The Federal Trade Commission has reached a settlement with two app developers over charges that they violated the Children’s Online Privacy Protection Act (COPPA) and will collect $360,000 total in penalties.  The FTC claims the app developers, LAI Systems, LLC and Retro Dreamer, violated COPPA and the FTC Act by failing to provide notice to parents and obtain verifiable parental consent prior to allowing third-party advertisers to collect “persistent identifiers” from children’s devices in order to serve targeted ads.  These are the first cases in which the FTC has alleged that companies allowed advertisers to use persistent identifiers to serve ads to kids.  The cases also emphasize the breadth of the definition of “personal information” under COPPA.  And they underscore the statutory penalties available to the FTC under COPPA ‒ $16,000 for “each violation.”