On Friday, November 22, 2013, the New Jersey Attorney General’s office announced that it settled alleged violations of the Children’s Online Privacy Protection Act (COPPA) with app developer, Dokogeo, Inc. This is the second such COPPA parens patriae action by the New Jersey Attorney General. Dokogeo, a San Francisco–based app developer, makes Dokobots, a geolocation app that leads users on a scavenger hunt through which they gather photos and notes from people they meet. The Attorney General argued that the app and its associated website violated COPPA, the Federal Trade Commission’s (FTC) amended COPPA Rule, which became effective in July 2013, and New Jersey’s Consumer Fraud CFA (CFA) by failing to age-screen visitors and obtain verifiable parental consent to collect personal information from children under 13.
Dokogeo claimed the app is not directed at children under the age of 13, and so does not violate COPPA or related laws. The Attorney General argued that the app was aimed at children and adults, pointing to animated cartoon characters and a storyline where users collect photos and location information to guide the “DokoStar Exploratory Fleet Mothership” to safety. The complaint noted that the app is rated 4+ in the app store. The Attorney General also argued that there was no written notice on the app stating that it is only intended for use by users older than 13.
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