Reasons for Settlement

   This statement accompanies the Consent Decree executed by defendant
   Hershey Foods Corporation, in settlement of an action brought to
   recover penalties and other equitable relief from the defendant for
   engaging in acts or practices in violation of the Commission's
   Children's Online Privacy Protection Rule, 16 C.F.R. Part 312 (the
   "Rule").

   Pursuant to Section 5(m)(3) of the Federal Trade Commission Act, as
   amended (15 U.S.C. § 45(m)(3)), the Commission hereby sets forth its
   reasons for settlement by entry of a Consent Decree and injunction:

     On the basis of the allegations contained in the attached
     Complaint, the Commission believes that the payment of $85,000 in
     civil penalties by the defendant constitutes an appropriate amount
     upon which to base a settlement. The amount should assure
     compliance with the law by defendant and by others who engage in
     practices covered by the Rule. Further, defendant is permanently
     enjoined from engaging in acts or practices that are prohibited by
     the Rule. With the entry of such Consent Decree the time and
     expense of litigation will be avoided.

   For the foregoing reasons, the Commission believes that the settlement
   by entry of the attached Consent Decree with Hershey Foods Corporation
   is justified and well within the public interest.

   Thomas A. Marino
   United States Attorney

   By:

   Assistant United States Attorney/Lead Counsel
   Middle District of Pennsylvania
   Federal Building, Suite 220
   228 Walnut Street
   Harrisburg, Pennsylvania 17108-1754
   (717) 221-4482

                    IN THE UNITED STATES DISTRICT COURT
                  FOR THE MIDDLE DISTRICT OF PENNSYLVANIA



   UNITED STATES OF AMERICA, Plaintiff,

   v.

   HERSHEY FOODS CORPORATION, a corporation, Defendant




   Civil Action No.

   COMPLAINT FOR CIVIL PENALTIES, INJUNCTIVE, AND OTHER RELIEF

   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), and 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), and 56(a), to
     obtain monetary civil penalties, a permanent injunction, and other
      equitable relief for defendant's violations of the 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), 1345, and 1355, and under 15 U.S.C. §§ 45(m)(1)(A),

   Thomas A. Marino
   United States Attorney

   By:

   Assistant United States Attorney/Lead Counsel
   Middle District of Pennsylvania
   Federal Building, Suite 220
   228 Walnut Street
   Harrisburg, Pennsylvania 17108-1754
   (717) 221-4482

                    IN THE UNITED STATES DISTRICT COURT
                  FOR THE MIDDLE DISTRICT OF PENNSYLVANIA




   UNITED STATES OF AMERICA, Plaintiff,

   v.

   HERSHEY FOODS CORPORATION, a corporation, Defendant.




   Civil Action No.
   CONSENT DECREE AND ORDER FOR CIVIL PENALTIES, INJUNCTIVE, AND OTHER
   RELIEF

   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 or
   that the facts as alleged in the Complaint, other than the
   jurisdictional facts, are true;

   THEREFORE, on the joint motion of plaintiff and defendant, it is
   hereby ORDERED, ADJUDGED, and DECREED as follows:

   1. This Court has jurisdiction of the subject matter and of the
   parties.

   2. The Complaint states a claim upon which relief may be granted