to view digital advertising and other forms of commercial marketing. The expert commissioning board we advise you to adopt will help ensure that the fund will operate fairly, and help eliminate potential conflict of interests. Operating the fund using these principles will allow YouTube to cement its place as a leader in children’s programming and more importantly, make a world of difference—ensuring that time spent watching YouTube will enrich children. We stand ready to confer with you on these suggestions and your development of the fund, and would welcome the opportunity to meet with you in the near future to discuss these items. Sincerely, Jeffrey Chester, Executive Director, Center for Digital Democracy Jessica J. González, Co-CEO, Free Press Josh Golin, Executive Director, Campaign for a Commercial-Free Childhood Justin Ruben, Co-Director, ParentsTogether Lowell Peterson, Executive Director, Writers Guild of America, East, AFL-CIO

The Campaign for Commercial-Free Childhood (CCFC) and CDD filed comments with the UN’s Special Rapporteur on privacy, as part of a consultation designed to propose global safeguards for young people online. Both CCFC and CDD, along with allies in the U.S. and throughout the world, are working to advance stronger international protections for young people, especially related to their privacy and the impacts that digital marketing has on their development.