The FTC introduced novel requirements around online services to individuals under 18 in its recent settlement with NGL Labs. Given the egregious missteps by NGL Labs, it may be tempting for companies to overlook this case as an outlier, but it offers some notable takeaways. This second installment of a two-part article series on the significant aspects of the NGL Labs case covers the FTC’s application of the substantial injury standard, enforcement coordination trends and compliance lessons, with insights from Alston & Bird, Covington & Burling, Hunton Andrews Kurth, Orrick and ZwillGen. Part one examined key violations and settlement terms as well as what the resolution signals about the FTC’s children’s privacy enforcement. See “Meta and Epic Cases Show FTC Toughening Its Children’s Privacy Enforcement” (May 17, 2023).