The Federal Trade Commission (FTC) introduced a novel ban on offering an online service to children and teens under 18 years old when it announced its settlement with California-based app developer NGL Labs and two of its co‑founders. NGL, short for “not gonna lie,” is an app that enables its users to receive anonymous messages. The settlement showcases the FTC’s willingness to use the Children’s Online Privacy Protection Act and other federal laws to protect teens as well as younger children. This first article in a two-part series on the significant aspects of the case examines the key violations and settlement terms as well as what the resolution signals about the FTC’s children’s privacy enforcement. It includes insights from Covington, Hunton Andrews Kurth, Orrick and ZwillGen. Part two will cover other novel aspects of the case, enforcement coordination trends and compliance lessons. See our two-part series on the SolarWinds Decision: “Court Narrows Case, but SEC’s Surviving Claims Alarm CISOs” (Aug. 28, 2024), and “Practical Takeaways for Cyber Communications” (Sep. 11, 2024).