> As far as I can see this is a non-Governmental non-profit doing this. So it has no legal merit.

It has no legal weight. Lave of legal merit is a feature of a legal argument and is missing if the argument improperly represents the law, not if it comes from a source that doesn’t provide it legal weight. (Since you later say you agree with it. that is equivalent to saying that, insofar as it is a legal argument, that argument does have legal merit.)

> Can’t tell if this is the ad industry attempting to self-regulate?

No, it is a non-advertising industry non-profit doing research and reporting to the public, which potentially puts political pressure on government actors (State Attorneys-General and, maybe, the FTC) to take action (it could also provide ammunition for private lawsuits, except COPPA doesn’t provide a private cause of action.)

Note that a part of COPPA regulation is a Safe Harbor provision which involves industry self-regulation and certification, but that only protects against FTC, not state, action.

Ooo, never knew those words actually had different meanings in the legal context. Appreciate it :).

> Lave of legal merit

Lack?