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It's been a while since I dealt with COPPA, but I'm almost positive you're correct.

The FTC's FAQ page on COPPA compliance concurs:


>If you choose to block children under 13 on your general audience site or service, you should take care to design your age screen in a manner that does not encourage children to falsify their ages to gain access to your site or service. Ask age information in a neutral manner at the point at which you invite visitors to provide personal information or to create a user ID.

> In designing a neutral age-screening mechanism, you should consider: [...] Avoiding encouraging children to falsify their age information, for example, by stating that visitors under 13 cannot participate or should ask their parents before participating. In addition, simply including a check box stating, “I am over 12 years old” would not be considered a neutral age-screening mechanism.

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