Meta & Children's Online SafetyTweens Argument
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Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 1 of 24 AMENDED Exhibit 315 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 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 2 of 24 Tweens Argument This is why we build a new Teens/Tweens App e Summary: o Tweens and Young Teens are Facebook's best opportunity to win future generations of people = This is because tweens are the earliest age at which people transition from orienting around parents to orienting around peers = Being the established app once their orient towards peers is much easier than the "10X better" which Is required to displace an existing social app o Inthe long run, this opportunity is much bigger than the present number of tweens and young teens although that number is sizeable as well = Tween sizing: e Globally in 2017, 140 million 8-12 y/o's had their own smartphone e This grows to 200 million by 2021 o From the perspective of our users: =» TIweens/Young Teens are starting to grow tired of existing apps (e.g., Snapchat and Instagram) and are looking for something new Looking for a change in the app — interaction model similar to what Snapchat did 7 years ago =» Current apps imperfectly serve tween/young teen needs o Aseparate interface/app is the best way to achieve our goals because: =» We have maximum freedom to innovate and create a novel app tailored for user needs » Wecancreatea new brand =» Wecan leverage existing family product assets and use the reach of other family apps to acquire users o The downsides are that: Itis very difficult to grow a new app Details e For our company: Tweens/young teens are Facebook's best opportunity to win future generations in the long run o Weare presently losing future generations of users. There is no indication that younger cohorts will reach the same levels as previous cohorts o Why tweens/young teens: Life stage transition of focus from parents to peers social graph = changes Opportunity for new social app(s) — o Displacing an established social media app is much harder than playing in white space. We have a much higher chance of success if we serve people before another social media app is prevalent for the cohort. o Tween Total Addressable Market = 2017: 140 million 8-12 y/o's with smartphones e 25% of global 8-12 y/o population a 2021: 200 million 8-12 y/o's with smartphones e 35% of global 8-12 y/o population = Presently, the most promising geographies are: e Tier 1: US, Canada, Westem Europe, and East Asia; of 8-12 y/o's have smartphones e 12 y/o's have smartphones Tier 2: Eastern Europe, Latin America; ~40% of 8- po Total 8-12 | EGE | IESE IGS | 5,343,902 5,343,470 5,377,139 Smartphone HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001198 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 3 of 24 3 | Eastern Europe and North Asia | Total 8-12 Smartphone | 10,868,509 | 11,679,849 | 10,868,509 | 13,048,102 | 13,606,051 4 | Latin America | Total 8-12 Smartphone | 20,725,385 | 21,827,148 | 20,725,385 | 23,791,573 | 24,681,279 5 | Middle-East and North Africa | Total 8-12 Smartphone | 16,718,245 | 18,641,176 | 16,718,245 | 22,156,250 | 23,630,934 6 | South Asia | Total 8-12 Smartphone | 23,277,515 | 28,985,862 | 23,277,515 | 42,564,694 | 49,283,062 7 | Southeast Asia | Total 8-12 Smartphone | 18,923,744 | 21,243,433 | 18,923,744 | 25,060,790 | 26,714,086 8 | Sub-Saharan Africa | Total 8-12 Smartphone | 16,502,752 | 20,507,956 | 16,502,752 | 30,363,432 | 35,337,142 9 | US Canada and Oceana | Total 8-12 Smartphone | 12,583,781 | 12,679,757 | 12,583,781 | 12,730,372 | 12,757,450 10 | Western Europe | Total 8-12 Smartphone | 11,723,287 | 11,834,289 | 11,723,287 | 11,913,740 | 11,912,349 11 | Global_Excluding_China | Total 8-12 Smartphone | 136,666,689 | 152,743,373 | 136,666,689 | 187,006,091 | 203,320,481 A | B | C | D | E | F | G 1 | | 7/1/2017 | 7/1/2018 | 7/1/2019 | 7/1/2020 | 7/1/2021 2 | East Asia | % Smartphone | 49% | 49% | 49% | 49% | 49% 3 | Eastern Europe and North Asia | % Smartphone | 43% | 45% | 43% | 48% | 49% 4 | Latin America | % Smartphone | 39% | 41% | 39% | 45% | 46% 5 | Middle-East and North Africa | % Smartphone | 31% | 34% | 31% | 38% | 40% 6 | South Asia | % Smartphone | 13% | 17% | 13% | 25% | 29% 7 | Southeast Asia | % Smartphone | 34% | 38% | 34% | 44% | 46% 8 | Sub-Saharan Africa | % Smartphone | 12% | 15% | 12% | 21% | 24% 9 | US Canada and Oceana | % Smartphone | 50% | 50% | 50% | 51% | 51% 10 | Western Europe | % Smartphone | 54% | 55% | 54% | 56% | 56% 11 | Global_Excluding_China | % Smartphone | 25% | 27% | 25% | 33% | 35% HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001199 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 4 of 24 US MAP By Year Of Birth of YearBirth 1x2 143 1999 in Bi 2000 2001 Bi 1996 Bi 2002 he i? 13 is if i? Approximate Age of Cohort a e For our users: Tweens/young teens are underserved by existing social apps o Tweens have different core needs from older teens QUESTION: We need your help in figuring out which features you want in a social media app. You will see a series of questions with different items to choose from. Always select the one you most want your dream app to have and the one you least want your dream app to have. Watch videos or listen to music with friends at the same time - even... Give me fun challenges to do with my friends when we're together Create things (videos, music) on my own and then share with others Create things (videos, music) together with my friends Connect only with really close friends Remix things (videos, music) on my own and then share with others Give mea safe space where | can share things worried about Give me a safe space where | don't feel like | have to update it all the... Remix things (videos, music) together with my friends Connect with lots of new people Share an account or profile with my best friend Share an account or profile with my family a 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Bmost least not picked o could you help with this section? | have a statement above and your max diff analysis but would benefit from your words/knowledge! e For the new app: Anew interface can leverage the strengths of the other family apps o We have other brands that resonate with teens = Instagram or WhatsApp Brand, whatever is most relevant in the country o We have reach to target tween/teens on =» FB a IG se WA o Product assets =» COPPA-compliance via Facebook = Graph from Instagram, Facebook, and WhatsApp HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001200 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 5 of 24 = Public content from Instagram and Facebook e For our team: o Anew interface gives us maximum freedom to build a highly differentiated product that will resonate with tweens and young teens = Every product has a very specific need it needs to fulfill. If you use an existing app, it would be perceived as a derivative of the existing app =» FB and |G are perceived by teens as copying other apps. And if even Snap is getting stale, and we're copying that, then that's a bad place to be o Ability to move quickly and iterate = Smaller codebase = Fewer cross-company dependencies APPENDIX e For our company: Tweens/young teens are Facebook's best opportunity to win future generations in the long run o : Show graph of how people at an earlier age still stage with us but newer cohorts are not with us as much. Show this generational change. o Social media apps get established at an earlier age, and once a patter is established and your peers are using it, there is no reason to change e For our users: Tweens/young teens are underserved by existing social apps o Would teens/tweens think they themselves have a gap? o : Tweens/teens may be tired of the existing app dynamics. Looking to fit in rather than differentiate. o Perhaps there's a social app per generation. Snap starting to feel stale. New generation itching for the new thing. o Has research on point above. o : Can use max diff results from work. o : Add more stuff here e Why tweens/young teens: Life stage transition of focus from parents to peers social graph changes = — Opportunity for new social app(s) e For the new app: Anew interface can leverage the strengths of the other family apps o We have other brands that resonate with teens = Instagram or WhatsApp Brand, whatever is most relevant in the country HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001201 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 6 of 24 o We have reach to target tween/teens on =» FB a IG se WA o Product assets =» COPPA-compliance via Facebook = Graph from Instagram, Facebook, and WhatsApp = Public content from Instagram and Facebook e For our team: o Anew interface gives us maximum freedom to build a highly differentiated product that will resonate with tweens and young teens = Every product has a very specific need it needs to fulfill. If you use an existing app, It would just be a derivative of the existing app. a FB and IG onlying copying other apps. And if Snap is getting stale, and we're copying that, then that's a bad place to be. o Ability to move quickly and iterate o Smaller codebase a : May contradict earlier branding point. Probably remove o Fewer cross-company dependencies e : Address supporting Blue in the long term o IGperhaps not sufficiently new o Over time people will tire of IG o Address need and innovate e 10X to convert from existing habit/preference versus before they form pattern of use e Need something innovative e Add the tween/teen TAM o Follow up with on the #'s e Focus on the long term LTV e Cons: o Very difficult to grow new app What is the Tweens product? e COPPA compliant for U13 e Butnot for U13 only. External positioning is for teens (aspirational AND makes market bigger) e App will be very "buzzy" and "cool" e Product will be highly social in nature (e.g., it can go on to challenge Snapchat in the future) e Product targeted for US, Western Europe, and other developed countries where Facebook is performing poorly e Variety of Options o Optimize for Family =»Version A: COPPA-Compliant version =» Version B: New interface or app o Optimize for Facebook Core App = Version C: COPPA-Compliant version =» Version D: New interface or app Tweens/Young Teen Data & Research HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001202 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 7 of 24 Summary Tweens and teens are different: * Tweens want to conform, teens want to stand out. * Tweens are insecure and parent-dependent, teens want independence. Tweens want to find themselves, teens want to show themselves. Yet, they use the same set of social apps, leaving tweens' core social needs unfulfilled. Current social apps are geared towards teens' needs mostly focus on "creativity & expression', leaving other core needs unfulfilled: * Love & comfort Adventure & exploration Belonging & inclusion Happiness & enjoyment Achievement & Success Atthe same time, tweens' core needs have been extended Into the teen years, as teens are saturated with self-presentation / "brand me" apps. They also yearn for tween-centric needs. Tweens decide which app Is for them based on the app's user base. The real driver for engagement on social media Is entertainment and emotional connections, not communication. No existing social media app feels like it was really made for them. Tweens are herd animals, and want to find communities where they can fit in. They are particularly intrigued by products that o Highlight group experiences and feelings of belonging o Strengthen connections (not communication!) to a small circle of close friends o Use entertainmentinterests as a starting point for interactive engagement (Tweens are super impatient, don't bore them by keeping them passive.) o De-emphasize self- presentation and instead highlight fitting in. (Tweens are soooo different from teens on this one.) Facebook tends to be the first social media app US tweens use. Provide a COPPA compliant solution. e Tweens use multiple apps for specific purposes, and Facebook loses ground when that happens. Provide a specific, additive use case for Facebook. Facebook in its current form is unlikely to work for tweens, because it's not clear what Facebook's purpose is. Lean into Facebook's existing strengths to provide a focused experience. Tweens need to be able to give an elevator pitch about why they need Facebook. Facebook provides pockets of unique strengths. A place for family, a hub from which social interactions start and a social archive are all unique value propositions for COPPA compliant, focused a Facebook. overindex on FB Lite https://fb.facebook.com/notes/laura-guglielmini/blue-for-u15s-identity-connections-and- interests/549509465430968/; Less performant phones, smaller footprint overindex on Profile and Messaging, e underindex on Groups Business Case Summary HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001203 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 8 of 24 Tweens and Young Teens Business Case Why Tweens and Young Teens * Life transition of focus from stage parents to peers = social praph changes Opportunity for new social apps) * Habits set at a young age have high "lifetime value" * of the best,if not the best, opportunities to win teens long term One COPPA-Compliant Version New Interface or App Shared Pros * Much more freedom on what app possibilities are built Shared Prog * Increased "space" for innovation to go beyond existing app mechanics; Independent * Piggyback off of existing app Cons possibility of creating fermi of communication a way," "third similar to how Snapchat created a new of Goal * May not be sufficiently differentiated from existing apps * Hone in an exact value proposition which can be more easily communicated Shared Cons * Value proposition would have to be highly differentiated to compete against Pros other Familyapps and Snapchat Existing Facebook Family apps, such as Instagram and VWhatsApp. * Facebook already have very strong usage and brand with the younger Pras optimizing on Family, new app could be "X App by WhatsApp" Family is the Constweenjteen demographic Because we are * or "Y App by Instagram" to benefit from the positive brand association Goal Nepotiating with Family on what experience to create for tweens/teens * Cons Constraints* on what Family apps. may "allow™ may constrain how * Connection back to family apps not well explored exactly we can tallor for tweenfyoung teen needs Pros. Pres Facebook - birect connection to Facebook Core App, which is the ultimate goal a Pewerful combination af being separate brand from Facebook but also net CoreApp * Facebook has very poor brand perception and poor usage levels Cons App fully leaving Facebook Core (blue) behind (Blue) isthe ~ by pocentially constrained the non-tweenfyoung teen version of Facebook Core App, butprobably less constrained than the COPPA- Connection back ta Facebook Core App not a space we have much in experience (perhaps Messenger the is exception) Goal compliant version of another Family App (such a3 1G and Fa) « Uncertain whether we would be a successful using new interface/app te connect back to Facebook Core App (Blue) Business Case Details Business Case for Tween/Young Teen Product, assuming FB Family usage is the end goal Situation Facebook Core App (Blue) and Messenger are losing future generations of users in developed markets to a combination of Snapchat, Instagram, and WhatsApp. What does success look like In the long term, 5- 10+ years, people in developed markets are using and having meaningful interactions at least one Facebook Family. Implications from success criteria It will not matter which Facebook Family app people use e If, for example, young people tend to use Instagram, we would be okay if they used Instagram long term over Facebook e If, for example, in the United States, Facebook became more niche and used less often and by fewer people, we would be okay with that e If, for example, we built a new app for teens, it would not need to connect very strongly back to any existing Facebook Family app Types of Products and Rationale for those Products Create COPPA-compliant version of existing family app Pros Existing Facebook Family apps, such as Instagram and WhatsApp, already have very strong usage and brand with the younger tween/teen demographic Negotiating with Family apps on what experience to create for tweens/teens Constraints on what Family apps may "allow" may constrain how exactly we can tailor for tween/young teen needs HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001204 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 9 of 24 New interface or app for tweens/young teens Pros Much more freedom on what app possibilities are built Increased "space" for innovation to go beyond existing app mechanics; possibility of creating a "third way," similar to how Snapchat created a new form of communication Hone in an exact value proposition which can be more easily communicated Because we are optimizing on Family, this new app could be "X App by WhatsApp" or "Y App by Instagram" to benefit from the positive brand association Uncertain what a new interface/app's retention might be Low level of initial awareness Connection back to family apps not well explored Value proposition would have to be highly differentiated to compete against other Family apps and Snapchat Business Case for Tween/Young Teen Product, assuming FB Blue usage is the end goal Situation Facebook Core App (Blue) and Messenger are losing future generations of users in developed markets to a combination of Snapchat, Instagram, and WhatsApp. What does success look like In the long term, 5- 10+ years, people in developed markets are using and having meaningful interactions on Facebook Core App. Implications from success criteria It does matter which Facebook Family app people use e Specifically, we want people to use Facebook Core App (Blue) in the long term e This means we would prioritize Facebook Core App (Blue) over Instagram and any other app e lfwe were to build a new app, we would want to make sure that the new app integrates back to Facebook Core App (Blue), either immediately or over the medium term Types of Products and Rationale for those Products Create COPPA-compliant version of existing Facebook Core App (Blue) Pros Direct connection to Facebook Core App, which is the ultimate goal Cons Facebook has very poor brand perception and poor usage levels Potentially constrained by the non-tween/young teen version of Facebook Core App, but probably less constrained than the COPPA-compliant version of another Family App (such as |G and FB) New interface or app for tweens/young teens Pros Much more freedom on what app possibilities are built Increased "space" for innovation to go beyond existing app mechanics; possibility of creating a "third way," similar to how Snapchat created a new form of communication Hone in an exact value proposition which can be more easily communicated Cons Uncertain what a new interface/app's retention might be Low level of initial awareness Connection back to Facebook Core App not a space we have much experience in Perhaps Messenger is the exception Uncertain whether we would be successful using a new interface/app to connect back to Facebook Core App (Blue) HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001205 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 10 of 24 Value proposition would have to be highly differentiated to compete against other Family apps and Snapchat Brainstorm on why tween / young teen product: The main idea below is that while making a social tween product is very hard, it has the highest chance of long-term success and all the other options are not as good. | am guessing the biggest argument that we need to combat is why to build a tween product instead ofjust leveraging Instagram. e Business imperative: MK needs to age up. We want teens! e can age up via three paths: o Instagram o Core App. Blue. o New Tween/Young Teen product e Instagram (There will be lots of arguments for why IG is better— we will have to address this directly) o Pros = Very strong brand among tweens = High usage levels among tweens o Cons =» Cannot tailor app for tweens because of dependencies on to the wider IG where US 75% of audience is adults. Technically, can't be nimble— legacy. =» Does not help advance Facebook Core App = Relatively "adult" product that may not be safe for tweens e Facebook o Pros = Directly funnels users to Facebook Core App o Cons = Very negative brand tax = Very negative product tax e Product is optimized for adults Tweens/teens will probably drop out of Facebook e New Tween App o Pros = Can be perfectly tailored to tween and young teen needs. Allows most aggressive differentiation. =» New brand without all the Facebook baggage e Full control of brand =» New app without all the Facebook baggage =» "Owned" by Core App so easier to funnel to Facebook in the future e Ideally app is built to be complementary to Facebook so that it is not a wholesale replacement of Core App = This may be the least hard way to, long term, onboard teens into Facebook Blue e E.g., many of the other "Big Bets" are not sufficiently social and sufficient broad o Gaming, subsegment of population o Public content and video: incredibly difficult to compete in because of existing competitors outside of FB (e.g., YouTube) and also within the FB Family (Watch, IG TV, IG Explore Tab) o Cons =» New apps are hard Difficult to differentiate against Instagram and Snapchat e However, there is likely an opportunity against Snapchat because Snapchat is aiming for older age groups (they've already saturated youth and they need more growth so going older) e Instagram, on the other hand, it will be harder because they too are trying to onboard more teens HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001206 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 11 of 24 Questions If we don't need to route to Blue, then is IG just our best option? Tweens use it now. Meets their needs enough — we should be saving resources for where our product doesn't It's FB fam. ALL: HOW IS IG WEAK FOR TWEENS? If it's weak in some way we can address, then opportunity for a new app. Research: Is |G a superior product to snapchat for Tweens (not Teens)? Tweens are more content-consumption than Teens so IG may be much more matched to their — needs. Miami Tweens all used IG more than Snap. ARGUMENT: |G is fine as a age-up. BUT: *""*ROB: IG's just maintaining with youth and not growing. Youth are moving from broadcast to messaging. So |G being the leader in feed/broadcast isn't a sustainable position. Could we create a third pillar NOW and become leaders of that'? User Research has shown an unmet need in collaborative creation/remixing. Tackling close friends through creation. Also, if we're looking at securing a kid's close friends, a kid starts forming friends in tween years, not teen years. Let's find a differentiated way to corner this market. But snap excels at close friends. What don't they dominate Tweens? Rob viewed the old Big Bets and felt that the scale and ambition didn't seem sufficiently big. Niche use cases instead of big, meaty things. Close Friends IG doesn't route to Blue because IG is just a replacement for Blue. IG wants to own messaging. ROB: Is there ANY reason why IG would insufficient'? Any reason on balance why exploring a new app would be supenor? New creation opportunities. New ways of using technology. Leaving behind the constraints Could we create a THIRD track, adding to Feed and Messaging? Some sort of creation track? Prior to Snapchat's existence, no one thought about ephemeral, this interface. We will never discover new ways of using things. IG declining? New affiliation model may indicate that they're holding. Snap can't really gain because It's so saturated. Unrelated. Memes. How are you going to beat IG on that? It's a huge discovery engine. Notes Social media behaviors are established and don't change. TAM is large Need a path from MK to 13+. And 13+ not compelling. Contact Support Conversation History HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001207 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 20 of 24 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001216 Case 4:22-md-03047-YGR Document 2758-21 Filed 02/20/26 Page 21 of 24 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-032-00001217