Project 2025 Tracker / What’s done, what’s next

30. Federal Trade Commission · Notable

Bring unfair trade practice cases over children's contracts without parental consent

Partially done

875 30. Federal Trade Commission

“The FTC can and should institute unfair trade practices proceedings against entities that enter into contracts with children without parental consent.”

What has happened

  1. Partially done

    In the Sendit case the Commission charged the operator of an anonymous-messaging app and its CEO with, among other things, unfairly using fake messages to trick child and teen users into buying premium subscriptions and failing to disclose the subscription terms — an unfair-practices count about children being pushed into paid contracts. It sits inside a run of 2025 children's proceedings (Disney, 2025-09-02, $10 million; the Apitor robot-toy action, 2025-09-03) whose central charge is collecting children's data without verifiable parental consent. What is missing is the Quote's own theory: no proceeding treats entering a contract with a child without parental consent as the unfair practice.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The alternative reading is not started under §3b’s “progress is measured on this ask”: every in-window children’s proceeding is a COPPA data-collection case, and the Quote is about contracts. partial was chosen because the Sendit complaint does carry an unfairness count about children being manoeuvred into paid subscriptions, which is a piece of the ask delivered by a different route. Recorded in the spot-check register.
  • The nearest case on the Quote’s own facts — the Genshin Impact order banning lootbox sales to teens under 16 without parental consent — is dated 2025-01-17 and falls outside the window.
  • Congress’s answer, the App Store Accountability Act (S. 1586, referred; H.R. 3149, forwarded by subcommittee 2025-12-11), would require parental consent for minors’ app-store contracts. Under §3b committee action is not a rung, and in any case it is a bill, not an FTC proceeding.
Action
issue
Object
unfair trade practices proceedings against firms contracting with children
ID
2243