A coalition of consumer groups led by the Center for Digital Democracy, Campaign for a Commercial-Free Childhood (CCFC) and Center for Science in the Public Interest have filed a complaint with the Federal Trade Commission (FTC), alleging that Google’s YouTube Kids application mixes “advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two.” According to the April 7, 2015, press release, the groups also claim that the app promotes several “branded channels” for fast-food and toy companies, as well as “user-generated segments” “that feature toys, candy and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTC’s Endorsement Guidelines.”

Filed on behalf of these consumer groups by Georgetown Law’s Institute for Public Representation, the complaint asks FTC to investigate whether the YouTube Kids app violates Section 5 of the FTC Act. It also requests more information about how Google selects the “recommended” videos associated with delivered content. “It is unclear how the app determines which videos to recommend,” opines the complaint. “Is Google tracking children’s online viewing habits to make the recommendations? If so, has it given direct notice and obtained verifiable parental consent before tracking them as required by the COPPA [Children’s Online Privacy Protection] Rule?”

In particular, the complaint singles out McDonald’s Corp. for purportedly presenting promotional videos “styled as news reports on topics such as What are McDonald’s Chicken McNuggets Made of?,” without identifying the content as advertising. As the coalition elaborates, “The McDonald’s channel also features television commercials, such as the one for Smurfy Happy Meals. Branded channels, such as the McDonald’s channel, take advantage of children because they do not understand that the entire channel is actually advertising.”

“There is nothing ‘child friendly’ about an app that obliterates longstanding principles designed to protect kids from commercialism,” said CCFC Associate Director Josh Golin. “YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of  advertising that masquerades as programming. Furthermore, YouTube Kids’ advertising policy is incredibly deceptive. To cite just one example, Google claims it doesn’t accept food and beverage ads but McDonald’s actually has its own channel and the ‘content’ includes actual Happy Meal commercials.”