How Meta Affects Young Minds

B. Unfair and/or Unconscionable Acts and Practices

847. Meta engaged in unfair and unconscionable acts and practices, including the following unfair and/or unconscionable acts and practices, in connection with young users’ use of and/or addiction to Meta’s Social Media Platforms:

a. Meta targeted its Social Media Platforms to young users while knowingly designing its Social Media Platforms to include features that Meta knew to be psychologically and physically harmful to young users—including features known to promote compulsive, prolonged, and unhealthy use by young users;

b. Meta utilized Social Media Platform features that unfairly and/or unconscionably harm young users independently of any actions taken by third-party users of Meta’s Platforms. These features include infinite scroll, ephemeral content features, autoplay, quantification and display of “Likes,” and disruptive alerts, all of which were unfairly and/or unconscionably utilized by Meta to extract additional time and attention from young users whose developing brains were not equipped to resist those manipulative tactics;

c. Meta designed, developed, and deployed disruptive audiovisual and vibration notifications and alerts and ephemeral content features in a way that unfairly and/or unconscionably exploited young users’ psychological vulnerabilities and cultivated a sense of “fear of missing out” in order to induce young users to spend more time than they would otherwise choose on Meta’s Social Media Platforms;

d. Meta algorithmically served content to young users, according to “variable reinforcement schedules,” thereby manipulating dopamine releases in young users, unfairly or unconscionably inducing them to engage repeatedly with its products— much like a gambler at a slot machine; and

e. Meta collected the personal information of under-13 users of Instagram and Facebook without first obtaining verifiable parental consent, which violated COPPA and the COPPA Rule.

848. Meta’s deployment of manipulative and harmful features, both on their own and especially in combination, for use by young users are unfair and/or unconscionable acts or practices.

849. At all relevant times, Meta had a thorough understanding of the mental and physical harms and addiction suffered by young users of its Social Media Platforms. Instead of taking adequate measures to mitigate these damaging effects, Meta turned a blind eye to them, and persisted in exploiting young users’ psychological vulnerabilities. Meta’s acts and practices alleged herein are immoral, unethical, oppressive, and unscrupulous, including because they constitute knowing decisions causing unnecessary and unjustified harm to young users for Meta’s financial gain.

850. Meta’s acts and practices alleged herein, including Meta’s actions taken to encourage young users’ compulsive and unhealthy use of and addiction to its Social Media Platforms, are offensive to public policy, as defined by statute and common law. The protection of minors from the harms of addiction and related afflictions are well-established objectives underlying public policy in the Filing States; Meta’s acts and practices alleged herein, including Meta’s actions taken to encourage young users’ compulsive and unhealthy use of and addiction to its Social Media Platforms, are therefore offensive to public policy.