https://techfreedom.org/coppa-rule-amendments-must-be-grounded-in-coppas-text/
"“Alone among regulations aimed at protecting kids online, COPPA has dodged First Amendment challenge because Congress was careful to avoid burdening sites that serve adults, but now the FTC proposes blurring that line in ways that invite litigation on both constitutional and textual grounds,” warned Berin Szóka, President of TechFreedom."