October 9, 2020
901 Cherry Avenue
San Bruno, CA 94006
Dear Ms. Wojciki:
We commend Google/YouTube’s plan to create a $100 million investment fund for children’s content, announced in 2019 following the FTC settlement to address YouTube’s violations of COPPA. This fund has the potential to stamp an imprint on children’s online content which will have influence for years to come. We ask that YouTube adopt policies to ensure this fund will operate in the best interests of children worldwide.
The programming supported by the fund should:
- Reflect the perspectives and interests of children from different countries and cultures
- Underwrite content makers who are diverse and independent, with at least 50% of funding dedicated to historically underrepresented communities
- Promote educational content and content which reflects the highest values of civil society, including diversity
- Not support content which promotes commercialism
- Facilitate union representation of creators of scripted and nonfiction content for YouTube
- Be advised by a team of leading independent experts who can ensure programming is commissioned that truly serves the educational, civic, and developmental needs of young people.
As the leading global online destination for many millions of children, as well as the most powerful digital marketing entity, Google should be at the forefront of providing financial resources for quality content that is innovative, takes creative risks, and supports emerging program makers from many different backgrounds. For example, programming supported by the fund should reflect a major commitment to diversity by commissioning producers from around the world who represent diverse cultures and perspectives.
The fund is also an opportunity for Google to make a significant contribution to the development of a distinct programming vision for young people that is primarily driven to foster their wellbeing. We urge Google to only fund programming free of commercial content, including influencer marketing, product and brand integration, and licensed characters or products. In addition, each program or series should have a robust release window that provides access to all children without being required to view digital advertising and other forms of commercial marketing. The expert commissioning board we advise you to adopt will help ensure that the fund will operate fairly, and help eliminate potential conflict of interests.
Operating the fund using these principles will allow YouTube to cement its place as a leader in children’s programming and more importantly, make a world of difference—ensuring that time spent watching YouTube will enrich children. We stand ready to confer with you on these suggestions and your development of the fund, and would welcome the opportunity to meet with you in the near future to discuss these items.
Jeffrey Chester, Executive Director, Center for Digital Democracy
Jessica J. González, Co-CEO, Free Press
Josh Golin, Executive Director, Campaign for a Commercial-Free Childhood
Justin Ruben, Co-Director, ParentsTogether
Lowell Peterson, Executive Director, Writers Guild of America, East, AFL-CIO