Table of Contents

 

I. Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

II. Introduction to Online Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

III. Discussion: Online Risks & Safeguards . . . . . . . . . . . . . . . . . . .  . . . . . . . . . .3

       A. Data Privacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

1. The Reality: Data Privacy Breach. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Child Protection Privacy Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

       B. Access to Inappropriate Content. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1. Problems with Pornography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6
2. Lone Star State Leading the Way. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

       C. Cyberbullying. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

1. Cyberbullicide. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
2. Shifting the Burden. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Child Predators. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

1. 1. A Loss of Innocence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
   2. Recognizing Sex Offenders Online. . . . . . . . . . . . . . . . . . . . . . . . .15

IV. Conclusion: It Takes a Village. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

 
I. EXECUTIVE SUMMARY

In today’s digital age, minors are exposed to technology at a young age, presenting both great opportunities and risks. Online risks include data privacy breaches, access to inappropriate, cyberbullying, and online child predators. These challenges can have negative long-lasting effects, including privacy, mental, emotional, and physical safety. Addressing these risks associated with increased technology among minors requires a collaborative effort across many sectors.  If communities, government, law enforcement, online platforms, and tech companies work together, they can minimize these risks. Once they start prioritizing online safety and implementing new safeguards, children can explore the digital world securely and safely.

II. INTRODUCTION TO ONLINE RISKS

In today’s digitally driven world, minors are engaging online on social platforms, chat rooms and forums. Children have the ability to interact with their friends, families, and strangers. However, this creates a great risk for children. First, with the advancement of online platforms, the risk of data breaches has escalated, and minors are especially vulnerable due to their limited understanding of privacy and security practices. Secondly, the internet offers unrestricted access to a wide-range of content such as pornography, which can negatively impact childrens’ attitude towards women and sex in their adulthood. Third, cyberbullying has emerged as a threat to minors’ mental health which has caused emotional harm, even resulting in suicide. Finally, the internet provides infinite opportunities for predators to target minors for grooming, abuse, and exploitation. The existing parental controls and legislation has shown to be ineffective. With the participation of the government, law enforcement, online platforms, and tech companies, they have the potential to protect these children and foster a safe online environment.

III. DISCUSSION: ONLINE RISKS & SAFEGUARDS

A. Data Privacy

As minors engage with online platforms and services, they are at risk of having their personal data compromised in data breaches. To address this risk, organizations must implement advanced cybersecurity measures in order to safeguard minors’ sensitive information.

I. The Reality: Data Privacy Breach

Data privacy refers to the protection of an individual’s personal data, including the ability to decide how organizations collect, store and use their data. Many organizations collect user data such as email addresses, biometrics and credit card numbers.^[1] Data and metadata are sensitive if they pertain to an individual such as home, work, or school environmental data.^[2] Data privacy breaches involving children are the most concerning due to their vulnerability and automated systems that collect, use, share, or store data related to sensitive domains should meet additional expectations.

In 2022, about 1.7 million children fell victim to a data breach; meaning 1 in every 43 children had personal information exposed or compromised.^[3] Additionally, between 2021 and 2022, schools saw more than a 300% increase in breaches, and the number of K-12 grade schools impacted by ransomware attacks against districts doubled to nearly 2,000.^[4] This caused several school districts to cancel class or close completely– disrupting the children’s education partially or entirely.

Furthermore, data privacy breaches can lead to a catastrophic domino effect. The data that is stored can contain information such as name, birthdate, address, email, and phone numbers. The leaked information can cause children to become victims of identity theft and fraud. For example, children typically do not own credit cards, which means that hackers and fraudsters can use the child’s personal information to open credit cards in their name. Due to this identity theft and fraud, it could pose future challenges. For example, victims could have difficulty applying for a driver’s license, be denied a line of credit, or be unable to access governmental data.

2. Child Online Privacy Protection Act (COPPA)

Existing legislation is not enough to prevent and protect children from data privacy breaches. For example, The Privacy Act of 1974 requires protections for personal information in federal records systems, including limits on data retention, and provides a general right to access and correct data. However, minors do not always understand and consent to sharing their personal information. In order to address this, Congress directed the Federal Trade Commission (FTC) to issue the Children’s Privacy Privacy Protection Act (COPPA).^[5] COPPA requires that websites gain consent from parents of children under the age of 13 about what information websites can collect from their children. Websites are required to comply with COPPA if (1) the website is directed to children under 13 and collects personal information from them; (2) if it is directed to a general audience, but the organization has “actual knowledge” that children under the age of 13 are accessing this site; and (3) if the website contains third-party ads or plug-ins that collects personal information from children under the age of 13.

There are several flaws within this law. As noted above, children have been subjected to privacy breaches. Additionally, COPPA only applies to children under the age of 13, which means that children 13-17 are not protected under the Act. This appears to be a relatively simple solution: amend the Act to include all minors. Children under the age of 13 are no less important to protect from the risk of data privacy breaches, than those aged 14-17. Furthermore, Pew Research Center (Pew) conducted research regarding how Americans protect their online data and 56% of Americans say they always or often click “agree” right away, without reading what privacy policies say.^[6] This study showed that more than half are not reading the information, which can result in COPPA being ineffective if the child’s own parents are not reading what they are consenting to. One potential safeguard that could be implemented to protect all minors is to require that websites require minors to change their password every three months. Some platforms, such as Microsoft, have an optional security setting that requests users to change their password every 72 days. Rather than having this feature be optional, it would be a requirement. Another solution is to require two-step authentication (2FA). This would require that users provide two forms of identification in order to access their account. Using 2FA would reduce the likelihood of unauthorized access. Both solutions would prevent passwords from hackers, protecting users from online predators gaining access to their personal information.

Additionally, government agencies are making attempts to prioritize cybersecurity. The Biden administration launched new initiatives to strengthen school’s cybersecurity by providing up to $200 million over three years, as well as partnering with tech companies to provide free and low-cost resources to school districts.^[7] While this is a great first step, this has the potential to create a disparity gap among wealthier school districts versus ones in impoverished areas. Schools need to identify creative funding and initiatives to prioritize cybersecurity when they cannot afford to do so. Cybersecurity is not only to protect children’s academic environment, but also their personal lives.

There are so many intersections with data privacy and every sector plays a crucial role in protecting children’s safety. “Almost 90% of Americans [said] they were concerned about social media platforms having their childrens’ personal information. Most of us think parents hold the primary responsibility for their kids’ online safety, but about 60% say tech companies are partially responsible, and almost half think the government shares a responsibility as well.”^[8] Protecting minors’ privacy should not rely solely on parents. Mitigating data breaches should be the responsibility of all.

B. Access to Inappropriate Content
The internet has made children’s access to inappropriate content, such as pornography, a lot easier. Without proper safety measures in place, children’s exposure to pornography can lead to negative sexual perceptions, ideas, fantasies, and habits, which can affect them in their adult years.

1. Problems with Pornography

Protecting minors from inappropriate content, specifically pornographic material is crucial for childrens’ well-being. Dr. Sharon Cooper, a forensic pediatrician, maintains that children are more vulnerable to learning sexual behavior in pornography because of mirror neurons in the brain which convince people that they are experiencing what they witness. Thus, children learn imitation when they watch pornography. This poses great risk because pornography typically displays a lack of an emotional relationship between consensual partners; glorifies unprotected sexual contact; and of greatest concern, encourages sexual violence and rape. Since children are vulnerable to adopt behavior and habits from what they see,  they can be subjected to negative long-term effects because it normalizes sexual harm, promotes aggression towards women, affects healthy intimate relationships, and promotes predatory behavior.

A 2010 study of 50 popular pornographic films found that only 20.2% of scenes did not contain an aggressive act, whereas 88.2% of scenes contained physical aggression. Additionally, men committed 70.3% of all aggressive acts and 94.4% of aggression was directed towards women.^[9] A 2006-2008 survey of youth (ages 10-15) found that youth who reported exposure to pornographic materials were 6.5x more likely to report sexually aggressive behavior, and the youth who reported exposure to violent pornographic material were 24x more likely to report sexually aggressive behavior.^[10] Violent sexual material can normalize and glorify sexual violence, non-consent, and rape. Not only does pornography include imagery of aggression, violence, and rape, but much pornographic content normalizes predatory and coercive behavior. For example, it normalizes intrafamilial sexual relationships, such as engaging in sexual activity with “step” family members or extended relatives. In addition, it promotes grooming, such as the abuse of power dynamics. Finally, storylines include adults that portray minors with titles using the words “minor” or “high-schooler” engaging in sexual contact with adults.

States have imposed ordinances that restrict stores from promoting sexual material in order to prevent minors’ exposure to it. Restrictions include requiring purchasers to show proper identification or for stores to cover the front of the magazines. In these states, age restrictions vary from 16-18, which coincidentally, correlate with the age of consensual sex. If store owners do not comply with these restrictions, then they can face fines and/or jail time. This is an example of the government showing concern over minors’ exposure to sexual content by limiting store owner’s promotion of obscene images in magazines. These magazines are a lot less explicit than pornography; therefore, this concern and prevention should extend to pornography.

2. Lone Star State Leading the Way

In November 2023, Attorney General Paxton won a victory allowing Texas to enforce HB 1181. HB 1181 requires certain sites with sexual content to have viewers provide digital IDs or other proof of age before they access the content.^[11] This provision was intended to protect minors from being exposed to harmful obscene material. In February 2024, Texas sued Aylo Global Entertainment, a company that runs several of the largest pornography websites, such as Pornhub. Since the suit, Pornhub has disabled its site entirely in Texas because they refused to comply with state law. Websites like Pornhub, Chaturbate, xHamster, and other pornographic websites that violate the age verification requirements will be subject to fines up to $10,000 per day, an additional $10,000 per day if the corporation illegally retains identifying information, and $250,000 if a child is exposed to pornographic content due to not properly verifying a user’s age.

Chaturbate is one pornographic platform that has complied with Texas’s state law. Before entering the website, there is an Agreement stating that the user meets the age verification and complies with state and federal law. Then in order to view the content, users must create an account and upload a scan of their valid government-issued identification (ID). The ID must contain the user’s date of birth, a recognizable photo, ID number, and legal name. Users must then submit a photo of themselves in real time to verify that the ID is theirs. Historically, courts have struck down laws imposing age verification requirements because the courts found that it was unconstitutional. The Supreme Court has repeatedly recognized the important role of anonymity online and held that these requirements infringe upon adult users’ First Amendment rights. However, the Fifth Circuit enforced HB 1181 because the age verification provisions had a rational basis because the goal of this bill was to protect children.

There is a possible loophole around this law: Virtual Private Network (VPN). VPNs are a cybersecurity tool to safeguard online privacy by changing a user’s IP address to another location. However, some governments have restricted, limited, or banned the use of a VPN. Additionally, corporations, schools, colleges, and major online streaming companies have also restricted or banned the use of VPNs.^[12] VPNs are legal in the United States, but with the large fines imposed against these pornographic websites in Texas, companies could potentially ban the use of VPNs in order to protect themselves legally and financially.

Unless the Supreme Court intervenes in Texas, the enforcement of HB 1181 has the potential to create precedent for more states to impose age verification requirements on websites that contain inappropriate content in order to protect minors emotional, mental, and physical well-being. HB 1181  not only protects children from accessing online sexual material, but it has the potential to extend beyond this. If Texas can enforce age verification requirements on websites, which has been commonly recognized as an infringement upon an individual’s First Amendment right, then this goal of protecting children online can be applied to other sectors of the internet, such as cyberbullying and online predators.

C. Cyberbullying

Cyberbullying among minors has become a growing concern across the nation due to  the anonymity and pervasive nature of the internet. Cyberbullying is defined as the intentional and repeated harm from one more persons against another that occurs online.^[13] Cyberbullying is a growing phenomenon that can have long standing effects on a child’s psychological health. Of greatest concern, is the correlation of cyberbullying and suicide. The incidences of both cyberbullying and adolescent suicides are rising in the United States, and this correlation has been newly termed as “cyberbullicide.” To combat cyberbullying, there must be stricter safety measures in place by communities, government, social platforms, and tech companies.

1. Cyberbullicide

On October 16, 2006, 13-year-old Megan Meier committed suicide after being cyberbullied on the online platform, MySpace.^[14] On September 20, 2006, Megan told her childhood friend, “Doe”, that she did not want to be friends anymore. “Doe” told her mother, Lori Drew, and the two devised a plan to create a fake profile on MySpace under the name of “Josh” in order to cyberbully and humiliate Megan. Over the next few weeks, Megan and “Josh” began an online flirtatious relationship. However, on October 7, “Josh” told Megan that he was moving away and on October 16, “Josh” told Megan that he no longer liked her and that the world would be a better place without her in it. Later that day, Megan took her own life at the age of 13.

Megan Meier is considered to be amongst the first cases of cyberbullying in the U.S. and a cyberbullicide victim. Along with Megan, other notable cyberbullicide cases include 12-year-old Rebecca Sedwick, 10-year-old Ashawnty Davis, and 16-year old Channing Smith. Rebecca was extensively cyberbullied via multiple online platforms by girls from school. This caused her to switch schools, but the cyberbullying continued for another year and a half, leading her to take her own life at the age of 12. Ashawnty was being cyberbullied by a girl at her school, and one day she decided to confront her, which led to a physical altercation. This altercation was posted on the online platform, Musical.ly, which prompted more bullying. Two weeks later, Ashawnty took her own life at the age of 10. Channing was outed as gay after explicit text messages between him and another male student were posted on social media. On that same day, only a few hours later, Channing took his own life at the age of 16. Although cyberbullying does not necessarily cause suicide, there is a strong correlation between the two that needs to be addressed.

2. Shifting the Burden

Megan Meier’s case was a good step towards holding cyberbullies accountable for their actions. In 2009, following Meier’s death, Representative Sanchez introduced the Megan Meier Cyberbullying Prevention Act, but it was not passed by Congress.^[15] Although it was not passed, it retains relevancy given its implications and precedent as one of the early cases involving attempted prosecution for cyberbullying. There are no Federal Laws regarding cyberbullying; however, as of January 2021, 48 states have extended their bullying laws to include cyberbullying.^[16] Each state defines cyberbullying differently and many states leave law enforcement in the hands of the schools. These school-based initiatives require that if a faculty member is notified of any student bullying another student, in person or online, then they are mandated to report it. This is not always effective because this requires that students report the harassment and that the school takes these actions seriously.

As a solution, platforms can implement keyword filtering. This algorithm can scan text, images, or videos to specific keywords or phrases associated with harmful content and language. Currently, apps such as Instagram, Bumble, TikTok, and Chatgbt, have keyword filtering algorithms to some extent. Typically, after the message that contains a filtered keyword or phrase is sent, there is notification that the text may violate community guidelines. Rather than sending the notification and leaving the burden on the recipient to report the message, online platforms could require that any message that is flagged as harmful would be reviewed immediately, regardless of whether the recipient reports it or not. Upon review, companies would have to report the message to law enforcement. This would be no different than existing statutes that require schools to report bullying. Additionally, AI and machine learning are increasingly used to enhance content filtering. These algorithms can learn extensive amounts of data to improve their ability to detect harmful content. These algorithms could prevent cyberbullies from sending harmful content to others. It is possible that with these algorithms, AI and machine learning could learn the repetitive behavior of perpetrators. With new technology, algorithms could detect the user’s repetitive nature of sending harmful messages, thus leading to the deactivation of their account on the grounds of cyberbullying. Finally, in order to avoid tragedies like Megan’s, platforms could restrict the use of individuals’ creation of multiple accounts. This would prevent individuals from creating fake profiles with the intent to cause harm towards others, as discussed in Megan’s case.

The courts have both rejected and upheld First Amendment defenses in cases of cyberbullying, finding that cyberbullying statutes are unconstitutional on the basis of restricting free speech. However, there is a rational basis for the government, schools, online platforms and tech companies to implement stricter policies in order to protect the lives of so many children. Causation may not always be found with cases of cyberbullying and suicide, but there is research that finds this correlation. Additionally, there is research that finds a correlation between cyberbullying and emotional distress amongst victims. The government, schools, online platforms, and tech companies need to recognize that cyberbullying is becoming increasingly easy to cause violence and harm towards children. The burden should not fall on the child to report their emotional distress because sometimes it is too late.

C. Child Predators

Since the development of online platforms, the online sexual predation of minors has increased. Online sexual offenders commit many crimes such as grooming, child pornography, sexual solicitation, child trafficking, and sextortion. As access to the internet increases, child sex offenders can interact with children more easily than ever before. Consequently making every child online a potential victim for predators. With the joint effort of governmental agencies and implementation of technological advancements, children can retain their innocence from predators.

1. A Loss of Innocence

On October 10, 2012, 15-year old Amanda Todd committed suicide after being extorted and cyberstalked by a man in an online chatroom in 2009. Amanda had a history of being bullied in school, and in order to find connections, she turned to the internet. She entered an online chatroom and befriended a man who flattered her. He preyed on her vulnerabilities and asked her to flash him. She complied, but he took a picture of her nude. TFrom that day on, he stalked her online and eventually posted her nude photographs on Facebook.^[17] This prompted more bullying and harassment, in school and online, causing her to transfer schools. This deteriorated her mental health and self-esteem, which led her to substance abuse. Amanda’s story was unique because just one month before her death, she posted a video on Youtube detailing her entire story. From being a victim of online sextortion, cyberstalking, and bullying, to being forced to transfer schools, and abusing drugs.^[18] It was not until 2022 when law enforcement finally identified Coban, a 44-year-old man, as the man who blackmailed and cyberstalked Amanda to her death. Coban was convicted on similar charges involving the online extortion of 33 young girls. Amanda was and is not the only victim. From October 2021 to March 2023, the FBI and Homeland Security Investigations received reports of online sextortion involving at least 12,600 minors.^[19] Amanda’s story of sextortion is not the only example of online sex crimes, but it did catch the nation’s attention after her gut wrenching YouTube video. Coban was just one of many online predators. There are 500,000 child predators online daily and 20% of children report being targeted by predators.^[20] Additionally, in another study, it evaluated recidivism rates of 2,630 online offenders and found that 4.6% of internet offenders committed a new sexual offense. It is expected that recidivism rates will increase with more opportunity.^[21] Unfortunately, Coban was only one example of a child predator who went unnoticed for years and had numerous victims.

While online sex offenders and conventional contact sex offenders are not always synonymous, conventional sex offenders could be useful to analyze how online sex offenders should be monitored. In the United States alone, the total number of registered sex offenders has increased. Between 2022 and 2023, there was a 3% increase with a total of 786,838 registered sex offenders. As previously stated, there are 500,000 documented child predators online daily and at least 786,838 conventional sex offenders. Unfortunately, this only includes offenders that have been caught and reported and there are many other predators that have not been caught. With the expansion of online platforms, predators now have a much wider audience they can target.

2. Recognizing Sex Offenders Online

Similar to Texas’s approach to pornography and age verification, other social platforms could implement a similar response. Analyzing how the government treats registered sex offenders can offer possible solutions to how online predators should be monitored. For example, convicted offenders of federal obscenity laws involving minors may be required to register as sex offenders. The Sex Offender Registration and Notification Act (SORNA), provides a comprehensive set of minimum standards for sex offender registration and notification in the United States. The Keeping the Internet Devoid of Predators Act (KIDS Act) was a bill introduced to Congress to amend SORNA to address the issue of online safety, which required jurisdictions to collect sex offenders’ internet identifiers in the registration process.^[22] The bill sought to restrict registered sex offenders from interacting with minors online. It proposed that websites implement measures to verify users’ ages which would prevent predators from creating fake profiles to interact with minors. However, the bill was not passed because it faced criticism for potential enforcement challenges and concerns about the effectiveness of preventing online exploitation of minors.

The KIDS Act was similar to Texas’s HB 1181, because it aimed to protect children from the dangers of online platforms. The KIDS Act offered safeguards to protect minors from online predators, and with the help of technology, it has the potential to be extremely effective. If social platforms enforce verifying identification, it could restrict online predators from using these sites. Additionally, social platforms can integrate flagging features that would require registered sex offenders to disclose their status on their profiles. Tech companies could work with social platforms as well. Using geolocation and IP tracking can help identify devices and locations owned by sex offenders. This could block users’ devices because it could prohibit these registered sex offenders from engaging on online platforms that minors frequent. Finally, similar to cyberbullying, content filtering and monitoring is equally important for recognizing inappropriate behavior targeted at minors. Employing these advanced algorithms and AI could automatically scan, filter and remove predatory behavior. This would limit predators from engaging in sexual texts, sending inappropriate photos in addition to children sending explicit photos, and restrict predators from exploiting and soliciting minors.

There are so many predators that go unnoticed, especially on the internet. While online offenders and conventional sex offenders are not synonymous, there is great overlap. Nonetheless, thousands of children are actual victims, and all children on the internet are potential victims. With the collaboration of social platforms and tech companies, they have the ability to protect all of these children.

IV.  CONCLUSION: IT TAKES A VILLAGE

The intersection of increased technology use and online risks presents a complex landscape that demands immediate attention and prevention to safeguard the well-being of minors. Data breaches, access to inappropriate content, cyberbullying, and online predators pose significant threats to minors’ privacy, safety, and overall well-being.

The emergence of online platforms and services has led to unremarkable amounts of personal data being shared and stored online, making minors vulnerable to data breaches and identity theft. Exposure to inappropriate content, like pornography, has shown to create violent behavior towards others sexually, as well as predatory behavior. Cyberbullying has emerged as an infinite threat that negatively impacts minors’ well-being, and has taken the lives of many children. Furthermore, online predators have the ability to make any and all children victims to sex crimes, posing serious risks to their safety.

Addressing these challenges requires policy makers, social platforms, and tech companies to prioritize digital safety in order to embrace a safer digital presence for minors. With robust cybersecurity measures; policies; and advanced technology, such as age-verification, content filtering, and AI; children can be protected from these online threats. By prioritizing the protection of minors and implementing aggressive and innovative measures to address online risks, children can navigate the internet safely and securely. Technology presents great risks, but it can also be the driving force to create positive tools to minimize the potential harms upon society’s most vulnerable members, thus protecting them in their adulthood.

^[1] IBM, What is data privacy?, https://www.ibm.com/topics/data-privacy

^[2] WH.GOV, DATA PRIVACY, https://www.whitehouse.gov/ostp/ai-bill-of-rights/data-privacy-2/

^[3] National Cybersecurity Alliance, Protecting Our Kids’ Data Privacy is Paramount (Jan. 2024). https://staysafeonline.org/resources/protecting-our-kids-data-privacy-is-paramount/#:~:text=Kids’%20Data%20Privacy%20Statistics,by%20Javelin%20Strategy%20and%20Research.

^[4] Yin, Steve. “Protecting Children’s Data Needs to Be a Priority for All,” DARKREADING (Jan. 2024). https://www.darkreading.com/cyberattacks-data-breaches/protecting-childrens-data-needs-priority-for-all

^[5] FEDERAL TRADE COMMISION, Children’s Online Privacy Protection Rule: Not Just for Kid’s Sites, https://www.ftc.gov/business-guidance/resources/childrens-online-privacy-protection-rule-not-just-kids-sites#rule (April 2013)

^[6] McClain, Colleen, et al., “How Americans View Privacy Data,” Pew Research Center. (Oct. 2023). https://www.pewresearch.org/internet/2023/10/18/how-americans-protect-their-online-data/

^[7] WH.GOV, Biden-Harris Administration Launces New Efforts to Strengthen America’s K-12 School’s Cybersecurity, (Aug. 2023). https://www.whitehouse.gov/briefing-room/statements-releases/2023/08/07/biden-harris-administration-launches-new-efforts-to-strengthen-americas-k-12-schools-cybersecurity/

^[8] See footnote 3.

^[9] Baxter, Allison, How Pornography Harms Children: The Advocate’s Role, ABA. (May 2014). https://www.americanbar.org/groups/public_interest/child_law/resources/child_law_practiceonline/child_law_practice/vol-33/may-2014/how-pornography-harms-children–the-advocate-s-role/

^[10] Id.

^[11] ATTORNEY GENERAL OF TEXAS, Attorney General Ken Paxton Sues Two More Pornography Companies for Violating Texas Age Verification Law, (March 2024). https://www.texasattorneygeneral.gov/news/releases/attorney-general-ken-paxton-sues-two-more-pornography-companies-violating-texas-age-verification-law#:~:text=Texas%20Attorney%20General%20Ken%20Paxton,exposed%20to%20harmful%20obscene%20material.

^[12] Einorytė, Aurelija, VPN bans: How they work and who’s behind them, NordVPN, (Feb 2024). https://nordvpn.com/blog/vpn-ban/#:~:text=Yes%2C%20a%20VPN%20can%20be,censorship%20to%20protecting%20internal%20networks.

^[13] Zhu, Chengyan, et al., Cyberbullying Among Adolescents and Children: A Comprehensive Review of the Global Situation, Risk Factors, and Preventative Measures. (March 2021).

^[14] United States v. Drew, 259 F.R.D. 449 (C.D. Cal. 2009)

^[15] https://jaapl.org/content/51/1/112.long

^[16] https://jaapl.org/content/51/1/112.long

^[17] Dean, Michelle, “The Story of Amanda Todd”, THE NEW YORKER, (Oct. 2012). https://www.newyorker.com/culture/culture-desk/the-story-of-amanda-todd

^[18] TheSomebodytoknow, My story: Struggling, bullying, suicide, self harm, YouTube (Sep 7, 2012), https://www.youtube.com/watch?v=vOHXGNx-E7E

^[19] FBI SACRAMENTO, “Sextortion: A Growing Threat Preying Upon Our Nation’s Teens” (Jan. 17, 2024). https://www.fbi.gov/contact-us/field-offices/sacramento/news/sextortion-a-growing-threat-preying-upon-our-nations-teens

^[20] Oklahoma Legal Group, How do You Protect Your Children from Online Predators? (March 29, 2023). https://www.oklahomalegalgroup.com/news/how-do-you-protect-your-children-from-online-predators#:~:text=An%20estimated%20500%2C000%20child%20predators,report%20being%20targeted%20by%20predators.

^[21] Seto, Michael, Internet-Facilitated Sexual Offending, SOMAPI, (July 2015). https://smart.ojp.gov/SOMAPI-brief-internet

^[22] H.R. 719 Keeping the Internet Devoid of Sexual Predators Act of 2008, 110th Congress (Oct. 2008).