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This multi-district litigation consolidates hundreds of actions brought on behalf of children and adolescents, school districts and local government entities, and state attorneys general (the “States”) alleging that several social media companies-Meta's Facebook and Instagram, Google's YouTube, ByteDance's TikTok, and Snapchat-designed their platforms to foster compulsive use by minors, resulting in a variety of harms to children. Ps allege that Ds violated their consumer-protection laws by (1) designing and deploying platform features it knew were harmful to young users and (2) misleading and concealing from the public its knowledge of this harm. Ps also alleged claims under the Children's Online Privacy and Protection Act (COPPA) in that Ds impermissibly collect the data of children under 13 years old without obtaining prior consent from their parents. Ds focuses on monetizing user information by converting user engagement into revenue obtained from advertisers, who can deploy targeted advertising based on the personal data Ds collect from each user. The more a user engages, the more revenue can be generated by collecting more user data and serving more targeted advertisements. Ds' platforms contain a significant teen user base. Attracting and retaining young users forms a central focus of their business models. Ds allegedly developed and implemented features that it knows induce young users' extended, addictive, and compulsive use of social media platforms. Site algorithms were designed not to “benefit” the user but to maximize engagement by: (i) presenting material in an unpredictable sequence, relying on “variable reinforcement schedules,” a known psychological tactic, (ii) harvesting data to “target user engagement on an individual level”, and (iii) periodically presenting users with “emotionally gripping content ․ to provoke intense reactions” (e.g., relating to eating disorders, self-harm, suicide, violence, body-image issues, and more), a result of what Ds refers to as the algorithms' “preference amplification.” Dopamine-manipulating “variable reinforcement schedules” are harmful because they cause teen users to stay up late, leading to sleep deprivation, or cause them to be distracted during school. Infinite scrolling or teasing refers to the “partial display of additional content at the bottom of the user's screen, such that the user is typically unable to look at a single post in isolation.” “Teasing” of additional content continues indefinitely, as each time a user scrolls down their feed, new content is automatically loaded. Infinite scroll “makes it difficult for young users to disengage [from the content] because there is no natural endpoint for the display of new information.” Ds use ephemeral content that disappears unless the user looks at it now. This induces a fear of missing out in order to drive teen engagement. Ds use “push notifications” (auditory and visual cues) to alert users when accounts they follow add new content, which again drives engagement. The platforms contain features that “exacerbate social comparison, such as the quantification and display of “Like” counts. These social comparison features cause harm to teen girls. Ds allow multiple accounts allowing “users to register up to five accounts without having to log out of any one account to access another.” Multiple account users also have a higher probability of being exposed to harmful content. Ds make is challenging to delete or deactivate a user account. Some platforms 'recommend minor accounts to adult strangers' and have private chat functions to enable private communication by adult predators. Some Ds allow children to share their location with other users. Ds also have no effective age verification, and offer parents limited tools for controlling a child’s access. Ds have also developed features that promote and encourage eating disorders, focusing on “visual filters that simulate facial plastic surgery available to young users.” “Daily Limit” and “Take a Break” features are easy to dismiss, and the systems “regularly tempt” users to revert to time-maximizing settings whenever the user reaches their chosen limit. Ds were fully aware of the harmful effects. In 2013 alone-the year after Instagram's surge in popularity among young users-the suicide rate for 13-year-old girls jumped by around 50%. Ps have targeted the design, development, and deployment of features of Ds' platforms. Ds moved to dismiss.

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