Meta & Children's Online SafetyPreference Amplification & Concentration of Harm
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Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 1 of 14 AMENDED Exhibit 248 PLAINTIFFS' OMNIBUS OPPOSITION TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT Case No.: 4:22-md-03047-YGR MDL No. 3047 In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation IG WELL-BEING Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 2 of 14 Preference Amplification & Concentration of Harm HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695288 Goals Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 3 of 14 1 Align on people problems & prioritization 2 Align on success metrics 3 Discussion questions 2 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695289 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 4 of 14 People Problems Problem Prioritization Success metrics Discussion Product Strategy [not in scope] HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695290 PEOPLE PROBLEMS How does harm manifest in our users? Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 5 of 14 Users with the worst IG experience (aka harm concentration) All IG users Seekers of harmful content Users driven to harmful content by Instagram Users on the path to the worst experience, thanks to IG (aka harm amplification) 4 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695291 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 6 of 14 PEOPLE PROBLEMS Preference Amplification = a user experiencing an increase in [harmful] content over time Harm Prevalence, Reach or Severity Harm = • Prevalence: e.g Going from seeing 1 violating content today to 10 in the near future • Severity: e.g Going from Hunting (does not violate any policies) -> Guns (non-rec) -> Violence (community violating). CIPCO severity framework • Reach: e.g Connected to 1 bad actor today to 10 bad actors in the near future Time Preference Amplification is the process by which a user 'rabbit-holes' into a certain type of content. The process may or may not be driven by intentful user actions. PA can happen for any content, but we're focused on harmful content. PA is mostly associated with Unconnected/Recommendation surfaces. HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695292 5 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 7 of 14 PEOPLE PROBLEMS Concentration of Harm = a user with a high prevalence of harmful content vs the average Instagram user Harm General Population Vulnerable Population Segment Concentration of harm is the situation when a user is already facing a significantly higher prevalence of harmful content in their Instagram experience, either with or without intent. It does not matter whether this harm is increasing over time. CH can happen on Connected or Unconnected surfaces HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695293 6 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 8 of 14 PEOPLE PROBLEMS Mission & Vision: Instagram needs to prevent users from preference amplification and remediate users who are experiencing concentration of harm, while respecting their intent and giving them the agency to control their experience. Remediate these users experiencing Concentration of harm All IG users Seekers of harmful content Users driven to harmful content by Instagram Prevent these users from Preference Amplification 7 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695294 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 9 of 14 PROBLEM PRIORITIZATION Who are our target users & how do we classify them? Teens (& parents/ regulators) Genpop Low intent (more likely to not want to see bad content) Includes 'Cold-start' High intent (more likely to seek out and welcome exposure to bad content) I might have engaged with a few influencer modeling pictures and now related content and have my IG my IG is full of lingerie models I actively seek out pornographic/drug Parents/Regulators: It is IG's responsibility to protect teens from harmful content I might have engaged with a couple of influencer modeling pictures and now my IG is full of lingerie models. IG can help by preventing me from this situation OR helping me 'clean up' my experience experience catered to my needs Parents/Regulators: It is IG's responsibility to protect teens from harmful content I actively seek out "alternative" news and have my Instagram experience catered to my needs. I do not want IG to actively interfere with my experience. Note: Why do we care about intent? See Appendix 9 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695296 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 10 of 14 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695297 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 11 of 14 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695298 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 12 of 14 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695300 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 13 of 14 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695301 Case 4:22-md-03047-YGR Document 2757-29 Filed 02/20/26 Page 14 of 14 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-020-00695303