Instagram's Child-Oriented Content Draws Attention from COPPA

e. Subject matter, characters, activities, music, and other content on Instagram are child-oriented.

794. Under 16 C.F.R. § 312.2, “subject matter, visual content, use of animated characters or child-oriented activities and incentives, music or other audio content” are relevant to determining whether an online service, or a portion thereof, is directed to children.

795. Instagram publicly hosts thousands of accounts and pages on its Platform that include child-oriented subject matter, characters, activities, music, and other categories of content for children.

796. To list only a few representative examples, Meta has admitted that it hosts the following accounts or pages on Instagram. Each such account or page on Instagram is child-oriented because it hosts images and videos relating to a character, product, or brand that is specially made for and/or marketed to children:

797. These and thousands of other child-oriented parts of Instagram are “a part []of” an online service that “is directed to children.”[39]

798. Meta’s maintenance and/or promotion of thousands of child-oriented pages on Instagram is one of the ways that Meta causes Instagram to be “directed to children.”

[39] See 16 C.F.R. § 312.2.