Excerpts from Complaint for Injunctive and Other Relief, California v. Meta

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• "Oof. This statement that mark made isn't accurate"
• Teens are exposed to harmful content on Instagram twice as much as adults
• 35% of Instagram users experienced some form of "aggression" in the previous 90 days
• An average of 12.2% of Instagram users and 16.6% of Facebook users reported seeing graphic violence.
• Meta found autoplay increased time spent for younger users and saw an "opportunity to grow time spent by personalizing auto-play rules"
• Meta executives abandoned efforts to hide Likes by default for teens despite expert advice
• "[W]e've set up an incentive structure that rewards content with catchy headlines, but then when [I] close the app, [I] feel slightly worse about myself"
• I feel even more convinced that we need to make more progress on well-being on the product side
• Meta had "no dedicated product focus to problematic use"
• Adam Mosseri declined to hide Like counts by default for teens
• "[Instagram] could stand to prioritize wellbeing higher than it currently is."
• Fidji Simo to Adam Mosseri: "The main problem is that we need to increase investment [in well-being]"
• Researchers academics and parents agree that instagram is inherently not designed for younger teens
• In a 2020 survey of 3,983 children, 22% of respondents aged 6 to 9 and 35% aged 10 to 12 had used Instagram
• The decline of 13 and 14-year-olds constituted "the most concerning problem from a strategic POV" for Instagram
• Meta received 1.1 million reports of U13 users on Instagram but disabled only a fraction of those accounts
• ████ instructed Meta employees to use stated ages for privacy and modeled ages for engagement
• Meta employee on age-verification improvements: "you probably don't want to open this pandora's box"
• Meta disabled fewer than half of the over 400000 reports of U13 users it received in 2021
• Adam Mosseri: "Tweens want access to Instagram, and they lie about their age to get it now."
• Meta had a stretch goal of 2 million hours of teen watch time on Instagram TV
• Meta had previously built experiences for users under the age of 13
• An internal chat discussed ways that Meta could utilize its teen users to recruit pre-teens
• Meta executives equivocated between identifying and removing children under 13 and preserving growth