Counsel shortlist — the two questions in §6 row 0
Scope of the engagement: a written opinion on (1) whether the live site (scribbleworks.co, printable games for ages 2 to 8, adult-only sign-in, no child login, parent types the child's first name and birth month/year) is "directed to children" under 16 CFR §312.2 as amended in 2025, and (2) whether a school-facing marketing test trips Florida's disjunctive operator test in the Florida Student Online Personal Information Protection Act, Fla. Stat. §1006.1494(1)(e). The dispatch that produced this note cited the Florida question to the Florida Digital Bill of Rights (Fla. Stat. §501.701 et seq.); the vault's [[2026-09-02-scribble-works-school-phase-state-law-plan|school-phase note]] pins the disjunctive test to §1006.1494, and that is what the email below cites. FDBR's known-child provisions are a secondary question counsel can fold in.
Fee ceiling (Ray-proposed, per row 0 "a ceiling Ray proposes"): $5,000 fixed fee for the written opinion, expected boutique range $2,500 to $5,000. The decision page names no dollar figure; this is Ray's estimate, not a founder number. The email carries no figure, by design.
How sourced: web search 2026-09-02 for boutique and solo children's-privacy / ed-tech practices with public COPPA evidence (practice pages, 2025-rule analyses, ex-FTC staff, CIPP credentials), filtered against AmLaw firms and non-attorney consultancies. Bar admissions and fee models were taken from the firms' own pages only; where a page did not say, the row says "not public."
Candidates (Ray-selected, awaiting his read)
| # | Who | Where / bar | COPPA and ed-tech evidence | Rate / engagement signal | Contact | Why |
|---|---|---|---|---|---|---|
| 1 | Susan Hintze, Hintze Law PLLC (privacy-only boutique, founded 2016) | Seattle, WA. Bars: Washington, California, DC (inactive). CIPP/US, CIPT, FIP | Co-chair of the firm's "Kids + Teens Group"; firm published a multi-part series on the 2025 final rule including the definitional changes post that walks the new "directed to children" factors (marketing materials, representations, reviews, similar-service age data) — exactly our question. Chambers "highly regarded boutique." Profile | Not public. Chambers-ranked boutique; expect hourly unless a project fee is asked for | susan@hintzelaw.com; hintzelaw.com | The strongest published analysis of the exact definition we need read against our site. No FL admission; ask whether they will opine on §1006.1494 |
| 2 | Kandi Parsons, ZwillGen PLLC (privacy litigation/counseling boutique) | Washington, DC (also SF, Chicago, NY). Bar admissions not public on the site | Eight years FTC Division of Privacy and Identity Protection; "helped implement the 2013 revised COPPA rule, and developed staff FAQs related to COPPA compliance" (press note). The Children's Privacy & Ed Tech page lists "analyzing whether services are directed to children" as a named service, plus FERPA and state student-privacy laws | Site states three billing options including "flat/project fees" where the firm bears overrun risk. No published menu | info@zwillgen.com, +1 (202) 296-3585 | The FAQ A.8 argument in §4 rests on staff FAQs she helped write. Priciest of the five, most authoritative |
| 3 | Alex Shahrestani / Maggie Shahrestani, Promise Legal | Austin, TX. Alex: Texas Bar, USPTO; Maggie: CIPP/US | Dedicated ed-tech practice page (COPPA, FERPA, SOPIPA, district data agreements); steady COPPA blog output in 2025 to 2026 including mixed-audience and 2025 amendments audit guide | Published pricing: $50 initial consult; "COPPA Ready" subscription $7,500/yr; startup packages at flat annual fees. Will almost certainly quote a fixed fee for a one-off opinion | book.promise.legal, 512-737-6437 | Only candidate with startup-priced, published flat fees and an ed-tech practice built for founders. Texas-only admission; ask about FL |
| 4 | Harry Richt, RICHT Law Firm PLLC (solo, privacy/marketing/tech) | New York, NY. bar admissions not public on the firm site (presents CLE with NYSBA); other admissions not public | Dedicated COPPA and children's privacy page covering games, apps, ed-tech, state minor laws; active enforcement-tracking insights feed | Not public. Solo practice, likely the cheapest lawyer-issued opinion on the list | richtfirm.com/contact-us, (917) 624-9565 | Marketing-copy plus privacy in one head, which matters because copy is our compliance surface (§4). Thinnest public credential trail; verify on the call |
| 5 | Laila Archer, LMB Law (solo) — the Florida-admitted option | Tampa Bay, FL. Florida Bar. CIPP/US | lailalaw.com lists data privacy and CIPP/US; no COPPA-specific work found | "Initial consultations are complimentary"; response within 24 hours | laila@lmblawfirm.com | Not a COPPA specialist. Listed as Florida co-counsel or reviewer for the §1006.1494 / FDBR half if candidates 1 to 4 will not opine on Florida law. Skip if any of them will |
Ray's ranking: 1 Hintze (best fit to question 1), 3 Promise Legal (best fit to budget and the classroom path), 2 ZwillGen (if the founder wants the FTC-insider read and the ceiling stretches). Send the email to all of 1, 2, 3 and 4; hold 5 for the Florida gap.
Avoid list
- AmLaw and large firms with strong COPPA pages (Hunton, Loeb & Loeb, Latham, Kelley Drye, Frankfurt Kurnit): the content is good, the minimums and conflicts intake are not built for a one-person LLC. Read their alerts, do not retain them.
- Non-attorney consultancies (Curated Privacy LLC, VeraSafe, PRIVO-style compliance shops): they sell COPPA "applicability assessments," which is a risk evaluation, not a legal opinion. No privilege, no reliance.
- Octillo (Buffalo/NYC): real ed-tech practice, but the only public ed-tech/COPPA piece found is from January 2020 with no author, nothing on the 2025 rule.
- Klein Moynihan Turco (NYC): advertising-law boutique; no COPPA 2025 content surfaced, so no evidence for the specific question.
- CERV LAW PLLC (Ocala / St. Petersburg, FL): Florida-admitted and names COPPA, but only as a statutory citation in a list; no depth, no credentials shown.
- General signal: any firm whose intake asks for company revenue or headcount before quoting, or that will only quote hourly with no cap, does not fit row 0's "quotes and turnaround times" ask.
Outreach email (founder sends; Ray does not)
Subject: Fixed-fee written opinion, COPPA "directed to children" + Florida student-privacy operator test
Hello [Name],
I run Scribble Works (scribbleworks.co), a small Delaware LLC registered in Florida. The site offers free printable games for children ages 2 to 8. Accounts are adult-only: there is no child login, and a parent types the child's first name and birth date. We plan a paid tier and a teacher/classroom path.
I would like a written opinion on two questions:
- Is the live site, including its marketing copy, "directed to children" under 16 CFR 312.2 as amended in 2025?
- Would school-facing marketing trigger the disjunctive "operator" test in Florida's Student Online Personal Information Protection Act, Fla. Stat. 1006.1494(1)(e)? A view on the Florida Digital Bill of Rights' known-child provisions would be welcome too.
Could you send a fixed-fee quote and turnaround for the opinion, and let me know whether you are admitted in Florida or otherwise comfortable opining on Florida law?
Thank you, Ben Wilson Ray Data Co / Scribble Works ben@raydata.co
Next
Founder picks recipients and sends; Ray tracks replies against the $5,000 proposed ceiling, logs quotes and turnaround on this page, and surfaces a pick once two or more quotes are in. v2 child-profile work stays behind a flag until an opinion lands (row 0).
Verified 2026-09-02 18:2x ET by an independent read-only pass: all five candidates, contact paths, credentials, both citations, and the email length confirmed; Richt bar admission softened to "not public". Send first: Hintze, ZwillGen, Promise Legal.