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Remarks of
Jonathan S. Adelstein
Commissioner, Federal Communications Commission
PointSmart.ClickSafe: Summit on Children’s Online Safety and Literacy
June 10, 2008
Thank you, Dan, for that kind introduction and especially for all of the work cable does 
for America’s children.  I would like to thank Common Sense Media, iKeepSafe and Cable in the 
Classroom for convening this summit.  Ensuring a safe online experience for children truly 
requires the cooperation of the advocacy community, private industry and government.  So I am 
pleased you all have been able to work together, putting the best interests of children first.  
Thank you for your service to America’s future – our children.
This is an issue that literally hits us where we live, myself included.  My wife and I face 
huge struggles as parents over what our two young children should be allowed to watch on TV 
and the Internet.  Life was not so complicated when we were growing up.  Instructions like 
“don’t talk to strangers” and “look in both directions before you cross the street” were enough 
for us.  But in today’s digital broadband era, many more and new dangers are lurking.  Those 
same basic messages have to be recalibrated to fit the times. 
We must protect our children and increase their media literacy so that they can safely 
access the vast new resources available on the net while avoiding the myriad dangers that they 
now face.  Online, a person is anonymous and yet can develop a personal relationship with an 
unsuspecting child on social networking sites.  And cyber-bullying, for example, has led to 
innocent children developing real social problems and even suicide.  We all know what 
happened to Megan Meier in St. Louis. 
All of society’s problems are digitized in this age of convergence.  All of the wonderful 
opportunities offered by the Internet are only a click or two away from insidious dangers.  While 
in the past it would have taken years for a particular mental health issue to develop in a child, 
today a child’s online experience can put that development cycle in “warp speed.”  Before even a 
protective parent notices, their child can be exposed to harm.  Even websites that are seemingly 
safe can expose children to relentless and excessive commercialism and unhealthy products.  
Parents desperately need and want information and tools to help them protect and teach 
their children the safe and healthy use of technology and the Internet.  It is clear that parents are 
the first, last and best line of defense against all forms of objectionable content.  Speaking as a 
parent, the problem is that in today’s media landscape, families have to navigate through a sea of 
inappropriate material.  Making a bad situation worse, most parents do not know about the 
navigational tools available to them, so they are like 17th Century sailors subject to the whims of 
an angry sea when they could be using more modern techniques to help chart a safe course for 
their children.
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Educating parents and children are both important.  Just as we protect our children in the
“real” world, we need to protect them in the digital world – where the seemingly virtual can 
become all too real all too quickly.  That is why the work of groups like iKeepSafe, Common 
Sense Media and the many others here today is so important.  And I am grateful that cable 
operators have taken a proactive role in working to develop programs for children and parents.  
As a Commissioner, my job is to ask you how I can help and what the government can 
do.  While I fully realize that whatever we do pales in comparison to what you can do, I 
nevertheless believe that we should proactively look for ways to improve online safety and 
media literacy.  It is easy to give you a lot of rhetoric about how much we care.  I could fill up an 
hour with soaring verbiage about the problem.  It is another thing to advocate real solutions, even 
when they are not popular with all of the big companies we oversee.  It is another thing entirely 
to take real action that will make a difference.  I wanted to raise a few concrete ideas that need 
FCC action now to put on your radar screen.  We do not always have the full support we need 
internally to get these steps accomplished, so we need your help.
For example, one item pending at the Commission is a Notice of Proposed Rulemaking 
on sponsorship identification and embedded advertising, and we need to get public comment on 
whether our existing rules governing commercials in children’s programming adequately 
promote the policy goals underlying the Children’s Television Act and the sponsorship 
identification rules.  This is especially important with respect to embedded advertising in 
children’s programming.  
Since last year, with the support of Chairman Martin, a majority of the Commission has 
already voted to issue this notice.  But there has been delay after delay, keeping this item frozen 
at the Commission.  I am urging all of my colleagues to complete this item without further delay.  
Another pending concern is how we deal with the Children’s Internet Protection Act 
requirements on schools and libraries that receive funding for Internet access under the E-Rate.  
As you may know, they cannot receive E-Rate funding unless they certify that they have an 
Internet safety policy and are either using blocking or filtering technology to protect children.  
While the Internet safety policy blocks or filters materials that are obscene, pornographic, or 
otherwise harmful to minors, I question whether we have appropriately defined what is harmful 
to children.  Do you think the Commission needs to provide more guidance to schools and 
libraries across the nation about what might be harmful to children?  Do we need to provide 
clarification?  I think that might be a good idea, but I want to hear from you about it first.
While the Commission does not have much authority in the online space, the standards 
we develop for other forms of media can produce guidance to help us tackle the common 
challenges old and new media pose to our kids.  Not since radios entered family rooms across the 
country has such an intimate medium as the Internet confronted the family unit.  The Internet, 
though, is far more powerful, because it is interactive and dynamic and because it engenders trust 
so easily among unsuspecting users.  We not only need to heed the lessons from our past, but we 
must also adapt these approaches to fit our new challenges. 
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When I told my wife what I was doing this morning, she instantly raised concern about 
how our kids and others click on flashy Internet ads and get sucked into a world they do not even 
know is advertising.  Kids really think they won the prize, and once they are able, will happily 
give away all kinds of personal information to get it – their name, address, age, you name it.  In 
fact, we have highly paid advertising executives spending countless hours trying to figure out 
how to get inside our kids’ minds.  We need to be just as smart and aggressive -- even if less well 
paid -- in figuring out how to keep them out.  Our kids are not mature enough to do it for 
themselves.  That is exactly what the marketers are preying on, and it is exactly why leaders like 
you and us on the FCC need to step up to protect our kids.
We must consider traditional media as a portal.  While traditional media confront new 
challenges as viewers are more and more fragmented across competing platforms, content 
creators, distributors and advertisers will surely seek to exploit new opportunities in the growing 
convergence of television and the Internet, and the endless technological advances and 
interactive features of digital and IPTV.  Marketers surely want to harness new technologies to 
capture the eyeballs of American children.
This increased incidence of our children being exposed to yet more commercialism 
troubles me deeply.  When I raised the issue of children’s media at my weekly staff meeting, 
every parent on my staff agreed that they face similar challenges.  When you multiply that by 
millions of families across the country affected, the responsibility is overwhelming.  And then 
when you consider that American families consume media – more than anything else – on TV, 
PC, laptops, radio, MP3, video handhelds and cell phones, it becomes evident that we will need 
to think more broadly.
As many of you know, since I have joined the Commission, I have traveled the country 
and heard a chorus of opposition to relaxing our media ownership rules that would allow big 
media to get bigger.  I have also expressed concern with what I believe to be one of the most 
pernicious symptoms of media concentration — the excessive commercialism in America media.  
In a speech to broadcasters and television executives at the Media Institute three years 
ago, I warned about the dangers of excessive commercialism and the fact that “well-trained 
marketers” were “preying on the unsuspecting minds of our young children.”  
My message might not have been particularly well received in that audience, but I felt it 
important to remind media representatives directly that my colleagues and I had reaffirmed the 
FCC’s longstanding policy that “listeners and viewers are entitled to know who seeks to 
persuade them with the programming over broadcast stations and cable systems.”  So whenever 
there are product placements on TV or cable originated programming, our rules require 
broadcasters and cable operators to provide full disclosure about who paid for them.
I warned that because children do not distinguish between programming and advertising, 
disclosure alone may not be adequate for children’s programming and that stricter measures may 
be necessary.  
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That is why, with my strong support, the FCC has taken steps to try to draw brighter lines 
between advertising and programming in children’s shows.  In the fall of 2004, we issued a 
landmark ruling that drew on the expertise of groups like Children NOW and many of you in this 
room.  We prevented broadcasters from displaying website addresses during children’s 
programming unless certain requirements designed to draw clear distinctions between 
commercial and other content were satisfied.
The Commission wanted to encourage broadcasters to develop interactive services that 
would enhance the educational value of children’s programming, so we decided not to prohibit 
the appearance of interactive links to commercial Internet sites.  
But perhaps the most critical part of the decision – when you think about its long-term 
impact – was our tentative conclusion that we should prohibit interactive advertisements during 
children’s programming.  We agreed unanimously that the TV should not connect viewers to 
interactive commercial matter unless parents “opt in” to such services.
That was the right conclusion then, and I am even more convinced that it is the right 
conclusion now.  I urge Chairman Martin to issue a final rule to ban interactive advertisement to 
children.  I hope all of my colleagues will support this.
Now it is important to recognize that not all of the initiatives are problematic.  One cable 
network reportedly launched a major mobile and interactive TV campaign to promote healthy 
eating to children as part of a week of on-air programming.  That is truly commendable, and 
more of that should be done. 
But I simply cannot accept the argument that it is too soon to act, because interactive 
television is a nascent technology or that we simply do not know what will unfold.  We know 
pretty well what is going to happen.  Just look at what companies are doing overseas.  Look at a 
Kaiser Family Foundation study on online food advertising targeting children or the recent 
Washington Post series on obesity.  If we think the epidemic of childhood obesity and diabetes is 
bad now, just wait until interactive advertising makes its force known on television.  But by then, 
it will be too late.
We should quickly move on the Further Notice on interactivity we issued in 2004 seeking 
comment on how to implement sensible restrictions on interactive ads and how those restrictions 
fit within our current regulatory structure.  We really need to take a hard look at interactive 
advertising and promulgate rules before it becomes an established business model here in this 
country.
Now is the time to stop the development of interactive advertising directed to children 
dead in its tracks.  Digital TV and new interactive technologies can provide a wealth of 
opportunities to children and their parents, but they should not provide wealth to advertisers at 
the expense of children and their parents.
The Commission has limited authority to take steps to protect children in this age of 
convergence.  So wherever we have authority, we need to act.  With our sensible and measured 
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actions, however modest, we can complement the work you all are doing here.  That kind of 
partnership is in the best interest of protecting our children.  And while that alone will not fully 
address the many issues we are discussing today, no single step will.
Continued cooperation and partnership between the advocacy community and private 
industry is essential.  Government should provide support and take action wherever possible.  
Kids do not need more talk from public officials.  They need action.  They need it now.
I only have a few minutes here today, but tomorrow I am speaking to the Media Institute 
on an American family agenda that will be more comprehensive.  I look forward to discussing 
that and all of the ideas that come out of this conference with you in the near future.  
Thank you for inviting me, and thank you all for sponsoring this forum to confront these 
urgent issues for our kids.