Interview objective: Avoid treating a generic age label as a substitute for an audience assessment.
Put this to: Michelle W. Cohen, US counsel and the publisher’s product lead.
Why it matters to buyers: FTC guidance describes COPPA coverage for child-directed services and certain services with actual knowledge of collecting children’s personal information. Separately, the UK Gambling Commission’s affiliate guidance distinguishes consumer-facing free-play advertising from B2B demonstrations. That UK guidance must not be imported as a universal US age-verification rule. (ftc.gov)
Draft framing — a good answer should cover:
- The site’s actual audience, presentation, acquisition channels and intended markets.
- Whether COPPA applies and how the amended requirements affect the proposed integration.
- Any distinct state, promotional, supplier-contract or cross-border requirements.
- Whether an age-control mechanism introduces additional data collection and retention obligations.
- How a denied or uncertain age outcome affects game loading, tracking and referrals.
Sharp follow-up: “Which requirement are you satisfying with this control, and what evidence demonstrates that it is effective for that purpose?”
Buyer output: An audience-and-age decision record, not an unexplained default of ‘18+’ or ‘21+’.
The interview should address the already-passed 22 April 2026 compliance date for most COPPA amendments where the publisher is covered. (govinfo.gov)
Expert quote — awaiting interview: [Approved quotation and attribution.]