On December 5, the Texas State Attorney General filed complaints against the operators of two web sites aimed at children – The Doll Palace and Games Radar – for violations of the Children’s Online Privacy Protection Act (“COPPA”). The Attorney General’s actions are particularly noteworthy, since previously only the Federal Trade Commission sought to enforce COPPA (although a state attorney general has jurisdiction under the Act to bring a regulatory action). Primarily, in the complaints, the Texas Attorney General charged the web site operators with collecting personally identifiable information from children (defined by COPPA as persons who are under 13) without first obtaining verifiable parental consent as required by the Act. The Doll Palace web site inquired of users “Is a parent with you right now?” and, depending on the answer, linked the user to a parental consent procedure which failed to comply with COPPA. Similarly, the age verification system employed by The Games Radar site was characterized by the Texas Attorney General as fatally flawed. The age screen involved a drop-down menu which only allowed users to select a birth date making them 13 or over (i.e., only a date 13 or more years ago could be selected as one’s birth date), which children could readily circumvent by misrepresenting their age. Other cited violations of COPPA include the operators collecting on their web sites more personally identifiable information than was reasonably necessary for a child to engage in the online activity in question as well as inadequate disclosure of the operator’s information collection and usage practices in its privacy policy. While the complaints are presently in a nascent stage (with no determination of liability by the web site operators), the Texas Attorney General’s interest in COPPA reinforces the need to approach the online collection of information from minors with extreme care and caution.