[Federal Register Volume 80, Number 36 (Tuesday, February 24, 2015)]
[Notices]
[Pages 9720-9723]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-03672]


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FEDERAL TRADE COMMISSION


Agency Information Collection Activities; Submission for OMB 
Review; Comment Request

AGENCY: Federal Trade Commission (``Commission'' or ``FTC'').

ACTION: Notice.

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SUMMARY: The FTC intends to conduct an evaluation of Admongo, its 
advertising literacy program for children ages 8-12. The evaluation 
will involve a randomized controlled trial of the Admongo online game, 
using an Internet panel recruited by a market research company. This 
research will be conducted to further the FTC's mission of protecting 
consumers from unfair and deceptive marketing. The information 
collection requirements described below

[[Page 9721]]

are being submitted to the Office of Management and Budget (``OMB'') 
for review as required by the Paperwork Reduction Act (``PRA'').

DATES: Comments must be submitted on or before March 26, 2015.

ADDRESSES: Interested parties may file a comment online or on paper, by 
following the instructions in the Request for Comment part of the 
SUPPLEMENTARY INFORMATION section below. Write ``Admongo Evaluation, 
FTC File No. P085200'' on your comment, and file your comment online at 
https://ftcpublic.commentworks.com/ftc/admongoevaluationpra2, by 
following the instructions on the web-based form. If you prefer to file 
your comment on paper, mail your comment to the following address: 
Federal Trade Commission, Office of the Secretary, 600 Pennsylvania 
Avenue NW., Suite CC-5610 (Annex J), Washington, DC 20580, or deliver 
your comment to the following address: Federal Trade Commission, Office 
of the Secretary, Constitution Center, 400 7th Street SW., 5th Floor, 
Suite 5610 (Annex J), Washington, DC 20024.

FOR FURTHER INFORMATION CONTACT: Requests for additional information 
should be addressed to David Givens, Economist, Bureau of Economics, 
Federal Trade Commission, 600 Pennsylvania Avenue NW., Washington, DC 
20580. Telephone: (202) 326-3397.

SUPPLEMENTARY INFORMATION:

I. Background

    As the nation's consumer protection agency, the FTC is responsible 
for enforcing laws that prohibit unfair and deceptive advertising and 
marketing practices. Part of this mission involves educating consumers, 
including young consumers. In April 2010, the FTC launched a youth-
directed, multi-media advertising literacy campaign called Admongo and 
distributed accompanying lesson plans to 100,000 educators in every 
U.S. public school with a fifth or sixth grade class. The Admongo 
program aims to help children from 8 to 12 become more discerning 
consumers of marketing information. The program has three broad 
objectives: (1) Raising awareness of advertising and marketing 
messages; (2) teaching critical thinking skills that will help children 
analyze and interpret advertisements; and (3) demonstrating the 
benefits of being an informed consumer. The program is designed to 
teach students specific skills: How to identify ads, how to identify 
the ways advertisers target certain groups of consumers, how to spot 
persuasive techniques commonly employed by ads, and how to apply an 
understanding of advertising techniques to make smarter purchase 
decisions. The campaign includes an online game, in-school lesson 
plans, training videos for teachers, and sample ads that can be used at 
home and in the classroom.
    The public can utilize individual components of Admongo as desired, 
or alternatively, schools can integrate all the components to build a 
cohesive unit on advertising literacy. All materials are free and can 
be viewed at www.admongo.gov.
    The proposed evaluation is designed to assess the impact of the 
Admongo online game. The game is an interactive teaching tool in which 
players advance to higher levels by mastering progressively more 
sophisticated topics in advertising. Players start by identifying ads, 
including logos and product placement; they advance to learning about 
the elements of advertising (graphics, copy, video, and audio) and then 
how advertisers target their ads. The game culminates in players 
creating their own video ad to target a specific audience.
    The proposed evaluation seeks to measure the effect of playing the 
Admongo game on a child's level of advertising literacy, as measured by 
a test specially written for this purpose by FTC staff. The online game 
is the one component of the Admongo program that children can most 
easily discover, engage with, and learn from on their own. Cost 
effectiveness data will enable FTC staff to evaluate both this program 
and the potential use of other similar programs in the future. The FTC 
is particularly interested in the effect of game play on the ability to 
interpret real ads (i.e., to differentiate explicit and implied claims, 
identify particular persuasive techniques, and understand why they were 
chosen, etc.) and the ways in which the game's effect varies by age and 
other family and demographic characteristics.

II. Paperwork Reduction Act

    Under the PRA, 44 U.S.C. 3501-3521, federal agencies must get OMB 
approval for each collection of information they conduct or sponsor. 
``Collection of information'' means agency requests or requirements 
that members of the public submit reports, keep records, or provide 
information to a third party. 44 U.S.C. 3502(3), 5 CFR 1320.3(c).
    On March 3, 2014, the FTC sought public comment on the information 
collection requirements associated with the proposed Admongo evaluation 
study. One comment was received. Pursuant to the OMB regulations, 5 CFR 
part 1320, that implement the PRA, the Commission is providing this 
second opportunity for public comment.

A. Description of the Collection of Information and Proposed Use

    Subject to OMB approval, the FTC will conduct a randomized trial of 
the Admongo online game, involving 800 students, ages 8-12. A market 
research contractor will select students for participation from among 
its existing panelists. Students must have parental permission to 
participate in the evaluation. A randomly selected half of the 
participants will be assigned to a treatment group, and the remaining 
students will be assigned to a control group.
    Treatment students will be instructed to play the Admongo online 
game from their homes for one hour and then to complete an advertising 
literacy test (also online) within the allotted time (20 minutes). To 
ensure that each treatment student's true exposure to the game is 
recorded accurately, her time spent playing (and other measures of her 
performance within the game) will be monitored and logged by the game's 
server. Control students will be instructed to take the test without 
playing the Admongo game. To ensure that control group members do not 
play the game, no mention will be made to these students about the 
existence of Admongo or its connection to the test they are instructed 
to take. To further ensure the integrity of the evaluation, the market 
research company will screen out any panelist who has been exposed to 
Admongo prior to this study.
    Admongo's effect on ad literacy will be estimated from the 
difference in test scores between the control and treatment groups. 
Additional variables measuring demographic, financial, and family 
characteristics of the students, to the extent this information can be 
captured through a screening questionnaire that is administered to 
participants' parents, will increase the precision of Admongo's 
estimated impact and will reveal the influence of these factors on ad 
literacy.
    The sample will be selected to mirror the U.S. population of 8-12 
year-olds along a number of observable dimensions. However, because 
participation in the study is voluntary and based on a marketing 
research Internet panel, the sample may suffer from selection bias and 
may not constitute a nationally representative sample of 8-12 year-old 
American children. Therefore, the estimate of Admongo's impact, derived 
from this sample, will not generalize to the broader audience of all 8-
12 year-old Americans.

[[Page 9722]]

B. Estimated Burden Hours

    The proposed evaluation will involve 800 students ages 8-12. The 
half of the sample assigned to the treatment group will play the 
Admongo online game for one hour and then take a 20-minute advertising 
literacy test immediately afterwards. The time burden for the 
treatment-group totals 533 hours. The half of the sample assigned to 
the control group will take the test without playing the game. The time 
burden for the control group will be only the time required to take the 
test--133 hours in total. Finally, a parent of each participating 
student will be asked to complete a screening questionnaire, estimated 
to take 5 minutes. The aggregate time burden to complete the 
questionnaire totals 67 hours. Therefore, the total time burden for all 
participants equals 733 hours.

C. Estimated Costs

    Participation will not impose any start-up, capital, or labor 
expenditures. The costs to respondents involve only the time expended 
to play the Admongo online game and/or take the online advertising 
literacy test or complete a screening questionnaire. Participation in 
the evaluation is voluntary; respondents are drawn from existing pools 
of Internet panelists (i.e., households that have already indicated 
they are willing and able to take part in Internet research), and 
participants and their parents are free to refuse the invitation to 
participate in any particular study. All students (or their parents) 
will be compensated at the standard rate by the market research company 
that recruits them and runs the experiment. Treatment-group students 
are expected to be compensated more than control-group students due to 
the former group's substantially larger time commitment.

D. Analysis of Comments Received

    The Commission received one comment regarding the proposed 
collection of information. The commenter was a private citizen who 
offered several observations on the proposed study design. First, the 
commenter pointed out that the sample is restricted to children with 
Internet access at home, limiting the generalizability of the results. 
In response, we note that although use of an Internet panel may limit 
generalizability of results, the household-level information collected 
from a screening questionnaire administered to parents should at least 
provide information on how the sample differs from the universe of 
interest. Second, the commenter noted that an evaluation of Admongo's 
effectiveness could be helpful to the FTC's child-directed outreach 
efforts, but that if few children access Admongo, then a study of its 
effectiveness is not needed. In response, we point out that the 
objective of the proposed study is to evaluate the potential 
effectiveness of the Admongo online game, which is independent of the 
actual use of the game. A finding of a beneficial effect could lead to 
wider use of Admongo. Third, the commenter expresses concern that the 
control and treatment groups may differ in ways that will confound 
measurement of Admongo's effect. In response, we note that 
participating students within each age-sex cell will be randomly 
assigned to control and treatment groups, minimizing the chances that 
the groups will differ systematically. And, fourth, the commenter 
suggested asking participants' parents to certify that their children 
have received no assistance when completing the ad literacy test. In 
response, we find this a sensible suggestion and will consult with the 
market research company on the feasibility of obtaining such a 
certification from parents.
E. Request for Comment
    You can file a comment online or on paper. For the Commission to 
consider your comment, we must receive it on or before March 26, 2015. 
Write ``Admongo Evaluation, FTC File No. P085200'' on your comment. 
Your comment, including your name and your state, will be placed on the 
public record of this proceeding, including, to the extent practicable, 
on the public Commission Web site, at http://www.ftc.gov/os/publiccomments.shtm. As a matter of discretion, the Commission tries to 
remove individuals' home contact information from comments before 
placing them on the Commission Web site.
    Because your comment will be made public, you are solely 
responsible for making sure that your comment does not include any 
sensitive personal information, like anyone's Social Security number, 
date of birth, driver's license number or other state identification 
number or foreign country equivalent, passport number, financial 
account number, or credit or debit card number. You are also solely 
responsible for making sure that your comment does not include any 
sensitive health information, like medical records or other 
individually identifiable health information. In addition, do not 
include any ``[t]rade secret or any commercial or financial information 
which . . . is privileged or confidential,'' as discussed in Section 
6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR 
4.10(a)(2). In particular, do not include competitively sensitive 
information such as costs, sales statistics, inventories, formulas, 
patterns, devices, manufacturing processes, or customer names.
    If you want the Commission to give your comment confidential 
treatment, you must file it in paper form, with a request for 
confidential treatment, and you have to follow the procedure explained 
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept 
confidential only if the FTC General Counsel grants your request in 
accordance with the law and the public interest.
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    \1\ In particular, the written request for confidential 
treatment that accompanies the comment must include the factual and 
legal basis for the request, and must identify the specific portions 
of the comment to be withheld from the public record. See FTC Rule 
4.9(c), 16 CFR 4.9(c).
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    Postal mail addressed to the Commission is subject to delay due to 
heightened security screening. As a result, we encourage you to submit 
your comments online. To make sure that the Commission considers your 
online comment, you must file it at http://ftcpublic.commentworks.com/ftc/admongoevaluationpra2, by following the instructions on the web-
based form. If this Notice appears at http://www.regulations.gov/#!home, you also may file a comment through that Web site.
    If you prefer to file your comment on paper, write ``Admongo 
Evaluation, FTC File No. P085200'' on your comment and on the envelope, 
and mail your comment to the following address: Federal Trade 
Commission, Office of the Secretary, 600 Pennsylvania Avenue NW., Suite 
CC-5610 (Annex J), Washington, DC 20580, or deliver your comment to the 
following address: Federal Trade Commission, Office of the Secretary, 
Constitution Center, 400 7th Street SW., 5th Floor, Suite 5610 (Annex 
J), Washington, DC 20024. If possible, submit your paper comment to the 
Commission by courier or overnight service.
    Visit the Commission Web site at http://www.ftc.gov to read this 
Notice and the news release describing it. The FTC Act and other laws 
that the Commission administers permit the collection of public 
comments to consider and use in this proceeding as appropriate. The 
Commission will consider all timely and responsive public comments that 
it receives on or before March 31, 2015. For information on the 
Commission's privacy policy, including routine uses permitted by the

[[Page 9723]]

Privacy Act, see http://www.ftc.gov/ftc/privacy.htm. For supporting 
documentation and other information underlying the PRA discussion in 
this Notice, see http://www.reginfo.gov/public/jsp/PRA/praDashboard.jsp.

David C. Shonka,
Principal Deputy General Counsel.
[FR Doc. 2015-03672 Filed 2-23-15; 8:45 am]
BILLING CODE 6750-01-P