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

Read this document

• "Instagram is investing in experiences targeting youth aged roughly 10- to 12."
• Meta was working to recruit "Gen Alpha before they reach teenage years" to Instagram.
• Meta employees hesitated to commission a study on bullying for fear they would discover children under 13 were being bullied
• Meta asked a vendor to conduct a survey of preteens but not to inform Meta employees if any were on Instagram
• Meta knew that roughly 90% of users claiming to be 13 years old had misrepresented their age
• 8.4% of 13 to 15 year olds had seen content relating to self-harm on Instagram within the last seven days
• Kristina Schake: "When I'm asked I'm going to be very honest about how Adam [Mosseri] dismissed our concerns [about SSI content] and told us we were over reacting and thrashing engineers"
• 6% of teen girls in the US and 13% in the UK traced their desire to self-harm or commit suicide to Instagram
• There were multiple confirmed minors using FB Dating including two who admitted to being under 12
• Instagram heavily emphasized content that promoted negative appearance comparison
• "[T]he algorithm behind new-user top-account recommendations may be unintentionally amplifying negative social comparison"
• Meta employees suggest censoring terms such as "mental health" in internal documents to avoid scrutiny