[Federal Register Volume 76, Number 232 (Friday, December 2, 2011)]
[Notices]
[Pages 75549-75551]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-30960]


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FEDERAL TRADE COMMISSION


Agency Information Collection Activities; Proposed Collection; 
Comment Request

AGENCY: Federal Trade Commission (``Commission'' or ``FTC'').

ACTION: Notice.

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SUMMARY: The FTC intends to conduct an evaluation of Admongo, its 
advertising literacy program for children ages 8-12. The evaluation 
will involve a randomized controlled trial of the Admongo program in 
one or more school districts, involving 6,000-8,000 students. This 
research will be conducted to further the FTC's mission of protecting 
consumers from unfair and deceptive marketing. We will consider 
comments on this proposed research before submitting a request for 
Office of Management and Budget (OMB) review under the Paperwork 
Reduction Act (PRA).

DATES: Comments must be submitted on or before January 31, 2012.

ADDRESSES: Interested parties may file a comment online or on paper, by 
following the instructions in the Request for Comment part of the 
SUPPLEMENTARY INFORMATION section below. Write ``Admongo Evaluation, 
FTC File No. P085200'' on your comment, and file your comment online at 
https://ftcpublic.commentworks.com/ftc/admongoevaluationpra, by 
following the instructions on the web-based form. If you prefer to file 
your comment on paper, mail or deliver your comment to the following 
address: Federal Trade Commission, Office of the Secretary, Room H-113 
(Annex J), 600 Pennsylvania Avenue NW., Washington, DC 20580.

FOR FURTHER INFORMATION CONTACT: Requests for additional information 
should be addressed to David Givens, Economist, Bureau of Economics, 
Federal Trade Commission, 600 Pennsylvania Avenue NW., Mail Stop NJ-
4136, Washington, DC 20580. Telephone: (202) 326-3397.

SUPPLEMENTARY INFORMATION: 

I. Background

    As the nation's consumer protection agency, the FTC is responsible 
for enforcing laws that prohibit unfair and deceptive advertising and 
marketing practices. Part of this mission involves educating consumers, 
including young consumers. In April 2010, the FTC launched a youth-
directed multi-media advertising literacy campaign called Admongo and 
distributed accompanying lesson plans to 100,000 educators in every 
U.S. public school with a fifth or sixth grade class. Admongo aims to 
help children from 8 to 12 become more discerning consumers of 
information. The program has three broad objectives: (1) Raising 
awareness of advertising and marketing messages; (2) teaching critical 
thinking skills that will allow children to better analyze and 
interpret advertisements; and (3) demonstrating the benefits of being 
an informed consumer. The program teaches students specific skills: How 
to identify ads, how to identify the ways advertisers target certain 
groups of consumers, how to spot persuasive techniques commonly 
employed by ads, and how to apply an understanding of advertising 
techniques to make smarter purchases. The campaign includes an online 
game, in-school lesson plans, sample ads that can be used at home and 
in the classroom, and teacher videos. All materials can be viewed at 
http://www.admongo.gov.
    The proposed evaluation will test a large group of students in 
these skills and then compare the performance of those who have been 
exposed to the Admongo curriculum with those who have not. The results 
will give the FTC valuable insight into the optimal design of youth-
directed consumer education. The FTC is interested in: The relative 
effectiveness of in-class versus online instruction, the variation in 
Admongo's benefits by age, pre-existing levels of ad literacy by age, 
and the relationship between ad literacy and academic achievement.\1\ 
The FTC also intends to interview teachers who have used the Admongo 
lessons in their classrooms. Teacher feedback will help us tailor the 
lessons to real-world classroom conditions.
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    \1\ All student-level data will be stripped of personally 
identifiable information by participating school districts before it 
reaches the FTC.
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II. Paperwork Reduction Act

    Under the PRA, 44 U.S.C. 3501-3521, federal agencies must obtain 
approval (``clearance'') from OMB for each collection of information 
they conduct or sponsor. ``Collection of information'' includes 
disclosure to an agency, third parties, or the public of information by 
or for an agency through identical questions posed to, or identical 
reporting, recordkeeping, or disclosure

[[Page 75550]]

requirements imposed on, ten or more persons. 44 U.S.C. 3502(3)(A). As 
required by section 3506(c)(2)(A) of the PRA, the FTC is providing an 
opportunity for public comment before seeking OMB clearance for the 
information collections presented here.
    The FTC invites comments on: (1) Whether the proposed collection of 
information is necessary for the proper performance of the functions of 
the agency, including whether the information will have practical 
utility; (2) the accuracy of the agency's estimate of the burden of the 
proposed collection of information, including the validity of the 
methodology and assumptions used; (3) ways to enhance the quality, 
utility, and clarity of the information to be collected; and (4) ways 
to minimize the burden of the collection of information.

A. Description of the Collection of Information and Proposed Use

    Subject to OMB approval, the FTC will conduct a randomized trial of 
the Admongo program in one or more U.S. school districts and involving 
6,000-8,000 students ages 8-12. Classrooms in each participating school 
will be randomly assigned to treatment or control status. In the 
treatment classrooms, the Admongo lesson plans will be taught over the 
course of one week, and students will be given in-class time to play 
the online Admongo game. At the end of the trial, treatment students 
will take a test in advertising literacy. Students in the control 
classrooms will take the same test before they are exposed to 
Admongo.\2\ Admongo's effect on ad literacy will be estimated from the 
difference in test scores. Additional controls measuring classroom, 
student, and teacher characteristics will increase the precision of the 
estimate of Admongo's impact.
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    \2\ With this protocol, the FTC gets a valid control group while 
still providing all experiment participants the benefit of the 
treatment.
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B. Estimated Burden Hours

    Each student's typical social studies or language arts teacher will 
teach the Admongo lessons. The paper-based test will last approximately 
20 minutes. The time required to experience the Admongo lessons, play 
the online game, and take the test should total approximately five 
hours and twenty minutes per student (four 45-minute in-class lessons, 
one hour of online game playing, one hour of homework assignments, and 
20 minutes for the test). With an estimated 6,000-8,000 students 
involved,\3\ cumulative burden for students will be in the range of 
32,000-42,667 hours. Teachers will require the same time per task as 
students, but will also need time for lesson planning--estimated at 
four hours per teacher. Thus, with an estimated 240-320 teachers 
involved,\4\ their time commitment will range from 2,240 to 2,987 
hours. The combined time for the Admongo trial should thus fall in the 
range of 34,240-45,654 hours.
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    \3\ Based on an anticipated school district's participation and 
its approximate student composition at present.
    \4\ Based on an estimated class size of 25 students and assuming 
a unique teacher for each classroom. [6,000 / 25 = 240; 8,000 / 25 = 
320]
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    These estimates are conservative. The Admongo lesson plans, tied to 
national standards of learning, will satisfy a pre-existing content 
requirement for participating schools.\5\ Thus, the incremental PRA 
burden for teachers and students would be much less than the estimates 
shown above.\6\ For example, if only the time required to take or 
administer the 20-minute test is considered, the resulting total would 
be a small fraction of the totals noted above.
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    \5\ See http://www.admongo.gov/state-standards/.
    \6\ See 5 CFR 1320.3(b)(2)(A) (a collection of information 
incurred by persons in the normal course of their activities is 
excluded from ``burden'' to the extent that the activities necessary 
to comply with it are ``usual and customary'').
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    A few participating teachers (20-40) also will take part in focus 
group discussions, lasting approximately 90 minutes. The estimated 
teacher time in focus groups, including an added hour of round-trip 
transportation to and from the discussion site, is 50-75 hours. 
Finally, administering the study will impose a small time burden on 
school district staff charged with scoring the tests and with compiling 
a master data set of 8-12 year-old students, stripped of personally 
identifiable information (to facilitate random assignment to treatment 
and control groups). These programming and data management tasks should 
take approximately 10-15 hours.
    The cumulative burden for participating students, teachers, and 
school district staff for the Admongo evaluation will total 34,300-
45,744 hours. Again, however, the bulk of this time would be subsumed 
within pre-existing classroom requirements.

C. Estimated Costs

    The cost per respondent should be negligible in both the evaluation 
and focus group components of the study. The participation of the 
school district in the evaluation is voluntary, and the district will 
use the Admongo program to meet curriculum requirements. Thus, 
participation in the evaluation study will not impose any start-up, 
capital, or labor expenditures beyond those ordinarily incurred by the 
district to administer curriculum units. Participation by students in 
the evaluation and teachers in the focus groups also will be voluntary 
and not impose any start-up, capital, or labor expenditures. Teachers 
participating in the focus groups will be compensated at the standard 
rate paid by the contractor to focus group participants. The school 
district will be compensated for the cost of the staff time to perform 
the data management and test-scoring tasks.

D. Request for Comment

    You can file a comment online or on paper. For the Commission to 
consider your comment, we must receive it on or before January 31, 
2012. Write ``Admongo Evaluation, FTC File No. P085200'' on your 
comment. Your comment--including your name and your state--will be 
placed on the public record of this proceeding, including, to the 
extent practicable, on the public Commission Web site, at http://www.ftc.gov/os/publiccomments.shtm. As a matter of discretion, the 
Commission tries to remove individuals' home contact information from 
comments before placing them on the Commission Web site.
    Because your comment will be made public, you are solely 
responsible for making sure that your comment does not include any 
sensitive personal information, like anyone's Social Security number, 
date of birth, driver's license number or other state identification 
number or foreign country equivalent, passport number, financial 
account number, or credit or debit card number. You are also solely 
responsible for making sure that your comment does not include any 
sensitive health information, like medical records or other 
individually identifiable health information. In addition, don't 
include any ``[t]rade secret or any commercial or financial information 
which is obtained from any person and which is privileged or 
confidential,'' as provided in Section 6(f) of the FTC Act, 15 U.S.C. 
46(f), and FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2). In particular, don't 
include competitively sensitive information such as costs, sales 
statistics, inventories, formulas, patterns, devices, manufacturing 
processes, or customer names.
    If you want the Commission to give your comment confidential 
treatment, you must file it in paper form, with a request for 
confidential treatment, and you have to follow the procedure

[[Page 75551]]

explained in FTC Rule 4.9(c), 16 CFR 4.9(c).\7\ Your comment will be 
kept confidential only if the FTC General Counsel, in his or her sole 
discretion, grants your request in accordance with the law and the 
public interest.
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    \7\ In particular, the written request for confidential 
treatment that accompanies the comment must include the factual and 
legal basis for the request, and must identify the specific portions 
of the comment to be withheld from the public record. See FTC Rule 
4.9(c), 16 CFR 4.9(c).
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    Postal mail addressed to the Commission is subject to delay due to 
heightened security screening. As a result, we encourage you to submit 
your comments online. To make sure that the Commission considers your 
online comment, you must file it at http://ftcpublic.commentworks.com/ftc/admongoevaluationpra, by following the instructions on the web-
based form. If this Notice appears at http://www.regulations.gov/#!home, you also may file a comment through that Web site.
    If you file your comment on paper, write ``Admongo Evaluation, FTC 
File No. P085200'' on your comment and on the envelope, and mail or 
deliver it to the following address: Federal Trade Commission, Office 
of the Secretary, Room H-113 (Annex J), 600 Pennsylvania Avenue NW., 
Washington, DC 20580. If possible, submit your paper comment to the 
Commission by courier or overnight service.
    Visit the Commission Web site at http://www.ftc.gov to read this 
Notice and the news release describing it. The FTC Act and other laws 
that the Commission administers permit the collection of public 
comments to consider and use in this proceeding as appropriate. The 
Commission will consider all timely and responsive public comments that 
it receives on or before January 31, 2012. You can find more 
information, including routine uses permitted by the Privacy Act, in 
the Commission's privacy policy, at http://www.ftc.gov/ftc/privacy.htm.

    By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2011-30960 Filed 12-1-11; 8:45 am]
BILLING CODE 6750-01-P