• by Wendy Davis , Staff Writer @wendyndavis, April 7, 2015

Google's YouTube Kids app hasn't been live for two months yet and it has already sparked a request for a privacy investigation.

A coalition of watchdogs today asked the Federal Trade Commission to probe whether the new app violates children's privacy laws. Specifically, the organizations are questioning whether Google is complying with the Children's Online Privacy Protection Act, which requires kids' app developers to disclose their tracking policies, and in many cases, obtain parental permission before tracking children younger than 13.

The organizations point to the app's recommendations feature, which the watchdogs say suggests videos similar to ones viewed recently. “Is Google tracking children’s online viewing habits to make the recommendations?” the organizations ask in a letter to the Federal Trade Commission. “If so, has it given direct notice and obtained verifiable parental consent?”

The groups add that YouTube's kids' app doesn't have its own privacy policy.

That's not the only potential problem with the app, according to the 10 organizations calling on the FTC to investigate. The advocacy organizations also allegedly take issue with content available on the app, including “unboxing” videos -- which often feature kids opening boxes containing toys.

Many of those clips appear to be created by users, but the organizations argue that the clips serve as “program-length commercials.”

The FTC might well side against the advocates on that point, according to ad law expert Greg Boyd, an attorney with Frankfurt Kurnit Klein & Selz. He says that unboxing clips -- at least the ones that aren't sponsored by companies -- are “more explorations of narrative and product experiences” than commercials. He adds that this kind of material “has been on the Internet as long as there's been an Internet.”

Google said in a statement that it “strongly” disagrees with the advocates' contentions, “including the suggestion that no free, ad-supported experience for kids will ever be acceptable.”

The letter was signed by the Center for Digital Democracy, Campaign for Commercial-Free Childhood, Center for Science in the Public Interest, Public Citizen, Children Now, Corporate Accountability International, Consumer Watchdog, American Academy of Child Adolescent Psychiatry, Consumer Federation of America and Consumers Union.