UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

Office of the Chair

1

Remarks of Chair Lina M. Khan

As Prepared for Delivery

Protecting Kids from Stealth Advertising in Digital Media

October 19, 2022

Good morning. Welcome everybody to today’s event. We have a phenomenal lineup of 

experts here to discuss a critical topic, and I’m so looking forward to today’s discussions

Advertising has changed a lot over the last few decades. It used to be, every kid watching 

a TV show would see the same commercial. It wasn’t hard for parents to keep an eye on the ads 

their children were seeing. But the rise of social media and targeted advertising changed 

everything. Now, every child is an audience of one.

Most young people today are digital natives. They were not around for life before the 

internet and the proliferation of digital technologies. They interact with digital technologies 

almost intuitively. In some ways, this is great news. Kids today have the natural competency to 

take advantage of new digital tools in a way that grownups can only dream of. But it also carries 

serious risks. When kids interact with digital media, they’re exposed to an array of marketing 

practices that blur the line between advertising and entertainment. That’s an especially serious 

issue when we’re talking about young people. As today’s speakers and panelists will explain, 

developing brains are more susceptible to deceptive or harmful practices. Both the immediate 

and long-term effects can be significant.

As digital media becomes more embedded in our daily lives, kids are interacting more 

and more with commercial content. Research indicates that some older kids may see over a 

thousand ads per day.1 What particularly concerns the FTC is the fact that kids often can’t tell the 

difference between ads and organic content. Some forms of advertising are intentionally 

designed to exploit kids’ insecurities for commercial gain. Children and teens can end up 

engaging in commercial transactions without realizing it. They may provide personal information 

without understanding the privacy risks. When stealth advertising is combined with concerning 

content like gambling or e-cigarettes, the risks can be even greater.

Today’s event will examine these concerns and the possible paths forward. Our panelists 

will unpack the privacy, psychological, physical, economic, and other harm that can arise from 

predatory advertising directed at children. And they’ll explore whether existing regulatory 

regimes are up to the task of protecting kids and families from those harms.

1 GLOBAL ACTION PLAN, KIDS FOR SALE: ONLINE ADVERTISING & THE MANIPULATION OF CHILDREN 10 (2020), 

https://www.globalactionplan.org.uk/files/kids_for_sale.pdf.
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First, there will be a presentation by Mamie Kresses of BBB National Programs. Mamie 

will discuss examples of ads that kids encounter online that blend into surrounding content. Her 

presentation will be followed by a question-and-answer session with Tawana Davis, an Assistant 

Director of our Division of Advertising Practices.

The remainder of the day will be filled with panel discussions on key issues surrounding 

kids and digital advertising. The first panel includes experts from a number of disciplines. 

They’ll discuss children’s cognitive abilities across different ages and developmental stages. And 

they’ll connect that to key questions around how kids process and perceive advertising. In the 

second panel, researchers and practitioners will discuss how kids actually interact with the 

current advertising landscape. They’ll also describe the harms caused by the increasingly blurred 

line between ads and organic content, and potential mitigating factors. The final panel will be 

more forward-looking. We will hear from a variety of stakeholders about potential interventions 

and remedies.

Given the complexities of these issues, there may not be one silver bullet to mitigate the 

risk and harms posed to children and teens. As today’s discussions will demonstrate, we will 

need a combination of interventions to produce effective outcomes. The FTC is currently 

exploring whether to update its rule implementing the Children’s Online Privacy Protection Act.2

The last time we revised that rule was 2013, and a lot has changed since then. We’re also 

soliciting comments for a proposed rulemaking on commercial surveillance more broadly.3In the 

meantime, we will continue to aggressively pursue enforcement actions using existing FTC legal 

authorities. And we will support Congressional action that aims to bolster our efforts. We look 

forward to working with consumer groups and other key stakeholders to deepen our 

understanding of the issues and improve our efforts to protect children and raise awareness for 

parents and teachers.

Thank you all again for coming today, and thanks to our panelists for sharing their time 

with us. Now I’ll hand it off to Tawana and Mamie.

***

2 Press Release, Fed. Trade Comm’n, FTC Seeks Comments on Children’s Online Privacy Protection Act Rule (July 

25, 2019), https://www.ftc.gov/news-events/news/press-releases/2019/07/ftc-seeks-comments-childrens-onlineprivacy-protection-act-rule.

3 Trade Regulation Rule on Commercial Surveillance and Data Security, 87 Fed. Reg. 51,273 (Aug. 22, 2022).