Partner Janis Kestenbaum was quoted in "Far-Reaching Google and YouTube Settlement Offers COPPA Compliance Lessons" a Cybersecurity Law Report* article outlining the ramifications of the FTC and New York AG's settlement against YouTube over allegations of harvesting children's personal data. 

“In 2013, in the Federal Register statement accompanying the FTC’s amended COPPA Rule, the FTC described YouTube as a ‘general audience’ site and suggested YouTube would be subject to COPPA only to the extent it had actual knowledge that it was collecting personal information from a child that was on the site, like any other general audience site,” she said, pointing out that, in contrast, the Complaint “describes YouTube as akin to a third-party ‘plug-in’ from a COPPA perspective vis-à-vis the content posted on the site, some of which may be child-directed.”

*Subscription-based publication.