On December 19, 2012, the Federal Trade Commission (“Commission”) announced long-awaited amendments to its rule implementing the Children’s Online Privacy Protection Act (“Rule”). The changes – which take effect on July 1, 2013 – are significant. They alter the scope and obligations of the Rule in a number of ways. We discuss the revisions in greater detail below.

• The Commission revised the Rule’s definition of “personal information” to include more types of data that trigger the Rule’s notice, consent, and other obligations. These include persistent identifiers when used for online behavioral advertising and other purposes not necessary to support the internal operations of the site or online service...