The FTC is considering modifications to the COPPA Rule. In this supplemental notice of proposed rulemaking, the FTC has proposed modifying the Rule’s definition of “operator,” “Web site or online service directed to children”, “personal information,” and “support for internal operations” to impose more restrictive rules on what personal information can be collected about children and who is allowed to collect this information. In particular, this would restrict targeted advertising on websites directed at children under the age of 13. As described in this filing, ITIF believes the current effort to create more restrictions on the collection and use of information about children is misguided and likely leaves children worse off. Rather than impose additional rules on website operators, the FTC should instead explore ways to foster more development of child-directed sites and services on the Internet using market-friendly methods.