[At-Large] Facebook on [U.S. Federal] Children's Online Privacy Protection Act (COPPA)

Carlton Samuels carlton.samuels at gmail.com
Tue Oct 2 16:22:12 UTC 2012

.....Facebook is in a dogfight with the FCC about proposal to change
liability re website operator's use - or allowing the use - of plugins.
U.S. Congress delegated rule making to the FCC for implementing COPPA.

Facebook says, among other things,  "a '*like*' counts as free speech"!

The letter is, IMO, quite a good example of an advocacy piece that covers
every inch of ground it sees. Follows the maxim attributed to a very
successful trial lawyer from Texas: 'when the facts are against your
position, plead the law. And when the law don't cooperate, plead the
facts'. Or, words to that effect.

The filing is attached.  Read an opinion piece on it here:


- Carlton

Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*
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