Instagram Does Little To Prevent Under-13 Users From Registering on the Platform

c. Meta’s design of the Instagram registration process allows children under 13 to use Instagram.

767. As set forth in detail above, Instagram first utilized no age gate for several years, then implemented an age gate that defaulted to a user age of 13 or above, then implemented an age gate that depends on children to self-report their own age. Meta is aware that because of these intentional design choices, under-13 users routinely supply a false date of birth when registering for Instagram.

768. Meta has access to, and chooses not to use, alternative feasible age verification methods that would significantly reduce or eliminate the number of underage users on Meta’s Social Media Platforms, for example, by requiring young users to submit student IDs upon registration.

769. Instagram’s decision not to use effective age verification that would exclude under-13 users is one way that it effectively targets and welcomes under-13 users onto the Platform.

770. Because Meta does not effectively exclude users under the age of 13 from Instagram, Meta’s external narrative regarding its COPPA compliance and age verification is misleading, including inaccurate public statements by Zuckerberg himself. [Redacted]