The CTA was enacted to limit “the amount of commercial matter presented during children’s programs to the greatest extent possible without negatively impacting the viability of children’s programming on commercial television.”Yet, as applied to the nostalgia programming on MeTV Toons, the rules do not protect children 12 and under, who by and large are not watching the network. The rules do, however, serve to restrict the commercial viability of a network in which adult viewers have demonstrated great interest. Nearly two years since the network launched, the ratings and advertisers demonstrate that the network audience consists primarily of adults. As referenced above, according to Nielsen data, on average since the network was first rated in June of 2025, {{ REDATED }} of the audience are adult (18 and over) viewers.
That same data shows that on average, only {{ REDATED }} of the audience are children under 12. This contrasts starkly with ratings data for networks directly targeted to children. For instance, during the same period, the Disney Channel’s audience of children under 12 was more than {{ REDATED }} and Nickelodeon’s was more than {{ REDATED }} Their sister networks targeted to even younger viewers, such as Disney Junior and Nick Jr., had audiences of children under 12 that were nearly {{ REDATED }}
larger respectively during the same period.
The ratings clearly reflect that MeTV Toons is a network primarily for adults, not children.
Moreover, the products and services advertised on MeTV Toons are clearly targeted to adults. As mentioned above, the most common advertising category on the network is insurance products. Among the range of advertising on the network, viewers have seen ads for walk-in bathtubs, automative warranty products, anti-wrinkle creams, credit monitoring services, home gym equipment, floodlights, kitchenware, life insurance, personal injury attorneys, toothpastes, and beach resorts. Viewers have not seen ads for candies, toys, digital games targeted to children, other children’s television programs, or character-branded clothing or school items. It is apparent that advertisers purchasing time on MeTV Toons do not believe they are advertising to children, but rather adults. Therefore, application of section 73.670 to MeTV Toons serves only to limit the amount and type of commercial speech directed to adult audiences, which is not
the intent of the CTA.
