The Children's Advertising Review Unit (CARU) continues its long-time quest to obtain compliance with its guidelines from marketers reaching out to kids online. CARU recently asked three website operators to change their online marketing practices after reviewing their sites. The self-regulatory group asked The Upper Deck Company, which operates the website, to modify the advertising for the site's rewards program, and the company agreed to do so. The site featured information about sports cards, building a card collection and sports memorabilia. Children have the option of personalizing their site, and opening an account to earn rewards points by winning quizzes and via online redemptions.

A consumer made a complaint regarding the way points were earned and redeemed, and CARU became concerned as to whether the advertising was "accurate and truthful." Following CARU's inquiry, Upper Deck agreed to clearly list prizes as "out of stock" and "unavailable," and to update its inventory more often.

The two other inquiries dealt with an issue that continues to be a major focus of CARU's enforcement efforts-compliance with the Children's Online Privacy Protection Act (COPPA).

The Subway Franchisee Advertising Fund Trust, which operates, and a section of the main site devoted to a younger audience,, was asked to modify its age screening mechanism to ensure that it was neutral and would not "tip off" children that they needed to be more than 13 to register and provide personally identifiable information.

The operators of were asked to modify their site so that children under 13 could not access portions of its site that collected personally identifiable information without first being required to obtain parental consent.

View a summary of CARU's review of the Upper Deck site, of Subway's site, and of Club Libby Lu's site at

Read previous KidAdLaw coverage of CARU's website reviews: "More Sites Agree to Privacy Changes".