Juggling Acts and Smoke Signals: Meta Accused of Deceptive and Unfair Practices

XI. SUMMARY OF META’S DECEPTIVE AND UNFAIR OR UNCONSCIONABLE ACTS AND PRACTICES

A. Deceptive Acts and Practices

846. Meta engaged in the following deceptive acts and practices, with the intent that consumers rely on the deceptive acts and practices:

a. Meta misrepresented, directly or indirectly, expressly or by implication, that its Social Media Platforms are not psychologically or physically harmful for young users and are not designed to induce young users’ compulsive and extended use, when they are in fact so designed;

b. Meta misrepresented, directly or indirectly, expressly or by implication, that its Social Media Platforms are less addictive and/or less likely to result in psychological and physical harm for young users than its Social Media Platforms are in reality;

c. Meta misrepresented, directly or indirectly, expressly or by implication, through the publication of CSER reports and [Redacted], and through other communications, that the incidence or prevalence of negative or harmful user experiences on Meta’s Social Media Platforms was lower than it actually was;

d. Meta misrepresented, directly or indirectly, expressly or by implication that it prioritized young users’ health and safety over maximizing profits, when in fact Meta subordinated young user health and safety to its goal of maximizing profits by prolonging young users’ time spent on its Social Media Platforms;

e. Meta misrepresented, directly or indirectly, expressly or by implication that Meta prevents under-13 users from using Instagram and/or Facebook when in fact Meta was aware that it does not prevent under-13 users from using Instagram and Facebook;

f. Meta misrepresented, directly or indirectly, expressly or by implication that Meta’s collection of user data was not for the purpose of causing those users to become addicted to the Social Media Platforms, when in reality that was one of the purposes for which Meta collected user data;

g. Meta has made other false and deceptive representations, including as set forth in paragraphs 1 through 835.