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1
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EXHIBITS A-E
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EXTRACTED KEY WORDS
WEB SITE COOKIES CLUB MEMBERSHIP GUESTS PARENTS EXHIBIT ONLINE AGREEMENT PRIVACY SHOPPING PURPOSES SITE SIGNIFIES PURSE PROTECT REQUIRF POSTING YOUNGER INTERNET SERVERS SECURITY PROMOTION MARKETING PURPOSES DISCLOSE GUARDIAN BROWSER GAME FRIENDS CHARACTERS |
day, November 6, 2: 2'
;::, `/ Activate your free time! Check out some cool
eason!
z;:,,
._. All new Club Chronicles is in. Have a !ook!
.-_
..) I
._ Play the new version of the Cpncentratlon Game
`-, ._- Read a beautlful tribute to a friend. Read
ctlon.
-.,
a..,
_, Ready to play? We are and so IS our new Ga!!~@
.- .,
..,I ._ Cool, Free downloads... ~kL!WlLQL&~
,.-,I
. . . AlI new characters! Click here to meet them!
w friends have
Chh Lisa Frank
Page 1 of 1
Exhibit B I
This is your chance to join the hippest,
club around...
Club Lisa Frank! All you have to do
re, and you will
be able to buy a membership online!
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2
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COMPLAINT
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EXTRACTED KEY WORDS
VIOLATION PERSONAL INFORMATION PARENTS WEBSITE PRACTICES CIVIL PENALTIES DISCLOSURE DEFENDANT FTC ACT COMPLAINT ONLINE RELIEF INJUNCTION PRIVACY CONSENT SHOPPING EXHIBIT REGISTRATION FORM HYPERLINK PLAINTIFF ONLINE PRIVACY PROTECTION COURT LISA FRANK FEDERAL TRADE COMMISSION UNITED STATES COMMERCE COPPA PRIVACY POLICY DECEPTIVE ACT |
KENNETH E. MELSON
United States Attorney
By:
Assistant United States Attorney
2100 Jamieson Ave.
Alexandria, VA 22214
(703) 299-3700
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
UNITED STATES OF AMERICA, Civil Action No. _______________
Plaintiff, COMPLAINT FOR CIVIL
PENALTIES, INJUNCTIVE, AND
v. OTHER RELIEF
LISA FRANK, INC.,
a corporation,
Defendant.
Plaintiff, the United States of America, acting upon notification and authorization to the
Attorney General by the Federal Trade Commission ("FTC" or "Commission"), for its Complaint
alleges that:
1. Plaintiff brings this action under Sections 1303(c) and 1306(d) of the Children's
Online Privacy Protection Act of 1998 ("COPPA"), 15 U.S.C. §§ 6501-6506, §§ 6502(c),
6505(d), and Sections 5(a)(1), 5(m)(1)(A), 13(b), and 16(a) of the Federal Trade Commission
Act ("FTC Act"), 15 U.S.C. §§ 41-58, §§ 45(a)(1), 45(m)(1)(A), 53(b), 56(a), to obtain monetary
civil penalties, a permanent injunction, and other equitable relief for defendant's violations of
Commission's Children's Online Privacy Protection Rule (the "Rule"), 16 C.F.R. Part 312.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this matter under 28 U.S.C. §§ 1331, 1337(a),
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3
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CONSENT DECREE
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EXTRACTED KEY WORDS
DEFENDANT TRADE COMMISSION COMPLIANCE SUCCESSORS CIVIL PENALTIES RELIEF FEDERAL TRADE PERSONAL INFORMATION PRIVACY STATEMENT SETTING ONLINE ENTRY UNITED STATES ATTORNEYS PARENTS REPRESENTATIVES PROTECTION WEBSITE DIRECTORS OFFICERS EMPLOYEES COMPLIANCE GUIDE LISA FRANK HEREBY ACT AGENTS PURPOSES DISCLOSURE PARAGRAPH |
KENNETH E. MELSON
United States Attorney
By:
Assistant United States Attorney
2100 Jamieson Ave.
Alexandria, VA 22314
(703) 299-3700
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
UNITED STATES OF AMERICA, Civil Action No. _______________
Plaintiff, CONSENT DECREE AND ORDER
FOR CIVIL PENALTIES,
v. INJUNCTIVE, AND OTHER RELIEF
LISA FRANK, INC.,
a corporation,
Defendant.
WHEREAS plaintiff, the United States of America, has commenced this action by filing
the Complaint herein; defendant has waived service of the Summons and Complaint; the parties
have been represented by the attorneys whose names appear hereafter; and the parties have
agreed to settlement of this action upon the following terms and conditions, without adjudication
of any issue of fact or law and without defendant admitting liability for any of the matters alleged
in the Complaint;
THEREFORE, on the joint motion of plaintiff and defendant, it is hereby ORDERED,
ADJUDGED, and DECREED as follows:
1. This Court has jurisdiction over the subject matter and of the parties.
2. The Complaint states a claim upon which relief may be granted against the
defendant under Sections 1303(c) and 1306(d) of the Children's Online Privacy Protection Act of
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