Wiley Rein Fearful of Proposed Policies to Protect Kids Privacy/the Digital Scrooge Tries to Save the Data Collection Past

The folks over at Wiley Rein--the Washington legal and lobbying firm which has long represented the largest media companies--are apparently apoplectic that the good people at the FTC want to do a better job in protecting the privacy of children under 13.  See their missive below on the FTC's proposed changes to COPPA.  Wiley appears to want to keep the FTC from making the appropriate policy changes that nearly everyone familiar with the digital data collection, profiling and targeting marketplace agree should be done.   I suppose Dick Wiley will be suiting up as the Digital Scrooge this Christmas.  Perhaps we can ask Santa to pass out some lie detectors to Wiley's digital media clients, so they can be quizzed on whether they use IP addresses, cookies and the like for behavioral targeting and other privacy implicated tactics. 
 
excerpt:  The FTC has extended the comment deadline to December 23.  Thus, companies have time to communicate to the agency that the proposed children's privacy rules must be clarified in order to prevent unintentional damage to standard online business models and general online liability protections.  Websites, online advertising, social networking ventures and mobile applications potentially could be affected....The FTC's drive on children's privacy does not occur in a vacuum.  Indeed, the COPPA rulemaking echoes the privacy "wish list" of the FTC staff presented in its December 2010 Preliminary Report concerning general online consumer privacy (a follow-up report is expected by the end of this year).  Similarities are troubling, because components of the framework for children's privacy are susceptible to becoming privacy benchmarks generally, due to the FTC's considerable informal influence over acceptable practices.
For example, businesses should be concerned that IP addresses and cookie identifiers-presently considered unregulated, anonymous data-would become "individually identifying" and thus subject to the new COPPA rule.  These identifiers, are fundamental to online advertising, which underwrites the free and affordable online services offered by companies.  The Commission is targeting these identifiers, although it admits it is "not aware of any operator directing online advertising to children."  Should industry accede to the idea that these strings of numbers "personally identify" children, it will be difficult to argue that they do not also "personally identify" adults.  In other words, the COPPA rulemaking could provide collateral support for the FTC to regulate online advertising generally.  Indeed, the FTC staff has told Congress that it is addressing the children's rule in the context of its broader views on privacy.