States Seek Relief Against Meta for COPPA Violations

PRAYER FOR RELIEF

A. On the Filing States’ joint COPPA claim, pursuant to 15 U.S.C. § 6504(a)(1) and as authorized by the Court’s own equitable powers, the Filing States request that the Court:

1. Enter a permanent injunction to stop ongoing violations and prevent future violations of the COPPA Rule by Meta;

   
   

2. Make such other orders as may be necessary to enforce Meta’s compliance with the COPPA Rule;

   
   

3. Award the Filing States damages, restitution, and other compensation;[43] and

   
   

4. Award other and additional relief the Court may determine to be just and proper.

B. On the Filing States’ individual claims set forth in paragraphs 860 through 1171, each State respectfully requests that the Court:

1. For Arizona:

a. Pursuant to Ariz. Rev. Stat. § 44-1528(A)(1), issue a permanent injunction in accordance with Ariz. R. Civ. P. 65(d)(1), enjoining and restraining (a) Meta, (b) its officers, agents, servants, employees, attorneys, and (c) all persons in active concert or participation with anyone described in part (a) or (b) of this paragraph, directly or indirectly, from engaging in deceptive, misleading, or unfair acts or practices, or concealments, suppressions, or omissions, that violate the Arizona Consumer Fraud Act, Ariz. Rev. Stat. § 44-1522(A), including specific injunctive relief barring Meta from engaging in the unlawful acts and practices set forth above;

b. Pursuant to Ariz. Rev. Stat. § 44-1528(A)(2), order Meta to restore to all persons in interest any monies or property, real or personal, which may have been acquired by any means or any practice in this article declared to be unlawful;

c. Pursuant to Ariz. Rev. Stat. § 44-1528(A)(3), order Meta to disgorge all profits, gains, gross receipts, or other benefits obtained as a result of its unlawful acts alleged herein;

d. Pursuant to Ariz. Rev. Stat. § 44-1531, order Meta to pay to the State of Arizona a civil penalty of up to $10,000 for each willful violation by each Defendant of Ariz. Rev. Stat. § 44-1522;

e. Pursuant to Ariz. Rev. Stat. § 44-1534, order Meta to reimburse the State of Arizona for its costs and attorneys’ fees incurred in the investigation and prosecution of Meta’s activities alleged in this Complaint;

f. Pursuant to Ariz. Rev. Stat. § 44-1201, require Meta to pay pre-judgment and post-judgment interest to the State of Arizona and all consumers;

g. Award the State such further relief the Court deems just and proper under the circumstances.

2. For California:

a. With respect to the state law claims set forth by California, pursuant to California Business and Professions Code sections 17203 and 17535, order that Meta, its successors, agents, representatives, employees, and all persons who act in concert with them be permanently enjoined from committing any acts which violate California Business and Professions Code sections 17200 and 17500, including, but not limited to, the acts and practices alleged in this Complaint; pursuant to California Business and Professions Code section 17536, award the People of the State of California civil penalties of $2,500 for each violation of California Business and Professions Code section 17500, as proved at trial; pursuant to California Business and Professions Code section 17206, award the People of the State of California civil penalties of $2,500 for each violation of California Business and Professions Code section 17200, as proved at trial (which are cumulative to the penalties awarded pursuant to section 17536); pursuant to California Business and Professions Code section 17206.1, award the People of the State of California additional civil penalties of $2,500 for each violation of California Business and Professions Code section 17200 against one or more disabled persons, as proved at trial; make such orders or judgments, pursuant to California Business and Professions Code sections 17203 and 17535, as may be necessary to prevent the use or employment by Meta of any act or practice that violates California Business and Professions Code sections 17200 or 17500, or as may be necessary to restore to any person in interest any money or property which Meta may have acquired either directly or indirectly from such persons by means of any practice that violates California Business and Professions Code sections 17200 or 17500; and award the People of the State of California all other relief to which they are legally entitled under California law.

3. For Colorado:

a. An order and judgment declaring Meta’s conduct to be in violation of the Colorado Consumer Protection Act, Colo. Rev. Stat. §§ 6-1-105(1)(e), (g), (u), and (rrr).

b. An order and judgment to enjoin and prevent the use and employment of the deceptive trade practices described in this Complaint and which are necessary to completely compensate the State of Colorado, its institutions, and any person injured by means of any such practice. Such relief shall include a judgment in an amount to be determined at trial for restitution, disgorgement, or other equitable relief, including injunctive relief, pursuant to Colo. Rev. Stat. § 6-1-110(1).

c. An order permanently enjoining Meta and anyone in active concert or participation with Meta with notice of such injunctive orders, from engaging in any deceptive trade practices as defined in and proscribed by the Colorado Consumer Protection Act and as set forth in this Complaint, pursuant to Colo. Rev. Stat. § 6-1-110(1).

d. An order requiring Meta to forfeit and pay civil penalties pursuant to Colo. Rev. Stat. § 6-1-112(1)(a).

e. An order requiring Meta to pay the costs and expenses of this action incurred by the Attorney General, including, but not limited to, expert costs and attorneys’ fees, pursuant to Colo. Rev. Stat. § 6-1-113(4).

f. Any such further orders as the Court may deem just and proper to effectuate the purposes of the Colorado Consumer Protection Act.

4. For Connecticut:

a. With respect to the state law claims set forth by the State of Connecticut, pursuant to the Connecticut Unfair Trade Practices Act (CUTPA), Connecticut General Statutes (Conn. Gen. Stat.) § 42-110b et seq., award the State of Connecticut: (1) civil penalties for each willful violation of CUTPA committed by Meta up to $5,000 per violation pursuant to Conn. Gen. Stat. § 42-110o; (2) damages and restitution for Connecticut consumers, pursuant to Conn. Gen. Stat. § 42-110m; (3) disgorgement, pursuant to Conn. Gen. Stat. § 42-110m; (4) injunctive and other equitable relief, pursuant to Conn. Gen. Stat. § 42-110m; (5) costs and attorney’s fees, pursuant to Conn. Gen. Stat. § 42-110m; and (6) other remedies as the Court may deem appropriate under the facts and circumstances of the case.

5. For Delaware:

a. With respect to the Delaware CFA claim set forth by the State of Delaware in Count X pursuant to 6 Del. Code Ann. §§2522, 2523 and 2526, a permanent injunction enjoining Meta from violating the Delaware CFA, award to the state civil penalties of up to $10,000 per violation for each willful violation of § 2513 of the Delaware CFA, the exact number of violations to be proven at trial; award all sums necessary to restore to any consumers the money or property acquired from them by Meta in connection with violations of § 2513 of the Delaware CFA; award to the State its costs as well as attorneys’ fees, and all other remedies and relief available at law and equity that this Court deems fit.

b. With respect to the Delaware DTPA claim set forth by the State of Delaware in Count XI pursuant to 6 Del. Code Ann. §§ 2532 and 2533 and award to the state a permanent injunction enjoining Meta from violating the Delaware DTPA, civil penalties of up to $10,000 per violation for each willful violation of § 2532 of the Delaware DTPA, the exact number of violations to be proven at trial; award all sums necessary to restore to any consumers the money or property acquired from them by Meta in connection with violations of § 2532 of the Delaware DTPA; award to the State its costs as well as attorneys’ fees, and all other remedies and relief available at law and equity that this Court deems fit.

6. For Georgia:

a. Declaring that Meta has violated the FBPA by engaging in the unlawful acts and practices alleged herein;

b. Permanently enjoining Meta from engaging in the unfair and/or deceptive acts and practices alleged herein;

c. Permanently enjoining Meta from violating the FBPA;

d. Ordering that Meta pay restitution to any person or persons adversely affected by Meta’s actions in violation of the FBPA;

e. Assessing a civil penalty against Meta in the amount of $5,000.00 per violation of the FBPA;

f. Assessing attorneys’ fees and costs against Meta; and

g. Granting such other and further relief as the Court deems just and appropriate.

7. For Hawai‘i:

a. Declaring that Meta has violated HIUDAP by engaging in the unlawful acts and practices alleged herein;

b. Permanently enjoining Meta from engaging in any acts that violate HIUDAP, including, but not limited to, the unfair or deceptive acts or practices alleged herein;

c. Assessing civil penalties against Meta in the amount not exceeding $10,000.00 for each and every violation of HIUDAP pursuant to HRS § 480-3.1;

d. Awarding the State’s reasonable attorneys’ fees and costs pursuant to HRS § 480-14 (c) for violations of HIUDAP;

e. Pre- and post-judgment interest; and

f. Awarding such other relief as this Court deems just and equitable.

8. For Illinois:

a. Find that Meta violated Section 2 of the Consumer Fraud Act, 815 ILCS 505/2, by engaging in unlawful acts and practices including, but not limited to, the unlawful acts and practices alleged herein;

b. Enter a permanent injunction pursuant to 815 ILCS 505/7 to prevent future violations of the Consumer Fraud Act;

c. Order Meta to pay penalties up to $50,000 per unfair or deceptive act or practice and an additional amount of $50,000 for each act or practice found to have been committed with the intent to defraud, as provided in Section 7 of the Consumer Fraud Act, 815 ILCS 505/7;

d. Order Meta to pay monetary relief, including restitution to Illinois consumers, and disgorgement of revenues pursuant to 815 ILCS 505/7;

e. Order Meta to pay all costs of the State of Illinois in bringing this action pursuant to 815 ILCS 505/10;

f. Award any other and additional relief as the Court may determine to be just and proper.

9. For Indiana:

a. Pursuant to Ind. Code § 24-5-0.5-4(c)(1), permanently enjoin Meta from engaging in acts or omissions alleged in this Complaint that violate the Indiana Deceptive Consumer Sales Act, Ind. Code § 24-5-0.5-1 et seq.;

b. Pursuant to Ind. Code § 24-5-0.5-4(c)(2), order Meta to pay restitution to aggrieved Indiana consumers;

c. Pursuant to Ind. Code § 24-5-0.5-4(c)(4), order Meta to pay costs, awarding the Office of the Attorney General its reasonable expenses incurred in the investigation and prosecution of this action;

d. Pursuant to Ind. Code § 24-5-0.5-4(g), order Meta to pay civil penalties for Meta’s knowing violations of Ind. Code § 24-5-0.5-3(a) and Ind. Code §§ 24-5-0.5-3(b)(1) and (2), payable to the State of Indiana, in the amount of five thousand dollars ($5,000.00) per violation;

e. Pursuant to Ind. Code § 24-5-0.5-8, order Meta to pay civil penalties for Meta’s incurable deceptive acts, payable to the State of Indiana, in the amount of five hundred dollars ($500.00) per violation; and

f. Pursuant to Ind. Code § 24-5-0.5-4(c), all other just and proper relief, including but not limited to equitable relief such as disgorgement of revenues from any ill-gotten gains.

10. For Kansas:

a. Permanently enjoin Meta, pursuant to K.S.A. 50-632 from engaging in any acts that violate the KCPA, including, but not limited to, the deceptive and unconscionable acts or practices alleged herein;

b. Order Meta to pay civil penalties in the amount of $10,000.00, pursuant to K.S.A. 50-636(a), for each violation of the KCPA;

c. Order Meta to pay all expenses and investigation fees, pursuant to K.S.A. 50-632(a)(4); and

d. Such other relief as the Court deems just and equitable.

11. For Kentucky:

a. Disgorgement and restitution pursuant to Ky. Rev. Stat.§ 15.020, Ky. Rev. Stat.§ 367.110 through Ky. Rev. Stat.§ 367.990, and common law;

b. Injunctive and other equitable relief pursuant to Ky. Rev. Stat. § 15.020, Ky. Rev. Stat. § 367.190, and common law;

c. Civil penalties pursuant to Ky. Rev. Stat.§ 367.990(2);

d. Costs and attorneys’ fees pursuant to Ky. Rev. Stat. § 367.110 through Ky. Rev. Stat.§ 367.990, Ky. Rev. Stat.§ 48.005(4), and common law; and

e. Other remedies as the Court may deem appropriate under the facts and circumstances of the

case.

12. For Louisiana:

a. An order declaring Meta’s conduct to be in violation of LA. REV. STAT. ANN. § 51:1405;

b. Issuing a permanent injunction prohibiting Meta from engaging in future unfair and deceptive trade practices pursuant to LA. REV. STAT. ANN. § 51:1407;

c. Ordering Meta to pay civil penalties for each and every violation of the Louisiana Consumer Protection Law pursuant to LA. REV. STAT. ANN. § 51:1407;

d. Ordering Meta to pay all costs and reasonable attorneys’ fees for the prosecution and investigation of this action; and e. Ordering any other additional relief as the Court may deem just and proper.

13. For Maine:

a. An order pursuant to ME. REV. STAT. ANN. tit. 5, § 209 to permanently enjoin and restrain the use of the unfair or deceptive methods, acts, or practices which are unlawful under ME. REV. STAT. ANN. tit. 5, § 207 as described in this Complaint;

b. An order pursuant to ME. REV. STAT. ANN. tit. 5, § 209 requiring Meta to forfeit and pay civil penalties for each intentional violation of the Maine Unfair Trade Practices Act;

c. An order requiring Meta to pay the costs and expenses of this action incurred by the Attorney General, including, but not limited to, expert costs and attorneys’ fees, pursuant to ME. REV. STAT. ANN. tit. 5, § 209 and ME. REV. STAT. ANN. tit. 14, § 1522(1)(A); and

d. Any such further orders as the Court may deem just and proper to effectuate the purposes of the Maine Unfair Trade Practices Act.

14. For Michigan:

a. The Attorney General for the State of Michigan seeks a permanent injunction against Meta restraining future violations of the MCPA and other law; a civil fine of $25,000 per violation; a declaratory judgment that the conduct comprising MCPA violations described above are unlawful; restitution and monetary damages of not less than $250.00 per consumer damaged by the MCPA violations described above; costs and reasonable attorneys’ fees; and any other relief this Court considers just and proper.

15. For Minnesota:

a. With respect to the state law claims set forth by the State of Minnesota, award judgment against Meta, jointly and severally, as follows:

i. Declaring that Meta’s actions and omissions, as described in this Complaint, constitute multiple, separate violations of Minnesota Statutes section 325D.44, subdivision 1;

ii. Permanently enjoining Meta and its employees, officers, directors, agents, successors, assignees, affiliates, merged or acquired predecessors, parents or controlling entities, subsidiaries, and all other persons acting in concert or participation with them from engaging in conduct in violation of Minnesota Statutes section 325D.44, subdivision 1;

iii. Awarding judgment against Meta for restitution, disgorgement, and/or damages for Minnesota consumers under Minnesota Statutes section 8.31, the parens patriae doctrine, the general equitable powers of this Court, and any other authority; iv. Awarding judgment against Meta for civil penalties pursuant to Minnesota Statutes section 8.31, subdivision 3, for each separate violation of Minnesota Statutes section 325D.44, subdivision 1; v. Awarding the State of Minnesota its costs, including litigation costs, costs of investigation, and attorneys’ fees, as authorized by Minnesota Statutes section 8.31, subdivision 3a; and vi. Granting such further relief as provided by law or equity or as the Court deems appropriate and just.

16. For Missouri:

a. An order declaring Meta’s conduct to be in violation of the Missouri Merchandising Practices Act (MMPA), Mo. Rev. Stat. §407.020;

b. An order permanently enjoining Meta and anyone in active concert or participation with Meta with notice of such injunctive orders, from engaging in any unlawful practices as defined in and proscribed by the MMPA and as set forth in this Complaint, pursuant to Mo. Rev. Stat. §407.100.1;

c. An order to prevent the employment and recurrence of the unlawful acts and practices described in this Complaint, including disgorgement, or other equitable relief, including injunctive relief, pursuant to Mo. Rev. Stat. §407.100.3;

d. An order an order of restitution, payable to the State of Missouri, as may be necessary to restore to any person who has suffered any ascertainable loss as a result of Meta’s unlawful practices, pursuant to Mo. Rev. Stat. §407.100.4;

e. An order requiring Meta to pay an amount equal to ten percent of any restitution awarded, pursuant to Mo. Rev. Stat. §407.140.3;

f. An order requiring Meta to pay civil penalties pursuant to Mo. Rev. Stat. §407.100.6;

g. An order requiring Meta to pay the Attorney General’s costs and fees of investigating and prosecuting this action, including, but not limited to, expert costs and attorneys’ fees, pursuant to Mo. Rev. Stat. §407.130; and

h. Any such further orders as the Court may deem just and proper to effectuate the purposes of the MMPA.

17. For Nebraska:

a. Permanently enjoining Meta, its agents, employees, and all other persons and entities, corporate or otherwise, in active concert or participation with any of them, pursuant to Neb. Rev. Stat. §§ 59-1608 and 87-303.05, from engaging in conduct described in the Complaint to be in violation of the Consumer Protection Act and Uniform Deceptive Trade Practices Act;

b. Permanently enjoining Meta, its agents, employees, and all other persons and entities, corporate or otherwise, in active concert or participation with any of them, pursuant to Neb. Rev. Stat. §§ 59-1608 and 87-303.05, from violating the Consumer Protection Act, Uniform Deceptive Trade Practices Act, and any amendments thereto;

c. Ordering Meta to pay restitution, pursuant to Neb. Rev. Stat. §§ 59-1608(2) and 87-303.05(1), to any person or persons adversely affected by Meta’s acts or practices in violation of the Nebraska Consumer Protection Act and Nebraska Uniform Deceptive Trade Practices Act;

d. Ordering Meta to pay the State a civil penalty in the amount of two thousand ($2,000.00) dollars per violation, pursuant Neb. Rev. Stat. §§ 59-1614 and 87-303.11, for each and every violation of the Consumer Protection Act and Uniform Deceptive Trade Practices Act;

e. Ordering Meta to pay the State’s costs and attorneys’ fees in this matter, pursuant to Neb. Rev. Stat. §§ 59-1608 and 87-303(b); and

f. Granting such further relief as the Court may deem just and appropriate.

18. For New Jersey:

a. With respect to the state law claims set forth by New Jersey, pursuant to the Consumer Fraud Act (CFA), N.J. STAT. ANN. §§ 56:8-1 to 227, award New Jersey: (1) the maximum statutory civil penalties for each violation of CFA committed by Meta of $10,000 for the first violation and $20,000 for each second and subsequent violation, pursuant to N.J. STAT. ANN. §§ 56:8-13 and 14; (2) damages and restitution for New Jersey consumers under N.J. STAT. ANN. § 56:8-8; (3) injunctive and other equitable relief, pursuant to N.J. STAT. ANN. § 56:8-8; (4) treble damages under N.J. STAT. ANN. § 56:8-19; (5) costs and attorneys’ fees pursuant to N.J. STAT. ANN. § 56:8-11; and (6) any other remedies as the Court may deem appropriate under the facts and circumstances of the case.

19. For New York:

a. Permanently enjoining Meta from violating the laws of the State of New York, including New York Executive Law § 63(12) and New York General Business Law §§ 349 and 350;

b. Directing Meta to make full restitution to consumers and pay damages caused, directly or indirectly, by the fraudulent, deceptive, and illegal acts complained of herein plus applicable pre-judgment interest;

c. Directing Meta to pay a civil penalty of $5,000 for each violation of New York General Business Law Article 22-A, pursuant to New York General Business Law § 350-d;

d. Directing such other equitable relief as may be necessary to redress Meta’s violations of New York law;

e. Directing Meta to produce an accounting of profits and to disgorge all profits resulting from the fraudulent and illegal practices alleged herein;

f. Awarding the Attorney General of the State of New York its costs; and

g. Granting such other and further relief as the Court deems just and proper.

20. For North Carolina:

a. Permanently enjoin Meta from engaging in the unfair or deceptive acts and practices described herein and from engaging in any other acts and practices with the same purpose or effect, pursuant to N.C.G.S. § 75-14;

b. Enter any other permanent relief necessary to remedy the effects of Meta’s unfair or deceptive conduct, pursuant to N.C.G.S. § 75-14;

c. Award the State of North Carolina the disgorgement of profits from Meta’s unfair or deceptive acts and practices;

d. Award the State of North Carolina civil penalties, pursuant to N.C.G.S. § 75-15.2;

e. Award the State of North Carolina its costs, including a reasonable attorney’s fee, incurred by the investigation and litigation of this matter, pursuant to N.C.G.S. § 75-16.1; f. Award the State of North Carolina any and all other legal and equitable relief as the Court may determine to be just and proper.

21. For North Dakota:

a. Find that Meta engaged in acts or practices that violate N.D. Cent. Code §51-15-02;

b. Permanently enjoin Meta from engaging in any acts or practices that violate N.D. Cent. Code §51-15-02, including the unlawful acts or practices alleged herein, pursuant to N.D. Cent. Code §51-15-07;

c. Award for the benefit of the state of North Dakota civil penalties of up to $5,000 for each violation of N.D. Cent. Code §51-15-02, pursuant to N.D. Cent. Code §51-15-11;

d. Award all sums necessary to prevent Meta’s use or employment of unlawful practices, and restore to persons any money or property that may have been acquired by means of a practice violating N.D. Cent. Code § 51- 15-02, pursuant to N.D. Cent. Code §51-15-07;

e. Award, to the Attorney General, reasonable attorneys’ fees, investigation fees, costs, and expenses of the investigation and prosecution of this action, pursuant to N.D. Cent. Code §51-15-10; and

f. Award such other relief as this Court deems just and equitable.

22. For Ohio:

a. Issue a declaratory judgment that each act or practice complained of herein violates the CSPA, Ohio Rev. Code §1345.01 et seq., in the manner set forth in the Complaint;

b. Issue a permanent injunction enjoining Meta, its agents, employees, successors or assigns, and all persons acting in concert and participation with them, directly or indirectly, through any corporate device, partnership, or other association, under these or any other names, from engaging in the acts and practices of which Ohio complains and from further violating the CSPA, Ohio Rev. Code §1345.01 et seq.;

c. Assess, fine and impose upon Meta a civil penalty of up to $25,000.00 for each separate and appropriate violation of the CSPA described herein pursuant to Ohio Rev. Code §1345.07(D);

d. Grant Ohio its costs incurred in bringing this action, including but not limited to, the cost of collecting on any judgment awarded;

e. Order Meta to pay all court costs associated with this matter; and

f. Grant such other relief as the Court deems to be just, equitable, and appropriate.

23. For Oregon:

a. Entering a permanent injunction to prevent Meta from future violations of Oregon’s UTPA, pursuant to O.R.S. § 646.636;

b. Awarding civil penalties up to $25,000 for each willful violation of O.R.S. § 646.607 and O.R.S. § 646.608, pursuant to O.R.S. § 646.642; and

c. Awarding reasonable attorneys’ fees and costs of the investigation, preparation, and litigation, pursuant to O.R.S. § 646.632(8) and O.R.C.P. 68.

24. For Pennsylvania:

a. Declaring Meta’s conduct as described herein above to be in violation of the UTPCL;

b. Permanently enjoining Meta and all other persons acting on its behalf, directly or indirectly, from violating the UTPCL;

c. Directing Meta to make full restitution, pursuant to section 201-4.1 of the UTPCL, to all consumers who have suffered losses as a result of the acts and practices alleged in this Complaint and any other acts or practices which violate the UTPCL;

d. Directing Meta to pay to the Commonwealth of Pennsylvania civil penalties of One Thousand and 00/100 Dollars ($1,000.00) for each instance of a past or present violation of the UTPCL;

e. Requiring Meta to pay the Commonwealth of Pennsylvania’s investigative and litigation costs in this matter; and

f. Granting such other general, equitable and/or further relief as the Court deems just and proper.

25. For Rhode Island:

a. Enter an order permanently enjoining Meta from engaging in any of the acts or practices described herein and any further violation of the RI DTPA;

b. Declare the acts or practices described herein to be unlawful under the RI DTPA;

c. Order Restoration to any person in interest any moneys or property, real or personal, that may have been acquired by means of any act or practice described herein;

d. Order Meta to pay the State of Rhode Island’s costs and attorneys’ fees;

e. Order Meta to pay a civil penalty of up to ten thousand dollars ($10,000.00) per violation of the Deceptive Trade Practices Act as provided by R.I. Gen. Laws § 6-13.1-8; and

f. Order any other relief that the Court deems appropriate.

26. For South Carolina:

a. Permanently enjoin Meta, pursuant to section 39-5-50(a) of the South Carolina Code from engaging in any acts that violate SCUTPA, including, but not limited to, the unfair or deceptive acts or practices alleged herein;

b. Order Meta to restore to all persons and entities all ascertainable losses suffered as a result of Meta’s violations of SCUTPA;

c. Order Meta to pay civil penalties in the amount of $5,000.00, pursuant to section 39-5-110(a) of the South Carolina Code, for each and every willful violation of SCUTPA;

d. Order Meta to pay attorneys’ fees and costs pursuant to section 1-7-85 of the South Carolina Code for violations of SCUTPA;

e. Pre- and post-judgment interest; and f. Such other and further relief as this Court deems just and equitable.

27. For Virginia:

a. Pursuant to Virginia Code § 59.1-203, enter a permanent injunction against Meta restraining future VCPA violations;

b. Pursuant to Virginia Code § 59.1-206(A), award to the Commonwealth of Virginia civil penalties of up to $2,500.00 per violation for each willful violation of § 59.1-200 of the VCPA, the exact number of violations to be proven at trial;

c. Pursuant to Virginia Code § 59.1-205, award all sums necessary to restore to any consumers the money or property acquired from them by Meta in connection with violations of § 59.1-200 of the VCPA;

d. Pursuant to Virginia Code § 59.1-206(D), award to the Commonwealth of Virginia its costs, reasonable expenses incurred in investigating and preparing the case, up to $1,000.00 per violation of § 59.1-200 of the VCPA, the exact number of violations to be proven at trial, as well as the Commonwealth of Virginia’s attorneys’ fees; and

e. Award any such other and additional relief as this Court deems just and proper.

28. For Washington:

a. Adjudge and decree that Meta has engaged in the conduct complained of herein;

b. Adjudge and decree that the conduct complained of in the Complaint constitutes unfair or deceptive acts or practices in violation of the Washington Consumer Protection Act, Wash. Rev. Code. § 19.86;

c. Issue a permanent injunction enjoining and restraining Meta and its representatives, successors, assigns, officers, agents, servants, employees, and all other persons acting or claiming to act for, on behalf of, or in active concert or participation with Meta from continuing or engaging in the unlawful conduct complained of herein;

d. Assess civil penalties, pursuant to Wash. Rev. Code. § 19.86.140, of up to $7,500 per violation against Meta for each and every violation of Wash. Rev. Code. § 19.86.020 alleged herein;

e. Assess an enhanced civil penalty of $5,000, pursuant to Wash. Rev. Code. § 19.86.140, against Meta for each and every violation of Wash. Rev. Code. § 19.86.020 alleged herein that target or impact specific individuals, groups of individuals, or communities based on demographic characteristics, including but not limited to sex and age;

f. Order Meta to pay restitution and/or other monetary relief;

g. Disgorge Meta of money, property, or data (including any algorithms developed using such data) acquired by Meta as a result of the conduct complained of herein;

h. Award the State of Washington the costs of bringing this action, including reasonable attorney’s fees; and

i. Award any other and additional relief as the Court may determine to be just and proper.

29. For Wisconsin:

a. An order and judgment declaring Meta’s conduct to be in violation of the Wisconsin Deceptive Trade Practices Act, Wis. Stat. § 100.18(1);

b. An order and judgment requiring Meta to restore any pecuniary losses suffered by any person because of Meta’s acts or practices in violation of Wis. Stat. § 100.18(1);

c. An order and judgment permanently enjoining Meta, its successors, assigns, officers, directors, agents, dealers, servants, employees, representatives, solicitors, and all persons acting or claiming to be acting on its behalf, pursuant to Wis. Stats. §§ 100.18(11)(a) and (d) from making further false, deceptive, or misleading representations;

d. An order and judgment imposing civil forfeitures against Meta in the amount of not less than $50 nor more than $200 for each violation of Wis. Stat. § 100.18(1) pursuant to Wis. Stat. § 100.26(4), consumer protection surcharges pursuant to Wis. Stat. § 100.261, plus all applicable assessments and costs;

e. An order and judgment awarding the State of Wisconsin the expenses of investigation and prosecution of this action, including attorneys’ fees, pursuant to Wis. Stat. § 100.263; and

f. Any such other and further relief as justice and equity may require.

[43] Maine does not join in the request for monetary relief on the Filing States’ joint COPPA claim.