FTC Pushed to Investigate Marketing in Android Kids Apps

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FTC Pushed to Investigate Marketing in Android Kids Apps

Groups say some in-app ad elements are deceptive


October 30, 2018


Armed with a new study on kids and advertising apps, a group of advocates asked the FCC to investigate Android apps targeted to kids five and under, alleging many are unfair and/or deceptive.

The FCC is empowered to punish unfair or deceptive conduct through its Sec. 5 authority.

The groups want the commission to hold app developers to account for those alleged unfair and deceptive practices (disguising ads as being part of a game, for example), including marketing the apps that require in-app purchases as “free” and manipulating children to access advertising.

The study is from the University of Michigan and C.S. Mott Children’s Hospital. It looked at 135 kids apps and found various “troubling” practices including ads disguised as game play, ‘beloved” characters encouraging kids to make in-app purchases (so-called “host selling).

The study, of family mobile device use, reviewed 39 apps (35 free and 4 paid), and 96 (50 free and 46 paid) of the “most popular apps,” which it defined as the apps for ages 5 and under most frequently downloaded from the Google Play store. The majority of the apps had been downloaded at last 10 million times, according to the study.

The study found that 95% of the apps contained at least one type of advertising, much of it embedded in the games in what was described as “manipulative” ways, such as requiring viewing ads to unlock game items or trying to get kids to pay for game items or buy a paid version of the game. 

“This groundbreaking study demonstrates that popular apps for preschoolers are rife with marketing that takes unfair advantage of children’s developmental vulnerabilities,” said CCFC Executive Director Josh Golin in a statement. “Disguising ads as part of game play and using cartoon characters to manipulate children into making in-app purchases is not only unethical, but illegal. We urge the FTC to take swift and decisive action to hold app developers accountable for their unfair and deceptive marketing.”

Lead groups on the letter were the Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) (with an assist from the
Communications & Technology Law Clinic in the Institute for Public Representation (“IPR”) at Georgetown University Law Center.

Signing on to the letter were Badass Teachers Association, Centre for Child Honouring, Color of Change, Consumer Action, Consumer Federation of America, Consumer Watchdog, Corporate Accountability, Defending the Early Years, Electronic Privacy Information Center, Media Education Foundation, New Dream, Open MIC (Open Media and Information Companies Initiative), Parent Coalition for Student Privacy, Parents Across America, Parents Television Council, Peace Educators Allied for Children Everywhere (P.E.A.C.E.), Public Citizen, the Story of Stuff, TRUCE (Teachers Resisting Unhealthy Childhood Entertainment), and USPIRG.

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