Court Rules
All enforcement actions
Consent DecreeHigh Risk

FTC Settles Kuuhuub Over $3M COPPA Violation

Kuuhuub Inc.July 1, 2021Federal Trade Commission

Penalty Amount

$3,000,000

Summary

The FTC settled with Kuuhuub Inc., operator of the Recolor coloring book app, for violating COPPA by collecting personal information from children under 13 without parental consent. The app's social media features allowed children to register and share data, and third-party ad networks collected persistent identifiers for targeted ads. The settlement requires deletion of children's data, refunds to underage subscribers, a $3 million penalty (suspended upon $100,000 payment), and user notifications about the violations.

Remedy

The companies must delete all personal information collected from children under 13 unless parental consent is obtained, offer refunds to current paid subscribers who were under 18 at sign-up, pay a $3 million monetary penalty (suspended upon payment of $100,000), and notify app users about the COPPA violations and steps to take.

Monetary PenaltyData DeletionConsumer RefundsCorrective Notice

Contract Impact

In-house legal teams should review all agreements involving the Recolor app or similar child-directed services, including vendor contracts with third-party ad networks, customer-facing terms of service and privacy policies, and any data processing agreements. Focus on clauses governing data collection from minors, consent mechanisms (especially verifiable parental consent), third-party data sharing and advertising integrations, data retention and deletion policies, and age-screening procedures. Updates may be needed to ensure robust parental consent workflows, restrict collection of personal information from users under 13, audit and restrict third-party ad network data practices, implement clear children's privacy notices, and establish automatic data deletion protocols for underage users to comply with COPPA.

Contract Search Terms

verifiable parental consentchildren's data collection clausethird-party data sharing agreementad network SDK integrationage-screening mechanismdata retention policy for minorsCOPPA compliance addendumparental consent formchildren's privacy noticedata deletion upon request

Laws Cited

Violation Types

Entity Details

Entity

Kuuhuub Inc.

Also known as: Kuuhuub

Industry

Technology

Official Sources

Source Evidence

Entity Name
"Kuuhuub Inc."
Fine Amount
"$3 million monetary penalty"
Laws Cited
"Children’s Online Privacy Protection Act Rule (COPPA Rule)"
Violation Types
"collecting personal information from children under the age of 13"
Violation Types
"failed to provide notice to parents"
Violation Types
"failed to obtain verifiable parental consent"

Related Enforcement Actions

FTC

12 Unnamed Nudify Tool Providers

The FTC sent warning letters to 12 companies offering 'nudify' tools that generate nonconsensual intimate images, for failing to comply with the TAKE IT DOWN Act (TIDA) by not providing a mechanism for victims to request removal of such content. The letters urge immediate compliance with TIDA, which requires platforms to remove nonconsensual intimate images within 48 hours of a valid request. Noncompliant companies may face future legal action and civil penalties of up to $53,088 per violation.

FTC

Covered Platforms

The FTC began enforcing the TAKE IT DOWN Act on May 19, 2026, a law requiring covered platforms to establish a process for victims to request removal of nonconsensual intimate images and delete such content within 48 hours of a valid request. The agency launched a consumer complaint portal, issued compliance guidance for businesses and consumers, and sent reminder letters to major platforms including Meta, TikTok, and X about their obligations under the law. No specific penalties or enforcement actions against individual companies were announced in this release.

FTC

Cliq Inc.

$6.5M

A federal court held Cliq Inc. and its executives Andrew Phillips and John Blaugrund in civil contempt for multiple violations of a 2015 FTC order requiring the payment processor to prevent enabling consumer fraud. The court found the defendants facilitated fraud by processing transactions for high-risk merchants, avoiding fraud monitoring, failing to conduct required underwriting, and ignoring chargeback thresholds. The court imposed $6.5 million in civil contempt sanctions against the defendants.

FTC

Chris Terry, Isis Terry, IM Mastery Academy, IYOVIA, iMarketsLive, IM Academy

$795.8M

The FTC and State of Nevada settled charges with lead defendants of the IM Mastery Academy MLM scheme, including Chris and Isis Terry and their affiliated companies, over false earnings claims used to promote financial training programs and a multi-level marketing venture. The stipulated order imposes a $795.8 million judgment, with defendants surrendering nearly $90 million in assets including luxury real estate, vehicles, jewelry, and a yacht, totaling over $100 million with prior judgments from other involved defendants. The order also bans defendants from selling trading-training services, prohibits false earnings claims, and restricts deceptive practices including negative-option misrepresentations and telemarketing violations.

FTC

B.E.S.T. GDR LLC, d/b/a Premium Home Service

The FTC and State of Illinois, via the Department of Justice, filed a complaint against B.E.S.T. GDR LLC (d/b/a Premium Home Service) and its owner Yosef Bernath for creating thousands of fake home repair business listings with fabricated five-star reviews to deceive consumers. The defendants allegedly routed consumer calls to unqualified representatives, arranged for unlicensed technicians, and violated the FTC Act, Reviews and Testimonials Rule, Gramm-Leach-Bliley Act, and Illinois consumer protection laws. No monetary penalty has been imposed yet as the case is in initial filing stages.

FTC

Amazon, Alphabet, Apple, Automattic, Bumble, Discord, Match Group, Meta, Microsoft, Pinterest, Reddit, SmugMug, Snapchat, TikTok, X

Federal Trade Commission Chairman Andrew N. Ferguson sent letters to over a dozen major technology companies reminding them of their obligation to comply with the Take It Down Act (TIDA) by May 19, 2026. TIDA requires covered platforms to establish a process for victims, including children, to request removal of nonconsensual intimate images, with takedown of content and all identical copies required within 48 hours of a valid request. The FTC also issued supplemental guidance to help companies prepare for compliance and warned that it will monitor and enforce violations of the law.