Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 1 of 81

1 Anthony J. Russo (Texas Bar No. 241406574)

[email protected]
2 Matthew A. Dolman (pro hac vice forthcoming)
[email protected]
3
R. Stanley Gipe (pro hac vice forthcoming)
4 [email protected]
Sara D. Beller (pro hac vice forthcoming)
5 [email protected]
DOLMAN LAW GROUP
6 800 N. Belcher Rd.

7 Clearwater, FL 33765
Telephone: (727) 451-6900
8 Facsimile: (727) 451-6907

9 Attorneys for Plaintiff John Doe and His Next Friend Jane Doe
10 UNITED STATES DISTRICT COURT
11 SOUTHERN DISTRICT OF TEXAS
12 BROWNSVILLE DIVISION

13
Case No.: 1:25-cv-00172
14 JANE DOE, as guardian and next friend of
minor plaintiff, JOHN DOE, COMPLAINT
15
Plaintiff, (1) Fraudulent Concealment and
16 Misrepresentations
17 v. (2) Negligent Misrepresentation
(3) Negligence – General
18 ROBLOX CORPORATION, (4) Negligence – Failure to Warn
(5) Negligence – Unreasonable Design
19 Defendant. (6) Negligent Undertaking
(7) Strict Liability – Design Defect
20
(8) Strict Liability – Failure to Warn
21

22 JURY TRIAL DEMANDED

23

24

25

26

27

28

COMPLAINT AGAINST ROBLOX CORPORATION

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 2 of 81

1 TABLE OF CONTENTS:

2 I. INTRODUCTION ................................................................................................................. 1
3 II. PARTIES ............................................................................................................................... 2
4 A. Plaintiff ...................................................................................................................... 2
5
B. Defendant .................................................................................................................. 3
6
III. JURISDICTION AND VENUE............................................................................................ 3
7
IV. FACTUAL ALLEGATIONS AS TO ROBLOX .................................................................. 4
8
A. Roblox Offers a Gaming App for Children. .............................................................. 4
9
B. Roblox Lures Parents into Letting Their Kids Use Roblox with Promises of
10 Safety. ........................................................................................................................ 8
11
C. In Reality, Roblox Is a Digital and Real-Life Nightmare for Children. .................. 14
12
1. Roblox hosts and promotes graphic, sexually explicit content. .................. 14
13
2. Roblox provides a hunting ground for child-sex predators. ........................ 22
14
D. Roblox Knowingly Causes and Facilitates the Sexual Exploitation of
15 Children. .................................................................................................................. 30

16 1. Roblox prioritizes growth over child safety. ............................................... 30

17 2. Roblox facilitates child sexual exploitation through the design of its

app, inadequate safety features, and refusal to invest in basic safety
18 protections. .................................................................................................. 35

19 3. Roblox’s recent safety changes are woefully inadequate and fail to

address years of neglect and harm caused by its app. ................................. 44
20
V. PLAINTIFF-SPECIFIC ALLEGATIONS .......................................................................... 50
21
VI. CAUSES OF ACTION ....................................................................................................... 51
22
FIRST CAUSE OF ACTION .............................................................................................. 51
23 FRAUDULENT CONCEALMENT AND MISREPRESENTATIONS
24 (By Plaintiff Against Defendant)

25 SECOND CAUSE OF ACTION......................................................................................... 53

NEGLIGENT MISREPRESENTATION
26 (By Plaintiff Against Defendant)

27 THIRD CAUSE OF ACTION ............................................................................................ 54

NEGLIGENCE – GENERAL
28

COMPLAINT AGAINST ROBLOX CORPORATION i

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 3 of 81

1 (By Plaintiff Against Defendant)

2 FOURTH CAUSE OF ACTION......................................................................................... 60

NEGLIGENCE – FAILURE TO WARN
3 (By Plaintiff Against Defendant)
4
FIFTH CAUSE OF ACTION ............................................................................................. 64
5 NEGLIGENCE – UNREASONABLE DESIGN
(By Plaintiff Against Defendant)
6
SIXTH CAUSE OF ACTION ............................................................................................. 67
7 NEGLIGENT UNDERTAKING
(By Plaintiff Against Defendant)
8

9 SEVENTH CAUSE OF ACTION ...................................................................................... 69

STRICT LIABILITY – DESIGN DEFECT
10 (By Plaintiff Against Defendant)
11 EIGHTH CAUSE OF ACTION .......................................................................................... 74
STRICT LIABILITY – FAILURE TO WARN
12 (By Plaintiff Against Each Defendant)
13
VII. PRAYER FOR RELIEF ...................................................................................................... 77
14
VIII. DEMAND FOR A JURY TRIAL ....................................................................................... 78
15

16

17

18

19

20

21

22

23

24

25

26

27

28

COMPLAINT AGAINST ROBLOX CORPORATION ii

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 4 of 81

1 Jane Doe, as guardian and next friend of minor Plaintiff John Doe (“Plaintiff”), brings this

2 action against Roblox Corporation (“Roblox” or “Defendant”) to recover damages arising from the

3 severe injuries that Plaintiff suffered because of Defendant’s conduct in creating, designing,

4 marketing, and distributing its mobile- and web-based application (“app”), and alleges as follows:

5 I. INTRODUCTION

6 1. This action seeks to hold Roblox accountable for recklessly and deceptively

7 operating businesses in a way that led to the sexual exploitation of Plaintiff. The heinous acts

8 against Plaintiff were committed by dangerous child predators whose actions were possible only

9 because of the egregiously tortious conduct of Defendant.

10 2. Through its pervasive patterns of misrepresentations about safety, Defendant
11 portrays its app as a safe and appropriate places for children to play. In reality, and as Defendant

12 well knows, the design of its app makes children easy prey for pedophiles, and Defendant had no

13 appropriate safeguards to ensure that children were in fact safe or that predators were screened.

14 There are steps that Defendant could have taken to protect children and to make its app safer. But

15 time and again Defendant has refused to invest in basic safety features to protect against exactly

16 the kind of exploitation that Plaintiff suffered.

17 3. The reason for Defendant’s unlawful conduct is simple: Defendant prioritizes

18 growing the number of users of its app over child safety. As one former Roblox employee explained

19 in describing the company’s approach to child safety, “You have to make a decision, right? You

20 can keep your players safe, but then it would be less of them on the platform. Or you just let them

21 do what they want to do. And then the numbers all look good and investors will be happy.” 1

22 Defendant’s prioritization of growth over the safety of children has devastated the lives of children

23 who use its app.

24 4. Plaintiff is currently an 8-year-old boy who was an avid user of Defendant’s app.

25 He relied heavily on the app for entertainment and social interaction, making him a prime target

26

27 1
Roblox: Inflated Key Metrics for Wall Street and a Pedophile Hellscape for Kids, Hindenburg
28 Research (Oct. 8, 2024), https://hindenburgresearch.com/roblox/.

COMPLAINT AGAINST ROBLOX CORPORATION 1

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 5 of 81

1 for the countless child predators that Defendant knew were freely roaming the app looking for

2 vulnerable children.

3 5. Plaintiff was targeted on Roblox by a predator who posed as a fellow child and

4 exploited Plaintiff’s age and vulnerability to build a false emotional connection with him by

5 promising friendship and connection. After capturing his trust, the predator escalated her grooming

6 of Plaintiff on Roblox. The predator sent Plaintiff graphic messages describing sexual acts she

7 intended to do to Plaintiff and sent him sexually explicit images of herself. The predator also

8 convinced Plaitniff to send her a sexually explicit image of himself.

9 6. Plaintiff suffered this sexual exploitation and abuse as the direct result of
10 Defendant’s conduct. For years, Defendant has misrepresented and deliberately concealed

11 information about the pervasive predatory conduct that its app enables and facilitates. Had

12 Defendant disclosed the truth of what was really occurring on its app, Plaintiff’s mother would

13 never have permitted Plaintiff to use this app without her strict supervision. Had Defendant taken

14 any steps to screen users before allowing them on the apps, Plaintiff would not have been exposed

15 to the large number of predators trolling the platform. Had Defendant implemented even the most

16 basic system of age and identity verification, as well as effective parental controls, Plaintiff would

17 never have engaged with this predator and never been harmed.

18 7. Plaintiff has suffered unimaginable harm. Tragically, what happened to him is far
19 from an isolated event. Indeed, Plaintiff is just one of countless children whose lives have been

20 devastated as a result of Defendant’s gross negligence and defectively designed app This action,

21 therefore, is not just a battle to vindicate Plaintiff’s rights—it is a stand against Defendant’s

22 systemic failures to protect society’s most vulnerable from unthinkable harm in pursuit of financial

23 gain over child safety.

24 II. PARTIES
25 A. Plaintiff

26 8. Minor Plaintiff John Doe, and his mother and next friend Jane Doe, are citizens and

27 residents of the State of Texas, with a principal place of residence in Cameron County.

28

COMPLAINT AGAINST ROBLOX CORPORATION 2

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 6 of 81

1 9. Plaintiff has suffered profound and enduring harm. This includes significant

2 emotional distress, psychological trauma, and mental anguish. Plaintiff’s experiences have led to a

3 loss of trust, safety, and personal security, depriving him of the opportunity for a normal and

4 healthy development. The injuries he sustained are severe, ongoing, and permanent, affecting his

5 daily life and emotional health in lasting and immeasurable ways.

6 10. Plaintiff never entered into any contract with Defendant. To the extent Defendant

7 claims that Plaintiff attempted to accept an electronic terms and conditions clause by clicking

8 buttons on a screen that included language that Plaintiff did not read or understand, such an

9 assertion is legally erroneous, invalid, and unenforceable, including because Plaintiff disaffirms
10 any such contract, including any forced arbitration clause and any delegation clause in any contract.

11 B. Defendant
12 11. Defendant Roblox Corporation is a Delaware corporation with its principal place of

13 business in San Mateo, California. Roblox owns, operates, controls, produces, designs, maintains,

14 manages, develops, tests, labels, markets, advertises, promotes, supplies, and distributes the Roblox

15 app. Roblox is widely available to consumers throughout the United States, including the State of

16 Texas.

17 III. JURISDICTION AND VENUE

18 12. This Court has subject-matter jurisdiction over this action under 28 U.S.C. § 1332(a)

19 because Plaintiff and Defendant are citizens of different states and the amount in controversy

20 exceeds $75,000. This Court has jurisdiction over Defendant Roblox because Defendant regularly

21 conduct and solicit business in the State of Texas, provides products and/or services by or to

22 persons here, and derives substantial revenue from the same. Defendant affirmatively and

23 extensively engages with a significant percentage of this State’s residents through messages,

24 notifications, recommendations, and other communications. Further, a substantial part of the events

25 or omissions giving rise to the claims, caused by Defendant Roblox, occurred in the State of Texas.

26 13. Venue is proper here under 28 U.S.C. § 1391(b)(2) because a substantial part of the

27 events or omissions giving rise to the claims occurred in this District.

28

COMPLAINT AGAINST ROBLOX CORPORATION 3

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 7 of 81

1 IV. FACTUAL ALLEGATIONS AS TO ROBLOX

2 A. Roblox Offers a Gaming App for Children.

3 14. Launched in 2006, Roblox is an online gaming app that allows users to play myriad

4 games, which the company refers to as “experiences.” There are currently more than 40 million

5 experiences within the Roblox ecosystem. Most experiences on Roblox are created not by Roblox

6 but by individuals (often Roblox users) or companies that develop their own games and make them

7 available on Roblox for others to play.

8 15. Roblox is easily accessible, including to children. It is free to download and play and

9 is available on gaming consoles, computers, tablets, and cellular devices.

10 16. Roblox is designed to be an interactive experience, allowing and encouraging users
11 to communicate with each other. Gameplay interactions, user hubs, direct messaging, and voice chat

12 all promote social interactions between users. Roblox’s co-founder and CEO David Baszucki has

13 explained that his vision is for Roblox to bring about “the next phase of human interaction,” which

14 he also has described as “a new category of human coexperience.” 2 Roblox has similarly explained

15 that it “operates a human co-experience platform . . . where users interact with each other to explore

16 and develop immersive, user-generated, 3D experiences.” 3

17 17. Roblox designed its app for children. Roblox has marketed its app not only as the

18 “#1 gaming site for kids and teens” 4 but also as an educational experience for young users. Roblox

19 claims that it provides “new gateways into learning”—from “chemistry to physics to robotics and

20 more, Roblox experiences bring concepts to life in ways that immerse learners and motivate

21 exploration, play, and deep thinking.” 5 These offerings, according to Roblox, include “high-quality,

22

23

24 2
David Baszucki, Co-founder and CEO of Roblox, The CEO of Roblox on Scaling Community-
Sourced Innovation, Har. Bus. Rev., The Magazine, (Mar-Apr 2022), https://hbr.org/2022/03/the-
25
ceo-of-roblox-on-scaling-community-sourced-innovation.
3
26 Roblox Corp., Quarterly Report (Form 10-Q) (Mar. 13, 2021).
4
Roblox, What Is Roblox, http://web.archive.org/web/20170227121323/https://www.roblox.com/
27 (archived Feb. 27, 2017).
5
Roblox, A New Era of Engaged Learning, https://corp.roblox.com/education (last visited Feb.
28 11, 2025).
COMPLAINT AGAINST ROBLOX CORPORATION 4
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 8 of 81

1 standards-aligned, immersive educational experiences designed by curriculum experts.” 6

9
10

11
Roblox webpage – “A New Era of Engaged Learning”
12 18. Roblox’s popularity among children exploded during the pandemic when the app
13 was flooded with millions of new users as kids were confined to their homes and glued to their

14 devices. By September 2020, roughly 30 million people, more than half of them under 13, were on

15 Roblox daily, making it the world’s biggest recreational zone for kids.

16 19. That growth has continued unabated. In Roblox’s 2023 Annual Report, the company
17 reported an average of 68.5 million daily active users, with 21% under 9 years of age; 21% from 9-

18 12 years of age; 16% from 13-16 years of age; and 41% over 17 years of age.

19 20. Today, Roblox is the most downloaded online game globally, and the average user
20 spends 139 minutes a day on the app. 7

21 21. Individuals who wish to play Roblox must create an account. It is extremely easy to
22 “SIGN UP AND START HAVING FUN!” Users must provide only a birthdate, username, and

23 password. Users of any age can create an account. There is no age minimum. Roblox does not

24 require users to verify their age upon sign-up, so they can easily represent that they are younger or

25

26

27 6
Id.
7
Qustodio, Research by App Category – Gaming, https://www.qustodio.com/en/the-digital-
28 dilemma/gaming/ (last visited Feb. 11, 2025).

COMPLAINT AGAINST ROBLOX CORPORATION 5

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 9 of 81

1 older than their actual age.

9
10

11

12

13 Roblox Sign-up Screen

14 22. Although Roblox states that children must have parental permission before signing
15 up for an account, nothing prevents them from creating their own accounts and playing on Roblox.

16 Roblox does nothing to confirm or document that parental permission has been given, no matter

17 how young a child is. Nor does Roblox require a parent to confirm the age given when a child signs

18 up to use Roblox.

19 23. After creating an account, all users are assigned a default player avatar—a cartoonish
20 character that represents the individual user within certain games.

21

22

23

24

25

26

27 Example default avatar on Roblox.

28 24. They can then play in millions of experiences on the app. These games are sorted

COMPLAINT AGAINST ROBLOX CORPORATION 6

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 10 of 81

1 into different genres/categories, such as Sports, Role-Playing Games, Fighting, First Person

2 Shooters, Fashion, Horror, Comedy, Military, and Naval. The games recommended to a user will

3 vary based on the age the user entered when generating their account and Roblox’s algorithm that

4 recommends games to the user.

9
10

11

12
Examples of games available on Roblox.
13
25. Until November 2024, Roblox configured its app to default to settings that allowed
14
adults to easily communicate with children. Adult strangers could “friend” and chat with a child of
15
any age via direct (i.e., private) message. Further, even without being “friends,” adults could also
16
chat with a child of any age within a Roblox experience through direct messages.
17
26. Now, under Roblox’s default settings, adults cannot directly message children under
18
13, but Roblox still does nothing to prevent children this young from creating accounts with fake
19
13+ birthdates, which gives them full access to Roblox’s direct-messaging options. Roblox still
20
relies on self-reported birthdates for age verification. Further, children 13 and over are still
21
vulnerable to receiving friend requests—or direct messages within Roblox experiences—from adult
22
strangers. There is also nothing that prohibits adults from entering fake birthdays and posing as
23
children in their attempts to friend or otherwise communicate with children users.
24
27. Roblox generates revenue largely by selling users an in-game digital currency called
25
Robux, which they exchange for digital content such as online experiences and customized outfits
26
and appearances for their avatars. Robux can be purchased in a single transaction or a user may
27
subscribe to receive Robux on a recurring basis with a Roblox Premium membership. Roblox also
28

COMPLAINT AGAINST ROBLOX CORPORATION 7

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 11 of 81

1 offers Robux gift cards that anyone can purchase and send to any user.

2 28. Children frequently become obsessed with purchasing or otherwise obtaining Robux

3 to buy items for their avatars and to spend in their favorite experiences on Roblox. In Roblox’s

4 Avatar Store, for example, the company sells rare items at astronomical prices, such as a type of

5 hair for an avatar, which children seek to purchase to keep up with or outdo their peers on Roblox.

6 As a result, children often tell others, including strangers, that they will do “Anything for Robux.” 8

7 B. Roblox Lures Parents into Letting Their Kids Use Roblox with Promises of

8 Safety.

9 29. Roblox’s success and continued growth have hinged on its constant, false assurances
10 to parents that its app is safe for children. The company has offered such assurances throughout its

11 history and in every forum possible—on its website, through public promises of its highest

12 executives, in news articles, on podcasts, and on and on.

13 30. Over the years, Roblox has repeatedly represented on its website that its app is safe
14 for children and has touted the safety controls it has in place. As early as 2007, Roblox’s website

15 assured parents that Roblox is an “online virtual playground . . . where kids of all ages can safely

16 interact, create, have fun, and learn.” 9

17 31. From 2008 to 2016, the website continued to promise parents, “We take every

18 precaution possible to make sure kids are protected from inappropriate and offensive individuals as

19 well as from indecent and distasteful content.” 10 It also assured parents that Roblox had a zero-

20 tolerance policy for “swearing and obscenities, messages and content of a sexual or violent nature,

21 and any sort of aggressive or threatening communication,” and “immediately suspended or

22
8
23 Olivia Carville & Cecilia D’Anastosio, Roblox’s Pedophile Problem, Bloomberg Businessweek
(July 23, 2024), https://www.bloomberg.com/features/2024-roblox-pedophile-problem/.
24 9
Roblox, Frequently Asked Questions (FAQs),
https://web.archive.org/web/20071105104643/http://www.roblox.com/Parents/FAQs.aspx
25
(archived Nov. 5, 2007).
10
26 Roblox, Keeping Kids Safe,
https://web.archive.org/web/20080501101437/http://www.roblox.com/Parents/KeepingKidsSafe.a
27 spx (archived May 1, 2008); see also Roblox, Information for Parents,
https://web.archive.org/web/20160131063648/http://corp.roblox.com/parents (archived Jan. 31,
28 2016).
COMPLAINT AGAINST ROBLOX CORPORATION 8
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 12 of 81

1 permanently expelled” any offenders. 11

2 32. The website has consistently sought to paint Roblox as “family friendly” and safe for

3 children of all ages. In 2017, Roblox began declaring that it “take[s] kids’ safety and privacy very

4 seriously” and “strive[s] to continually develop new and innovative technologies that will protect

5 the safety of our community while allowing players to imagine, create, and play together in a family-

6 friendly environment.” 12 Roblox similarly has advertised its app as “a safe, moderated place to meet,

7 play, chat, and collaborate on creative projects.” 13

9
10

11

12

13

14

15

16

17

18

19 Excerpt from Roblox Parent’s Guide in 2017

20 33. Roblox’s website representations have remained largely unchanged since then. In
21 2023, for example, Roblox assured parents that it “continually develop[s] cutting-edge technologies

22 to ensure that the Roblox platform remains a safe and fun space for players all over the world.” 14

23

24 11
Id.
12
Roblox, Parents’ Guide,
25
https://web.archive.org/web/20170716032712/https://corp.roblox.com/parents/ (archived Jul. 16,
26 2017).
13
Id.
27 14
Roblox, For Parents,
https://web.archive.org/web/20230405060048/https://corporate.roblox.com/parents/ (archived
28 Apr. 5, 2023).
COMPLAINT AGAINST ROBLOX CORPORATION 9
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 13 of 81

1 Roblox claimed that the company was “dedicated to working together with parents and digital safety

2 experts to promote a family-friendly environment that allows all players to imagine, create, and play

3 online.” 15 Roblox emphasized that it is “committed to ensuring that Roblox is a safe and fun place

4 for everyone.” 16 According to Roblox, it “goes above and beyond to foster an environment where

5 people of any age can create, play, learn, and imagine safely. We’ve kept children’s privacy and

6 safety top-of-mind when designing our platform, especially through the implementation of advanced

7 text filters that block inappropriate language or other unsafe content.” 17

8 34. Roblox’s website today contains similar assurances. It claims, “Safety is in our DNA:

9 when Dave Baszucki and Erik Cassel launched Roblox in 2006, they spent a few hours each day
10 with the community, helping to ensure that Roblox was a safe and welcoming environment. Safety

11 was their top priority, and they made constant improvements in their moderation, both for content

12 and for communication on the platform.” 18

13 35. According to the current website, Roblox “won’t allow language that is used to

14 harass, discriminate, incite violence, threaten others, or used in a sexual context.” 19 Roblox touts a

15 “stringent safety system and policies,” 20 which include its “expertly trained team with thousands of

16 members dedicated to protecting our users and monitoring for inappropriate content”; its “safety

17 review of every uploaded image, audio, and video file, using a combination of review by a large

18 team of human moderators and machine detection before they become available on our platform”;

19

20
15
Id.
21 16
Roblox, Roblox FAQ,
22 https://web.archive.org/web/20230328011957/https://corporate.roblox.com/faq/ (archived Mar.
28, 2023).
17
23 Roblox, Roblox & User Data FAQ, https://en.help.roblox.com/hc/en-
us/articles/4406238486676-Roblox-User-Data-FAQ (last visited Feb. 11, 2025).
24 18
Roblox, Safety Comes First on Roblox, https://corp.roblox.com/safety-civility-
resources?section=news&article=safety-comes-first-on-roblox (last visited Feb. 11, 2025).
25 19
Roblox, Safety Features: Chat, Privacy & Filtering, https://en.help.roblox.com/hc/en-
26 us/articles/203313120-Safety-Features-Chat-Privacy-
Filtering#:~:text=Players%20have%20different%20safety%20settings,and%20phrases%2%200tha
27 n%20younger%20players (last visited Feb. 11, 2025).
20
Roblox, Safety & Civility at Roblox, https://en.help.roblox.com/hc/en-
28 us/articles/4407444339348-Safety-Civility-at-Roblox (last visited Feb. 11, 2025).
COMPLAINT AGAINST ROBLOX CORPORATION 10
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 14 of 81

1 and its chat filters for inappropriate content, which “are even stricter” for children under 13 and

2 “include any potentially identifiable personal information, slang etc.” 21

3 36. These false promises and assurances are not confined to Roblox’s website. They are

4 repeated in statements by the company’s highest executives—including in direct response to

5 concerns raised by parents.

6 37. In 2009, a blogger wrote about blocking Roblox because he doubted its safety for his

7 children. CEO David Baszucki responded to the blogger reassuring him that Roblox flags

8 “obviously offensive content” and removes it, and if “something is marginal, but gets flagged as

9 inappropriate,” Roblox “investigate[s] immediately.” 22

10 38. In a 2013 Wired interview, when asked whether a parent should be concerned about
11 whom his child was chatting with in-game, Baszucki declared, “We take every precaution possible

12 to make sure kids are protected from inappropriate and offensive individuals as well as from

13 indecent and distasteful content,” taking a sentence verbatim from Roblox’s webpage for parents.23

14 39. Tami Bhaumik, Roblox’s current Vice President of Civility & Partnerships, has

15 doubled down on these promises in statements to parenting magazines, news outlets, and podcasts—

16 all aimed at persuading parents to let their children use Roblox. She also has contacted international

17 online safety experts in an effort to sell Roblox’s safety story.

18 40. As recently as 2024, Bhaumik told Parents Magazine that “[w]e have a responsibility

19 to make sure our players can learn, create, and play safely. This continues to be our most important

20 priority and that will never change.” 24

21

22

23

24
21
Id.
25 22
Eric Frenchman, Revisiting Roblox, Pardon My French (Oct. 5, 2009),
26 https://pardonmyfrench.typepad.com/pardonmyfrench/2009/10/revisiting-roblox.html.
23
Tony Sims, Interview with David Baszucki, Founder & CEO of Roblox, Wired (Feb. 7, 2013),
27 https://www.wired.com/2013/02/roblox/.
24
Maressa Brown, Is Roblox Safe for Kids? Here’s What the Experts Have to Say, Parents
28 Magazine (Apr. 29, 2024), https://www.parents.com/kids/safety/internet/is-roblox-safe-forkids/.

COMPLAINT AGAINST ROBLOX CORPORATION 11

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 15 of 81

9 41. Such statements by Bhaumik date back years. In 2018, Bhaumik told the Washington
10 Post that Roblox “focus[es] on making sure that everything is done in a safe and appropriate way.” 25

11 That year, she also claimed to another newspaper that Roblox’s “safety team reviews every uploaded

12 image, video, and audio file used within our games to make sure they are safe and age appropriate.”26

13 She also boasted that Roblox has “created extensive parental controls for our games and a detailed

14 Roblox Parent’s Guide that provides information to parents to help create a Roblox experience that’s

15 best for their child.” 27

16 42. In 2019, while presenting on a “Digital Civility Panel,” Bhaumik emphasized that
17 “[w]e make sure there’s a safe environment,” citing Roblox’s “tremendous reporting system” and

18 “incredible moderation and CS team that reacts very, very quickly.” 28 On that same panel—and in

19 contradiction to Roblox’s representation that it had always taken “every precaution possible” to

20 protect children—Bhaumik conceded that “digital civility did not exist at Roblox a year and a half

21

22 25
Hayley Tsukayama, Roblox, an Online Kids Game, Explains How a Hack Allowed a
23 Character’s Virtual ‘Rape’, Wash. Post. (Jul. 17, 2018),
https://www.washingtonpost.com/technology/2018/07/17/roblox-an-online-kids-game-explains-
24 how-hack-allowed-characters-virtual-rape/.
26
Chris Pollard, Police Warn that Children as Young as Five-Years-Old are Seeing Naked Lego-
25
Type Characters Having Sex on Roblox App, The Sun (Jan. 29, 2018),
26 https://www.thesun.co.uk/news/5445444/roblox-app-children-danger-sex-warning/.
27
Id.
27 28 YouTube, Digital Civility Panel (Oct. 23, 2019),
https://www.youtube.com/watch?v=XoUs1Js7WG0&list=PLcKphP00N1_kCLjvcOWdwbegJkNS
28 L-CuL&index=6.

COMPLAINT AGAINST ROBLOX CORPORATION 12

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 16 of 81

1 ago and we established this and made it a movement within our company.” 29 She added later, “It’s

2 still very early days for us. This whole digital civility focus for Roblox is still there, we’re just still

3 establishing it.” 30

4 43. In a 2022 video interview about safety on Roblox, Bhaumik asserted that Roblox’s

5 “number one priority” is “to create a safe, civil, and inclusive community” and that “[s]afety and

6 civility has always been baked into everything that we do.” 31 That year, on a podcast, she also

7 bragged about Roblox’s purported safety protections, including “thousands of human moderators

8 on the front lines” and “machine learning that is constantly taking a look at chat filters.” 32 With

9 these and other measures, she exclaimed, “[a]ny sort of bad actor that comes onto the platform is
10 dealt with swiftly” and “[w]e remove any content that’s reported to us within minutes.” 33

11 44. In 2023, Matt Kaufman, formerly the Chief Systems Officer for Roblox, was

12 appointed Chief Safety Officer, at which point he too began peddling Roblox’s child safety

13 narrative.

14 45. In a 2024 blog post on Roblox’s website, Kaufman asserted that “Roblox has spent

15 almost two decades working to make the platform one of the safest online environments for our

16 users, particularly the youngest users. Our guiding vision is to create the safest and most civil

17 community in the world.” 34 According to Kaufman, “For users under 13, our filters block sharing

18 of personal information and attempts to take conversations off Roblox, where safety standards and

19 moderation are less stringent.” 35 A few months later, he added, “Safety is and always has been

20

21

22 29
Id.
30
23 Id.
31
Video Interview with Tami Bhaumik, Roblox’s VP of Digital Civility & Partnerships (2022),
24 https://www.facebook.com/bedford.sheriff/videos/roblox-how-to-help-kids-use-itsafelyrobloxs-
vp-of-digital-civility-partnerships/1338989609901259/.
25 32
YouTube, Into the Metaverse, Podcast: EP.21: Tami Bhaumik (Roblox) - Building a Safe &
26 Resilient Metaverse, https://www.youtube.com/watch?v=LT5_bBOYS9A.
33
Id.
27 34
Matt Kaufman, Chief Safety Officer, Driving Civility and Safety for All Users, Roblox (July 22,
2024), https://corp.roblox.com/newsroom/2024/07/driving-civility-and-safety-for-allusers.
28 35
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 13
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 17 of 81

1 foundational to everything we do at Roblox.” 36

2 46. In a later blog post, Kaufman touted Roblox’s “track record of putting the safety of

3 the youngest and most vulnerable people on our platform first.” 37

4 47. Kaufman also recently told NPR that “any time anything happens to a child that puts

5 them at risk is one too many.” 38

6 C. In Reality, Roblox Is a Digital and Real-Life Nightmare for Children.

7 48. Roblox’s public statements and promises are carefully crafted to paint the picture of

8 a digital playground that is safe and appropriate for children. When parents, the press, or child

9 advocates raise questions and concerns, the company’s highest executives respond with comforting
10 promises of safety.

11 49. This campaign of reassurance masks the truth about Roblox. Far from creating a
12 safe place for children, Roblox designed, built, and maintains a toxic environment that has enabled

13 obscene material to flourish and, worse, enables predatory pedophiles to hunt, groom, and sexually

14 exploit children. What Roblox represents as a safe, appropriate space for children is, in fact, a

15 digital and real-life nightmare for kids.

16 1. Roblox hosts and promotes graphic, sexually explicit content.

17 50. Roblox is a vast ecosystem offering an endless array of not just online games but
18 also immersive virtual worlds where children’s customized avatars can engage in activities like

19 playing house, adopting pets, and mimicking adult behaviors, including sexually explicit ones.

20 51. These games and virtual worlds are brought to life through developer tools that
21 Roblox designs, controls, and makes available to third parties. These tools, which include scripting

22 capabilities, 3D modeling systems, and other software supply the infrastructure needed to create

23

24 36
Matt Kaufman, Chief Safety Officer, Major Updates to Our Safety Systems and Parental
Controls, Roblox (Nov. 18, 2024), https://corp.roblox.com/newsroom/2024/11/major-updates-to-
25
our-safety-systems-and-parental-controls.
37
26 Matt Kaufman, Chief Safety Officer, Scaling Safety and Civility on Roblox, Roblox (Apr. 4,
2024), https://corp.roblox.com/newsroom/2024/04/scaling-safety-civility-roblox.
27 38
Scott Tong & James Perkins Mastromarino, Roblox Chief Safety Officer on New Safety
Features, Past Cases of Child Abuse on the Platform, WBUR (Nov. 18, 2024),
28 https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.
COMPLAINT AGAINST ROBLOX CORPORATION 14
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 18 of 81

1 content for the Roblox platform. Roblox has the power to control the use of these tools. Instead,

2 over the years, the company has given third parties essentially unfettered access to use the tools to

3 build what they want, with no meaningful oversight or safeguards. The results are deplorable.

4 52. As early as 2010, Roblox’s virtual games had already devolved into hosting and

5 promoting sexually explicit content. Roblox’s scripting language, which allows developers to

6 manipulate avatar activity and interactions any way they want, was deployed to create scenarios

7 where avatars engaged in simulated sexual activity. 39

8 53. This simulated sexual activity pervades Roblox. There have been numerous reports

9 of children’s avatars being raped by other users’ avatars. For example, in 2018, a seven-year-old
10 girl’s avatar was violently raped by two male avatars on a playground in a Roblox experience,

11 which was witnessed by the girl’s mother. 40 In describing the aftermath of this traumatic

12 experience, the girl’s mother exclaimed, “I never in my wildest dreams would’ve ever imagined

13 that I would have to talk with my seven-year-old about rape.” 41

14 54. Roblox also hosts a staggering number of experiences centered on simulated sexual

15 activity. For instance, children can play in “condo games”—predatory digital environments,

16 including houses, where users can remove their avatars’ virtual clothing, revealing nudity, and

17 engage in disturbing simulated sexual activities with other Roblox users. 42 They can also play

18 games like “Public Bathroom Simulator Vibe,” which allows access to users as young as nine

19 years old and enables users to simulate sexual activity in virtual bathrooms, 43 as well as virtual

20

21
39
22 See, e.g., YouTube, How to Do Roblox Sex Glitch,
https://www.youtube.com/watch?v=Zz97Q1SQE_k; see also YouTube, Roblox Sex?,
23 https://www.youtube.com/watch?v=hyqCHG6nUYI.
40
Savannah Levins, North Carolina Mom Outraged After Roblox Game Depicts Violent Acts,
24 Including Rape, WFMYNews2 (June 30, 2018),
https://www.wfmynews2.com/article/news/local/2-wants-to-know/north-carolina-mom-outraged-
25
after-roblox-game-depicts-violent-acts-including-rape/83-569498171.
41
26 Id.
42
EJ Dickson, Inside the Underground Strip-Club Scene on Kid-Friendly Gaming Site Roblox,
27 Rolling Stone (Sep. 12, 2021), https://www.rollingstone.com/culture/culture-features/roblox-
virtual-strip-clubs-condo-games-sex-1197237/.
28 43
Hindenburg, supra note 1.
COMPLAINT AGAINST ROBLOX CORPORATION 15
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 19 of 81

1 strip clubs, where child avatars perform sexually explicit acts, like giving lap dances to patrons. 44

9
10

11
Roblox’s Public Bathroom Simulator Game is rated ages nine and up and
12 allows users to simulate sexual activity. 45
13 55. A recent investigative report also exposed a multitude of other exploitative

14 experiences on Roblox that recklessly trivialize and gamify serious criminal conduct, including

15 rape. The report confirmed that Roblox actively hosted over 600 “Diddy” games, with titles like

16 “Survive Diddy,” “Run from Diddy Simulator,” and “Diddy Party,” which appear to recreate

17 reported incidents involving the music mogul Sean Combs, publicly known as “Diddy.” Diddy

18 was recently indicted and is on trial for sex trafficking of minors and other grievous criminal

19 charges regarding allegations surrounding reports about “freak-off” parties—events which,

20 according to multiple lawsuits and media reports, allegedly involved forced drug use, violent

21 assaults, and the sex trafficking of minors, including victims as young as 10 years old.

22

23

24

25

26

27
44
Dickson, supra note 42.
28 45
Hindenburg Research, supra note 1.
COMPLAINT AGAINST ROBLOX CORPORATION 16
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 20 of 81

9
10

11

12
Examples of Roblox games modeled after Diddy’s sex trafficking ventures. 46
13 56. This report also revealed that Roblox permitted more than 900 Roblox accounts
14 displaying variations of convicted sex trafficker Jeffrey Epstein’s name, such as

15 “JeffEpsteinSupporter,” whose account Roblox actively permitted to be openly engaged in

16 children’s games. Roblox also allowed games like “Escape to Epstein Island”—a title that directly

17 references one of the locations where for years Epstein trafficked minors and other non-consenting

18 individuals so he and others could sexually and physically abuse them.

19

20

21

22

23

24

25
Example of Roblox game modeled after Jeffrey Epstein’s sex trafficking ventures. 47
26

27
46
Id.
28 47
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 17
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 21 of 81

1 57. Roblox played a direct role in enabling these rampant, sexually exploitative

2 experiences. Roblox is fully aware that these experiences pervade its app, and it allows them to

3 continue to exist unchecked despite the ability to control or eliminate them. Leaked internal

4 Roblox documents reveal that Roblox monitored this type of content and made decisions such as

5 “[h]ow big of a ‘bulge’” was acceptable, and, with the introduction of layered clothing for avatars

6 (i.e., allowing avatars to wear multiple layers of clothing), whether players could be nude. 48 By

7 allowing this type of content to exist and be easily accessible, Roblox directly contributed to the

8 proliferation of games simulating sexual activity, such as condo games and virtual strip clubs.

9 58. The effects of these games on children can be devastating. Playing video games
10 with explicit sexual content normalizes exploitative and predatory behavior, blurring the lines of

11 what is acceptable in real life. This is particularly harmful for children, who are still developing

12 their understanding of social norms and morality. When such behavior is depicted as humorous,

13 exciting, or rewarded within a game, young players can internalize the idea that harassment or

14 sexual exploitation is harmless or even acceptable.

15 59. Studies support this connection. One study found that playing games with
16 sexualized content was linked to increased rates of sexual harassment toward female targets,

17 suggesting that such exposure desensitizes players to the real-world consequences of these

18 actions. 49 Another study showed that playing mature-rated games was associated with higher rates

19 of risky sexual behavior years later, highlighting the long-term impact of exposure to sexualized or

20 exploitative content. 50

21 60. The interactive nature of games amplifies this effect. Unlike passive media, video

22 games require players to actively participate in behaviors, including those that simulate

23

24
48
Joseph Cox & Emanuel Malberg, Leaked Documents Reveal How Roblox Handles Grooming
25
and Mass Shooting Simulators, Vice (Aug. 1, 2022), https://www.vice.com/en/article/leaked-
26 documents-how-roblox-moderates-content-mass-shootings-grooming/.
49
Jonathan Burnay, Brad J. Bushman & Frank Larøi, Effects of Sexualized Video Games on
27 Online Sexual Harassment, 45 Aggressive Behavior 2, 214 (March/April 2019).
50
Jay G. Hull et al., A Longitudinal Study of Risk-Glorifying Video Games and Behavior
28 Deviance, J. Pers. Soc. Psychol. 2014 August; 107(2): 300–325. doi:10.1037/a0036058.

COMPLAINT AGAINST ROBLOX CORPORATION 18

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 22 of 81

1 harassment or exploitation, reinforcing the perception that such actions are normal or desirable.

2 This environment not only desensitizes children but also makes them more likely to replicate these

3 actions in real-world interactions.

4 61. The dangerous content on Roblox is not limited to online games. The recent

5 investigative report discussed above found that a basic search for “adult” in Roblox revealed a

6 group with 3,334 members “openly trading child pornography and soliciting sexual acts from

7 minors.” 51 And tracking these members unearthed additional Roblox groups engaged in the same

8 criminal conduct, including one massive group with 103,000 members. 52 Yet Roblox failed to

9 implement any age restrictions on these criminal groups, deliberately leaving them accessible to
10 all users. 53

11

12

13

14

15

16

17

18

19

20

21

22

23
Public chat wall for a group named “Adult Studios,” where users openly solicited
24 child pornography. 54

25

26
51
Hindenburg Research, supra note 1.
27 52
Id.
53
Id.
28 54 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 19

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 23 of 81

1 62. Roblox has also enabled individuals to create an entire category of pornographic

2 content. Using Roblox’s tools and software, users make virtual sex videos between avatars on

3 Roblox. These videos are clearly marked with the .rbxl file extension—Roblox’s proprietary file

4 format—establishing that this content was created within the Roblox application. Moreover, on

5 XVideos, a porn website, Roblox users seek out other users to simulate sexual acts within

6 seemingly innocuous games, like Brookhaven, which is one of Roblox’s most popular experiences

7 and is available to all users, regardless of age.

9
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COMPLAINT AGAINST ROBLOX CORPORATION 20

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 24 of 81

9
10

11

12

13

14

15

16
This Roblox user advertised their Roblox account on porn website, XVideos, where
17 they had uploaded videos of their avatar having sex with other Roblox users. 55
18

19

20

21

22

23

24

25 Searching “Roblox” on XVideos, a porn website, yields more than 250,000 results. 56

26

27
55
Id.
28 56
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 21
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 25 of 81

9
10
The comment section on a Roblox porn video on XVideos – Brookhaven is one of
11 Roblox’s most popular games and is available to users of all ages. 57
12
63. In sum, the online environment that Roblox hosts and enables contradicts its
13
representations of providing a safe product, demonstrating Roblox’s blatant disregard for the
14
safety of its youngest users and revealing the company’s prioritization of user engagement over its
15
fundamental duty to protect young users.
16
2. Roblox provides a hunting ground for child-sex predators.
17
64. For years, Roblox has served as the online platform of choice for predators seeking
18
to find, groom, abuse, and exploit children. Roblox provides predators with easy access to tens of
19
millions of children and allows these predators to freely move between inappropriate content and
20
popular games to identify and target vulnerable young users. By doing so, Roblox has demonstrated
21
reckless indifference to its fundamental obligation not to create and foster an environment that
22
places children at significant risk of sexual exploitation.
23
65. These systematic patterns of exploitation on Roblox follow a predictable and
24
preventable sequence that the company has known about and facilitated for years: a predator
25
misrepresents their age to other users on the app, cosplaying as a fellow child, methodically
26

27

28 57
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 22
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 26 of 81

1 befriends the vulnerable young victim, and then strategically manipulates the child to move the

2 conversation off Roblox to other popular apps, such as Discord or Snapchat.

3 66. As the recent Bloomberg Businessweek article titled Roblox’s Pedophile Problem

4 put it, “These predators weren’t just lurking outside the world’s largest virtual playground. They

5 were hanging from the jungle gym, using Roblox to lure kids into sending photographs or

6 developing relationships with them that moved to other online platforms and, eventually, offline.”58

7 67. Roblox, in effect, serves as an initial access point to children for predators. Media

8 reports have repeatedly highlighted that Roblox “is being used as a first point of contact for

9 predators.” 59 The children, due to their underdeveloped brains, are more trusting and naïve, and
10 often fail to recognize the danger of providing their usernames on other sites.

11 68. Once on another app, like Discord or Snapchat, predators escalate their exploitation
12 by soliciting explicit material, like nude photos or videos of children doing sexually inappropriate

13 acts, all of which constitute child pornography. And while the ultimate solicitation of explicit

14 photos or other criminal acts may occur on other apps, Roblox serves as the critical facilitator that

15 enables these predators to first identify, target, and gain the trust of young victims through its app’s

16 design and inadequate safety measures.

17 69. Roblox’s app and profit-driven virtual currency system enable predators to exploit
18 children, often by trading or extorting Robux in exchange for explicit photos. Predators commonly

19 offer children Robux for these photos or demand Robux to avoid publicly releasing them, directly

20 tying Roblox’s profits to the sexual exploitation of children. Roblox’s manipulative reward systems

21 and social dynamics, intentionally designed to exploit children’s developmental vulnerabilities,

22 create psychological pressures that predators weaponize for extortion.

23 70. Despite full awareness of how its app facilitates such exploitation, Roblox continues
24 to profit from these tactics by collecting transaction fees on Robux exchanges. Its reckless

25

26

27 58
Carville & D’Anastosio, supra note 8.
59
National Center on Sexual Exploitation, The Dirty Dozen List ’24: Roblox,
28 https://endsexualexploitation.org/roblox/ (last updated Dec. 4, 2024).

COMPLAINT AGAINST ROBLOX CORPORATION 23

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 27 of 81

1 indifference to the consequences of its deliberately engineered app mechanics highlights its

2 prioritization of profits over the safety and well-being of its young users.

3 71. Roblox enables another pattern of predatory grooming in which predators employ

4 immediate blackmail tactics and make no attempt to ingratiate themselves with the children, but

5 instead threaten them from the outset. The predator will often threaten to post nude photos of others

6 online, but claim that the child victim is the person depicted unless the child complies with the

7 predator’s demands. Through its deliberately insufficient monitoring systems, Roblox allows

8 predators to threaten children with false claims about possessing and potentially releasing explicit

9 photos, coercing young victims into complying with criminal demands.

10 72. Regardless of how the initial grooming relationship begins, which is often as simple
11 as someone asking the child to be their boyfriend or girlfriend, the predators also often attempt to

12 make in-person contact with the child. The dangerous progression from Roblox’s online app to

13 real-world violence reveals the devastating consequences of the company’s product. Roblox’s app

14 enables predators to escalate from virtual contact to orchestrating physical meetings, leading to

15 harassment, kidnapping, trafficking, violence, and sexual assault of minors, all instances of which

16 these children suffered as a direct result of Roblox’s actions.

17 73. Through numerous well-documented and publicized cases, Roblox has long been
18 aware of the systemic exploitation that its app enables and facilitates. For years, countless children

19 have been sexually exploited and abused by predators they met on Roblox.

20 74. For example, in 2017, Roblox’s app enabled a predator to target an eight-year-old
21 child and solicit explicit photos, prompting one mother to observe that Roblox had created “the

22 perfect place for pedophiles.” 60

23 75. In 2018, Roblox’s app enabled a predator posing as a child to coerce a nine-year-old

24 girl into performing and filming sexually abusive acts on her four-year-old brother through violent

25

26
60
Pei-Sze Cheng, Evan Stulberger & Dave Manney, I-Team: Popular Online Gaming Site for
27 Kids is Breeding Ground for Child Sex Predators, Mother Says, NBC New York (Apr. 6, 2017),
https://www.nbcnewyork.com/news/local/video-game-warning-roblox-child-sex-predator-online-
28 site-investigation-what-to-know/87438/.

COMPLAINT AGAINST ROBLOX CORPORATION 24

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 28 of 81

1 threats, including of death, against her family. 61 That year, 24 men in New Jersey were also charged

2 with soliciting sex from minors as part of a sting operation, where the New Jersey State Police

3 Lieutenant specifically called out Roblox as a place where “individuals are posing as someone else”

4 in order “to gain someone’s trust.” 62

5 76. In 2019, a Florida predator systematically used Roblox to target children ages 10-

6 12, moving them to Discord to coerce the children into sending him naked pictures of themselves. 63

7 That year, a man in Wales encouraged 150 children to engage in sexual activity by contacting them

8 through Roblox, where he pretended to be a child and used fake names. 64

9 77. During the pandemic, reports of child sex abuse facilitated by Roblox accelerated.
10 In 2020, for example, Roblox enabled a 47-year-old predator to pose as a teenager, target a 16-year-

11 old girl, move the conversation to Facebook, solicit explicit photos and videos, all of which

12 constituted child pornography, 65 and ultimately traffic her across state lines, raping her multiple

13 times. 66 In Michigan, a man was arrested for persuading an eight-year-old girl to send him videos

14 of herself, in various stages of undress, in exchange for Robux. 67 The perpetrator had been arrested

15 for similar offenses three years earlier and was a registered sex offender in Kansas. This perpetrator

16

17
61
18 Briana Barker, Internet Safety and Your Children: How Kids are at Risk, Record-Courier (Mar.
27, 2018), https://www.record-courier.com/story/news/2018/03/27/internet-safety-your-children-
19 how/12899346007/.
62
Cop, Firefighter Among 25 Charged in Child Luring Sting, FOX 13 TAMPA BAY (Sep. 25, 2018),
20 https://www.fox13news.com/news/cop-firefighter-among-24-charged-in-child-luring-sting.
63
Max Chesnes, Deputies Say Vero Beach Man Used Popular Video Game Platforms to Target
21
Children, TC Palm (Aug. 20, 2019), https://www.tcpalm.com/story/news/crime/indian-river-
22 county/2019/08/20/detectives-advise-online-safety-after-vero-beach-man-used-video-game-
platforms-target-minors/2059599001/.
64
23 Liz Day, Paedophile Groomed 150 Children to Engage in Sexual Activity Using Online Game
Roblox, Wales Online (May 10, 2019), https://www.walesonline.co.uk/news/wales-
24 news/paedophile-groomed-150-children-engage-16258877.
65
U.S. Dep’t of Justice, Magnolia Man Gets Life For Exploiting Young Female He Met and
25
Communicated With Via Roblox and Facebook (Oct. 15, 2020), https://www.justice.gov/usao-
26 sdtx/pr/magnolia-man-gets-life-exploiting-young-female-he-met-and-communicated-roblox-and.
66
United States v. McGavitt, 28 F.4th 571, 578 (5th Cir. 2022).
27 67
Man Arrested for Inappropriate Relationship with 8-Year-Old Bloomfield Twp. Girl Through
Roblox, WXYZ Detroit (Sep. 24, 2020), https://www.wxyz.com/news/man-arrested-for-
28 inappropriate-relationship-with-8-year-old-bloomfield-twp-girl-through-roblox.
COMPLAINT AGAINST ROBLOX CORPORATION 25
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 29 of 81

1 was not the only convicted sex offender who was able to freely create accounts on Roblox: in 2021,

2 a convicted sex offender used Roblox to sexually solicit a 12-year-old child. 68 And in 2022, a 33-

3 year-old man groomed a 13-year-old girl on Roblox, transported her from her home in Kansas to

4 his home in Georgia, and raped her multiple times. 69

5 78. 2023 was more of the same. For example, a 30-year-old man was arrested for

6 soliciting illicit photos from young victims and authorities reported that he had three separate

7 Roblox accounts. 70 A 27-year-old man was arrested for kidnapping an 11-year-old girl whom he

8 met on Roblox.71 A 23-year-old New Jersey man, who was a prominent Roblox developer with a

9 known history of exploiting children via Roblox, was sentenced to 15 years in prison for grooming
10 a 15-year-old girl, transporting her to his house, and sexually abusing her. 72

11 79. Similar incidents continued throughout 2024. For example, a 21-year-old Chilean

12 man was arrested for traveling to the U.S. to meet an underage girl he met on Roblox, where he

13 had “spent several months manipulating and grooming” her. 73 A 21-year-old in California pled

14 guilty for directing a 10-year-old girl, whom he met on Roblox, to disrobe and touch herself. 74 A

15

16
68
Jeff Bonty, Man Charged With Soliciting Juvenile Through Roblox, Daily Journal (Jul. 23,
17 2021), https://www.shawlocal.com/daily-journal/.
69
18 Fox 5Atlanta Digital Team, Clayton County Man Charged with Sex Trafficking, Rape of 13-
year-old Girl He Met on Gaming App Roblox, Fox5 (Mar. 2, 2022),
19 https://www.fox5atlanta.com/news/clayton-county-man-charged-with-sex-trafficking-rape-of-
kansas-girl.
20 70 City of Fontana Police Department, Internet Predator Arrested, Facebook (Dec. 20, 2023),
https://www.facebook.com/watch/?v=338311109095057.
21 71
Man Charged in Kidnapping of 11-year-old He Met Through Roblox from Her NJ Home:
22 Police, ABC7 (Oct. 21, 2023), https://abc7ny.com/roblox-kidnapping-new-jersey-online-
grooming/13927383/.
23 72 U.S. Dep’t of Justice, New Jersey Man Sentenced to 15 Years in Federal Prison After Grooming
Minor Online and Transporting Her Across State Lines Via Uber for Sex (Aug. 30, 2023),
24 https://www.justice.gov/usao-sdin/pr/new-jersey-man-sentenced-15-years-federal-prison-after-
grooming-minor-online-and.
25 73
Grace Toohey, Chilean Man Groomed 13-Year-Old Girl He Met on Roblox Before Flying to
26 U.S. to Meet Her, Police Say, L.A. Times (Aug. 22, 2024),
https://www.latimes.com/california/story/2024-08-22/chilean-arrest-roblox-child-exploitation.
27 74 Ashley Harting, Online Predator Who Targeted 10-Year-Old on Roblox Pleads Guilty in Butte
County, KRCR (Sep. 25, 2024), https://krcrtv.com/news/local/online-predator-who-targeted-10-
28 year-old-on-roblox-pleads-guilty-in-butte-county.

COMPLAINT AGAINST ROBLOX CORPORATION 26

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 30 of 81

1 64-year-old man admitted to posing as a 13-year-old boy on Roblox, where he met a 12-year-old

2 girl and convinced her to send sexually explicit photos of herself and a young relative. 75 A 29-year-

3 old Michigan man befriended and groomed an 11-year-old girl on Roblox by posing as a teenager

4 and then coerced the girl into sending multiple explicit photos of herself. 76 And a 24-year-old man

5 raped a 10-year-old girl he had met on Roblox. 77

6 80. Despite supposed “parental controls” that Roblox implemented in 2024 and 2025,

7 predators continue to enjoy easy access to children on the app, causing devastating harm. For

8 example, in April 2025, a California man was arrested and charged with kidnapping and engaging

9 in unlawful sexual conduct with 10-year-old girl whom he met and communicated with on
10 Roblox. 78 The next month, a 17-year-old Florida teenager was arrested after authorities learned he

11 had been communicating on Roblox with numerous children, some as young as eight-years-old,

12 over the course of a year, and convinced them to send him sexually explicit images of themselves. 79

13 And just a few days later, a New York man who used Roblox to connect with 11- and 13-year-old

14 girls was arrested and federally charged with enticement and possession of child pornography. 80

15

16

17
75
18 Travis Schlepp, Man, 64, Admits to ‘Catfishing’ Girl on Roblox, Convincing Her to Send
Explicit Images, KTLA 5 (Jul. 26, 2024), https://ktla.com/news/california/man-64-admits-to-
19 catfishing-girl-on-roblox-convincing-her-to-send-explicit-images/.
76
Michael Martin, Roblox Predator: School Staffer Accused of Grooming West Michigan Child
20 for Illicit Photos, Fox17 West Michigan (Jan. 16, 2025),
https://www.fox17online.com/news/local-news/roblox-predator-school-staffer-accused-of-
21
grooming-west-michigan-child-for-illicit-photos.
77
22 Martin Robinson, Roblox Predator Who Raped 10-year-old Girl is Locked Up: Paedophile Who
‘Targeted Child He Met on Gaming Platform Is Jailed for Six Years, Daily Mail (Jan. 17, 2025),
23 https://www.dailymail.co.uk/news/article-14278563/Roblox-predator-raped-10-year-old-girl.html.
78
Elk Grove Man Accused of Kidnapping Kern County Girl He Communicated with on Roblox,
24 CBS News (Apr. 18, 2025), https://www.cbsnews.com/sacramento/news/elk-grove-man-accused-
kidnapping-kern-county-girl-roblox/.
25 79
Briana Trujillo, Ocala 17-Year-Old Convinced Kids to Send Him Sex Abuse Material on
26 Roblox, NBC (May 2, 2025), https://www.nbcmiami.com/news/local/ocala-17-year-old-
convinced-kids-to-send-him-sex-abuse-material-on-roblox-sheriff/3605691/.
27 80
U.S. Dep’t of Justice, Fairport Man Who Used Roblox to Attempt to Communicate with Minors
for Sex Arrested (May 6, 2025), https://www.justice.gov/usao-wdny/pr/fairport-man-who-used-
28 roblox-attempt-communicate-minors-sex-arrested.
COMPLAINT AGAINST ROBLOX CORPORATION 27
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 31 of 81

1 81. While most predators on Roblox lure children into their grasp by pretending to also

2 be children, many predators do not even hide their intentions, roaming Roblox with usernames like

3 like “@Igruum_minors,” “@RavpeTinyK1dsJE,” and “@EarlBrianBradley”—a reference to one

4 of the most prolific pedophiles ever, who raped and molested hundreds of children.

9
10

11

12

13

14 Results from an account search for “earlbrianbradley.” 81

15 82. Roblox’s systematic endangerment of children has been publicly condemned by

16 leading advocacy organizations. The National Center on Sexual Exploitation (“NCSE”) has

17 consistently named Roblox to its “Dirty Dozen” list—an annual campaign exposing companies that

18 facilitate, enable, or profit from sexual exploitation. The NCSE blasts Roblox for “treat[ing] child

19 protection like a game.” 82 According to the NCSE, “[u]ntil basic child protection standards are met,

20 Roblox remains too high risk for kids.” 83

21 83. Parent reviews of Roblox on sites like Common Sense Media also document
22 disturbing incidents of naked avatars, sexting, simulated sexual assault, and adult predators. 84

23

24

25 81
Hindenburg Research, supra note 1.
82
26 National Center on Sexual Exploitation, supra note 59.
83
Id.
27 84 Common Sense Media, Parent Reviews of Roblox,
https://www.commonsensemedia.org/website-reviews/roblox/user-reviews/adult (last visited Feb.
28 11, 2025).

COMPLAINT AGAINST ROBLOX CORPORATION 28

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 32 of 81

1 84. The harm from this child abuse and exploitation extends beyond the initial victims.

2 Through the design of its app and inadequate safeguards, Roblox has created an abusive ecosystem

3 where former victims—children who were once exploited on Roblox—become teenage

4 perpetrators who then prey upon younger users, making today’s victims tomorrow’s perpetrators.

5 Indeed, researchers have repeatedly confirmed this victim-victimizer pipeline: when children are

6 exposed to and victimized by sexual content, they are more likely to become desensitized teenagers

7 and adults who then exploit younger users in the same ways. 85 In effect, Roblox contributes to this

8 “raising of” predators who perpetuate the cycle of exploitation.

9 85. The magnitude of the harm caused by Roblox is devastating. Yet rather than warn
10 parents, schools and the public, Roblox minimizes these dangers through repeated misleading

11 public statements. Roblox’s Chief Safety Officer, Matt Kaufman, attempting to deflect attention

12 from serious safety failures, told NPR, “I think we’re losing sight of the tens of millions of people

13 where Roblox is an incredibly enriching part of their life.” 86 And while Kaufman publicly claims

14 that “any time anything happens to a child that puts them at risk is one too many,” 87 Roblox

15 simultaneously admitted to investors that it was “unable to prevent all such [inappropriate]

16 interactions from taking place.” 88 This calculated contradiction between public messaging and

17 private admissions—telling parents that even one incident is unacceptable while simultaneously

18 acknowledging to investors that abuse is inevitable—exposes Roblox’s strategy of prioritizing

19 public relations through hollow and misleading public statements over its fundamental duty to

20 protect children.

21

22
85
23 James RP Ogloff, Margaret C. Cutajar, Emily Mann & Paul Mullen, Child Sexual Abuse and
Subsequent Offending and Victimisation: A 45 Year Follow-Up Study, Trends & Issues in Crime
24 & Criminal Justice No. 440 (Jun. 2012), https://www.aic.gov.au/sites/default/files/2020-
05/tandi440.pdf; M. Glasser et al., Cycle of Child Sex Abuse: Links Between Being a Victim and
25
Becoming a Perpetrator, British J. Psychiatry (2001).
86
26 Scott Tong & James Perkins Mastromarino, Roblox Chief Safety Officer on New Safety
Features, Past Cases of Child Abuse on the Platform, WBUR (Nov. 18, 2024),
27 https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.
87
Id.
28 88
Roblox Corp., S-1 (Securities Registration Statement) 24 (Nov. 19, 2020).
COMPLAINT AGAINST ROBLOX CORPORATION 29
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 33 of 81

1 D. Roblox Knowingly Causes and Facilitates the Sexual Exploitation of Children.

2 86. The reason that Roblox is overrun with harmful content and predators is simple:

3 Roblox prioritizes user growth, revenue, and eventual profits over child safety. For years, Roblox

4 has knowingly prioritized these numbers over the safety of children through the actions it has taken

5 and decisions it has made to increase and monetize users regardless of the consequences.

6 1. Roblox prioritizes growth over child safety.

7 91. From its inception, Roblox has focused on growth above all else, which has meant

8 deliberately targeting, exploiting, and capitalizing on the underdeveloped child market, positioning

9 itself as a place where kids can learn and play games in a safe environment. Recognizing that
10 children have more free time, underdeveloped cognitive functioning, and diminished impulse

11 control, Roblox has exploited their vulnerability to lure them to its app.

12 92. Roblox’s business model allowed the company to attract significant venture capital
13 funding from big-name investors like Kleiner Perkins and Andreessen Horowitz, putting enormous

14 pressure on the company to prioritize growing and monetizing its users. To do so, Roblox made

15 deliberate decisions that placed children at risk. For example, while other digital platforms

16 (including other video game platforms) verified users’ ages and restricted communications between

17 children and adults, Roblox did not require age verification and did not restrict communications

18 between children and adults. Similarly, while other digital platforms required children’s accounts

19 to be connected to the account of a parent or guardian during set-up, with various parental controls

20 turned on by default, it is easy for children (including very young children) to download and install

21 Roblox without involving an adult. While other platforms implemented reliable, accurate age

22 ratings for games and videos that correctly informed parents about the type of content their children

23 would see, Roblox’s deeply flawed “content label” system gave parents a false sense of security,

24 incorrectly labeling graphic sexual and violent games as safe for kids. And while other platforms

25 restricted access if a child fell below a certain age, Roblox welcomed and encouraged children of

26 any age, despite its knowledge of significant harms that children routinely experience there.

27 93. In 2021, riding the explosive growth in users generated by the pandemic and the
28 pandemic-driven enthusiasm for technology stocks, Roblox went public at a valuation of $41

COMPLAINT AGAINST ROBLOX CORPORATION 30

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 34 of 81

1 billion, which brought new pressures. To satisfy the scrutiny and demands of public market

2 investors, Roblox, like many unprofitable companies, prioritized rapid growth in revenue and user

3 engagement metrics—like new user acquisition, daily active users, and average hours spent on the

4 app—on the theory that profitability would follow once the business achieved sufficient scale and

5 operating costs decreased as a percentage of revenue. 89

6 94. In pursuit of growth, Roblox deprioritized safety measures even further so that it

7 could report strong numbers to Wall Street. For instance, Roblox executives rejected employee

8 proposals for parental approval requirements that would protect children on the platform. 90

9 Employees also reported feeling explicit pressure to avoid any changes that could reduce platform
10 engagement, even when those changes would protect children from predators. 91

11 95. As one former Roblox employee explained, “You’re supposed to make sure that

12 your users are safe but then the downside is that, if you’re limiting users’ engagement, it’s hurting

13 our metrics. It’s hurting the active users, the time spent on the platform, and in a lot of cases, the

14 leadership doesn’t want that.” 92 That same employee added, “You have to make a decision, right?

15 You can keep your players safe, but then it would be less of them on the platform. Or you just let

16 them do what they want to do. And then the numbers all look good and investors will be happy.”93

17 96. By limiting safety measures, Roblox not only increased its users but also reduced

18 the company’s safety expenses as a percentage of its revenue—a key metric for Wall Steet, which

19 views trust and safety costs as detrimental to Roblox’s stock performance. Barclays, for example,

20

21
89
22 After listing on the New York Stock Exchange, Roblox CEO David Baszucki told CNBC,
“Roblox has been growing for 15 years . . . . That’s a long-term growth path, and we believe that
23 continues forward, even after Covid.” Ari Levy & Jessica Bursztynsky, Roblox Jumps to $38
Billion Mark Cap as Public Investors Get Their First Crack at the Popular Kids Game App,
24 CNBC (Mar. 10, 2021), https://www.cnbc.com/2021/03/10/roblox-rblx-starts-trading-at-
64point50-after-direct-listing.html. CFO Michael Guthrie added, “As [Covid] restrictions ease, we
25
expect the rates of growth in 2021 will be well below the rates in 2020, however, we believe we
26 will see absolute growth in most of our core metrics for the full year.” Id.
90
Hindenburg Research, supra note 1.
27 91
Id.
92
Id.
28 93
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 31
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 35 of 81

1 identified its “downside case” for Roblox’s stock as “additional safety investments due to its

2 younger demographic . . . becom[ing] a drag on [earnings] margins.” 94 Barclays also wrote that it

3 viewed increased safety costs as a “negative” in Roblox’s quarterly earnings. 95

4 97. During earnings calls for investors, Roblox frequently addresses questions from

5 analysts about how trust and safety expenditures will evolve over time. Roblox’s answers reveal

6 that the company is hyper-focused on reducing its trust and safety expenses as a percentage of its

7 revenue, showing that the company is not investing as much proportionally in trust and safety as

8 the company continues to grow and attract millions of additional users.

9 98. For example, on Roblox’s 2023 fourth quarter earnings call, an analyst praised the
10 “really high level of efficiency” seen in the numbers for infrastructure and trust and safety

11 expenditures and then asked how those figures would evolve over time. 96 In response, Mike

12 Guthrie, Roblox’s CFO, emphasized the company’s goal of reducing expenses, stating, “cost to

13 serve is the metric that we use and it’s the metric that the [infrastructure] team owns . . . they’re

14 working hard to drive that down . . . . [L]ike you said, it’s about 11% now, ultimately with higher

15 efficiency . . . we see that as a high-single-digit number over the next few years.” 97 He added,

16 “[W]e still think there’s more to do there.” 98

17 99. At other times, Guthrie has reassured investors stating, “look for trust and safety

18 [costs] to scale below linear as we grow” 99 and that Roblox was “quite happy with” trust and safety

19 costs growing “at a lower rate than our bookings growth.” 100

20 100. Similarly, in the second quarter of 2024, CEO Baszucki highlighted that,

21 “[i]mportantly, our infrastructure and trust and safety expenditures were 8% lower year-on-year.” 101

22
94
23 Ross Sandler, Trevor Young & Alex Hughes, Back on Track Following the 1H Hiccup,
Barclays (Aug. 1, 2024)
24 95
Ross Sandler, Trevor Young & Alex Hughes, Everything Accelerating, Safety & Security a Top
Priority, Barclays (Nov. 1, 2024)
25 96
Q4 2023 Earnings Call (Feb. 7, 2024).
97
26 Id. (emphasis added).
98
Id.
27 99
Q4 2022 Earnings Call (Feb. 15, 2023)
100
Q3 2022 Earnings Cal (Nov. 8, 2023).
28 101
Q2 2024 Earnings Call (Aug. 1, 2024).
COMPLAINT AGAINST ROBLOX CORPORATION 32
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 36 of 81

1 101. Once public, Roblox also decided to try to attract more adult users to its app—which

2 it had historically touted as the “#1 gaming site for kids and teens.” 102 With the market for underage

3 users near saturation, Roblox shifted its growth strategy to attracting older users.

4 102. In its public offering filings, Roblox identified “age demographic expansion” as a

5 key strategy, explaining that it planned to develop experiences and content that appealed to older

6 users. 103 For Roblox, “aging up” had benefits beyond user growth—it was also more profitable.

7 Older users offered a distinct financial advantage. While children spend more hours on Roblox,

8 they do not “monetize” as well because they are more constrained in their ability to spend. In

9 contrast, older users, who “have more direct control over their spend” and “monetize better,” are
10 far more lucrative—an outcome that Roblox said it predicted when it started to target older users. 104

11 103. Roblox’s executives repeatedly emphasized their strategy of “aging up” the app to

12 attract older users. At the company’s inaugural conference with an investment bank in September

13 2021, Roblox’s CFO, Michael Guthrie, noted that Roblox had achieved “very good penetration of

14 nine to twelve year-olds,” and was focused on adding users over the age of 13. 105 One plan was to

15 “improve the search algorithms such that older users were finding older content,” or content

16 tailored to their age-related demographic. 106

17 104. And at its annual Developer Conference, CEO David Baszucki encouraged

18 developers to create experiences for older audiences, explaining that Roblox was rolling out

19 features designed to appeal to older users, including use of real names, screen capture and sharing

20 capabilities, video calls, and relaxed chat moderation. 107 These decisions, while framed as growth

21

22
102
23 Roblox, What Is Roblox,
http://web.archive.org/web/20170227121323/https://www.roblox.com/ (archived Feb. 27, 2017).
24 103
Roblox Corp., S-1 (Securities Registration Statement) 7 (Nov. 19, 2020).
104
Q2 2022 Earnings Call (Aug. 10, 2022).
25 105
Roblox at Goldman Sachs Communicopia Conference (Sep. 9, 2021),
26 https://ir.roblox.com/events-and-presentations/events/event-details/2021/Goldman-Sachs-
Communicopia/default.aspx.
27 106
Id.
107
Roblox Developers Conference 2023 Keynote (Sep. 8, 2023),
28 https://www.youtube.com/watch?v=CwLThCghzA4.
COMPLAINT AGAINST ROBLOX CORPORATION 33
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 37 of 81

1 strategies, reflected Roblox’s willingness to compromise safety, creating new vulnerabilities and

2 more dangerous circumstances for children in its pursuit of a more profitable, older user base.

3 105. Roblox executives consistently highlighted progress with the company’s “aging up”

4 strategy on every quarterly earnings call after this until the second quarter of 2023, when CEO

5 Baszucki declared that Roblox had achieved its goal: “We’re no longer talking about aging up. We

6 are a platform for all ages.” 108 He also revealed that developers had started to “build specific 17-

7 plus experiences.” 109 This progress was praised by Wall Street investment banks, who noted that

8 aged-up experiences were a promising indicator of “potential sustainable growth tailwinds for

9 Roblox,” reinforcing the company’s pivot toward maximizing profitability. 110

10 106. Despite Roblox’s deliberate targeting of older users, it failed to implement any
11 meaningful restrictions on contact between adult and child users or limit the mature content and

12 experiences it solicited from developers to attract older audiences. When asked by an equity

13 research analyst about aged-13-and-up experiences for older users, CEO Baszucki admitted, “I

14 want to highlight right now that we don’t have any only 13 and up experiences. We have 28% of

15 the top thousand experiences having a majority of 13-plus [users] but those are still experiences

16 that are open to all ages.” 111 Similarly, despite urging developers to build more mature experiences,

17 Roblox continued to allow users to set up accounts without any type of age verification. 112 Even

18 investors recognized the connection between older users and the increased risks for children,

19 questioning how Roblox planned to prevent inappropriate content from reaching younger users. 113

20 107. Not only did Roblox seek to increase adult users while knowing the risks that

21 strategy posed to children, but it also sought to encourage relationships between users. At Roblox’s

22 2023 Developers Conference, CEO Baszucki revealed Roblox’s strategy to facilitate “real-life

23 relationships” between users—i.e., dating. While he deliberately avoided the word “dating,” he

24

25 108
Q2 2023 Earnings Call (Aug. 9, 2023).
109
26 Q2 2023 Earnings Call (Aug. 9, 2023).
110
Benjamin Black et al., Bookings Back on Track, Deutsche Bank (Nov. 4, 2024).
27 111 Q3 2021 Earnings Call (Nov. 9, 2021) (emphasis added).
112
Q4 2022 Earnings Call (Feb. 15, 2023).
28 113 Q3 2021 Earnings Call, supra note 111.

COMPLAINT AGAINST ROBLOX CORPORATION 34

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 38 of 81

1 then announced plans to build a product to support it: “I’m not going to use the D word but

2 subsequent[] real-life relationships is going to happen, okay? And we’re going to build a platform

3 to support that.” 114

4 108. By the next year, in 2024, Baszucki explicitly acknowledged this strategy. He first

5 acknowledged that online dating is “edgy” but then mocked his own safety team’s concerns about

6 the dangers—“the policy and safety team told me [dating and real-life relationships] isn’t within

7 our current policy right now”—to which the audience shared in laughter. 115

8 109. In short, for years, Roblox has deliberately sacrificed child protection—a

9 longstanding issue for the company—in pursuit of growth and profit. This systematic subordination
10 of child safety to business objectives reflects Roblox’s continued choice to maximize its business

11 goals while knowingly exposing children to preventable dangers on its app.

12 2. Roblox facilitates child sexual exploitation through the design of its app,
13 inadequate safety features, and refusal to invest in basic safety protections.
14 110. Roblox’s pursuit of growth and profit over child safety is reflected in numerous
15 actions it took and decisions it made related to the design and safety of its app. Had Roblox acted

16 differently, the harm suffered by countless children would not have occurred.

17 111. Roblox designed its app so that anyone can easily communicate with children,
18 creating a virtual world where predators can freely target and groom children. Until November

19 2024, adult strangers could “friend” and chat with children of any age via direct messages and chat

20 with them in an experience through direct messages even if they were not friends. While Roblox

21 offered some adjustable parental controls for users under the age of 13, these children could bypass

22 those controls simply by creating an alternate account falsely identifying as a 13+-year-old user.

23 By designing its app this way, Roblox stripped parents of basic protective options to prevent adult

24 strangers from communicating with their children.

25

26
114
Roblox Developers Conference 2023 Keynote (Sep. 8, 2023),
27 https://www.youtube.com/watch?v=CwLThCghzA4.
115
Roblox Developers Conference 2024 Keynote (Sep. 6, 2024);
28 https://www.youtube.com/watch?v=HwbcWc2CwnM.

COMPLAINT AGAINST ROBLOX CORPORATION 35

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 39 of 81

1 112. This practice contrasts sharply with other gaming products like Nintendo, which use

2 preprogrammed dialogue options to tightly control user interactions. 116 By adopting a similar

3 approach, Roblox could have significantly reduced—if not eliminated—the grooming and child

4 abuse facilitated by its app because predators would not have been able to solicit any personal

5 information or send any coercive or sexually suggestive messages.

6 113. Roblox further endangered children by introducing voice calls in November 2023.

7 Called “Roblox Connect,” this virtual call feature allows users to have a conversation through their

8 avatars in real time. Concerns were immediately raised about this feature. For example, one user

9 emphasized, “This is a bad idea Roblox, and especially on your platform because this is where
10 most predators are coming from, and it makes it way easier for predators to prey on children.” 117

11 114. As Roblox contemplated and rolled out Roblox Connect, it knew that this feature

12 would drastically increase the risk to children on its app. That is because another company had

13 implemented a similar feature with disastrous consequences. Omegle was a chat website that

14 operated from 2009 to 2023. Omegle allowed users, including children, to engage in anonymous

15 chats with strangers. In March 2010, Omegle introduced a video-chat feature. Despite efforts to

16 monitor for mature and sexual content, the website became infamous for exposing minors to

17 explicit material, predators, and exploitation. Omegle’s failure to protect users led to numerous

18 incidents, including criminal cases involving child pornography. In November 2023, the same

19 month Roblox launched Roblox Connect, Omegle announced that it would cease operations. In

20 shutting down, its founder highlighted the site’s misuse: “[T]here can be no honest accounting of

21 Omegle without acknowledging that some people misused it, including to commit unspeakably

22 heinous crimes.” 118 And he thanked one survivor for “opening my eyes to the human cost of

23 Omegle.” 119 Nevertheless, Roblox introduced voice calls the same month that Omegle shut down.

24

25 116
Carville & D’Anastosio, supra note 8.
117
26 Josh Taylor, Roblox Under Fire After Adding Controversial Voice Call Feature, Dexerto (Nov.
15, 2023), https://www.dexerto.com/roblox/roblox-under-fire-after-adding-controversial-voice-
27 call-feature-2384564/.
118
Omegle, https://www.omegle.com/ (last visited Feb. 11, 2025).
28 119 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 36

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 40 of 81

1 115. Roblox also refused to implement simple measures that would have protected

2 children using its app. For example, despite having the ability to require basic identity verification,

3 Roblox instead chose to allow users to create accounts without providing their name or email

4 address—a policy that enables predators to easily create multiple anonymous accounts. Roblox

5 also could have implemented basic screening measures before allowing users on the app, which

6 would have ensured that known predators are not permitted on the app.

7 116. Roblox also could have required children to provide their names and email

8 addresses and obtain parental approval—a fundamental protection against predators—but refused

9 to do so. This decision allowed the company to bypass certain protections that are mandated by
10 federal law and designed to protect children. The Children’s Online Privacy Protection Act

11 (“COPPA”) prohibits companies like Roblox from collecting, using, or disclosing the personal

12 information of children under 13 without verifiable parental consent. COPPA was enacted because

13 Congress recognized the heightened vulnerability of children on the internet. As the Federal Trade

14 Commission (“FTC”) noted, children under 13 lack the capacity to “understand fully the potential

15 serious safety and privacy implications” of sharing their personal information. 120 More recent

16 international regulations are stricter. For example, the European Union’s General Data Protection

17 Regulation (GDPR) requires verifiable parental consent for children under 16. 121

18 117. The FTC has outlined clear and acceptable methods for obtaining verifiable parental

19 consent. These include: (a) providing a form for parents to sign and return; (b) requiring the use of

20 a credit card or online payment that notifies parents of each transaction; (c) connecting parents to

21 trained personnel via video conference; (d) offering a staffed toll-free number for parental

22

23

24
120
Federal Trade Commission, Privacy Online: A Report to Congress (1998),
25 https://www.ftc.gov/sites/default/files/documents/reports/privacy-online-report-congress/priv-
23a.pdf.
26 121 Art. 8 GDPR; see also Consent to Use Data on Children, EU Agency for Fundamental Rights

27 (https://fra.europa.eu/en/publication/2017/mapping-minimum-age-requirements-concerning-
rights-child-eu/consent-use-data-children). Note that member states can lower the cutoff to 13, 14
28 or 15 if they choose.

COMPLAINT AGAINST ROBLOX CORPORATION 37

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 41 of 81

1 verification; (e) asking knowledge-based questions to confirm identity; or (f) verifying a parent’s

2 photo-ID by comparing it to a second photo using facial recognition technology. 122

3 118. Yet instead of implementing safeguards to comply with COPPA, Roblox chose to

4 bypass these protections altogether. Roblox intentionally avoids requesting a name or email address

5 during sign-up to sidestep the requirement of verifiable parental consent. In fact, former employees

6 revealed that Roblox considered requiring verifiable consent, but ultimately resisted its

7 implementation out of fear that such requirements might drive users away. 123 Consequently,

8 creating a Roblox account is alarmingly easy, requiring less than sixty seconds and no meaningful

9 oversight—a choice that prioritizes growth over the safety of its youngest users. 124
10 119. Another easy-to-implement feature that would have improved safety is adding pop-
11 up safety notices within chats and games to warn users about their behavior or the dangerous

12 behavior of others. But Roblox executives also rejected this change. 125

13 120. Additionally, although Roblox knew that predators routinely operate dozens of

14 Roblox accounts at the same time, the company chose not to implement basic blocking of digital

15 identifiers—both the unique network addresses that track internet connections (Internet Protocol

16 or IP addresses) and the permanent hardware identification numbers assigned to devices (Media

17 Access Control or MAC addresses) that could prevent predators from creating multiple accounts. 126

18 121. Similarly, Roblox chose not to require adult users to verify phone numbers—which

19 would create significant barriers to predators creating multiple accounts—despite knowing that this

20 enables bad actors to easily create numerous anonymous accounts to target children. 127

21

22

23
122
Federal Trade Commission, Complying with COPPA: Frequently Asked Questions, July 2020,
24 https://www.ftc.gov/business-guidance/resources/complying-coppa-frequently-asked-questions.
123
Hindenburg Research, supra note 1.
25 124
Scott Tong & James Perkins Mastromarino, Roblox Attempts to Bar Child Predators as Short
26 Sellers Target the Popular Game Platform, WBUR (Oct. 21, 2024),
https://www.wbur.org/hereandnow/2024/10/21/roblox-child-predators-safety.
27 125 Carville & D’Anastosio, supra note 8.
126
Id.
28

COMPLAINT AGAINST ROBLOX CORPORATION 38

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 42 of 81

1 122. Roblox also opted not to require users to verify their age by uploading a picture of

2 either their or their parents’ ID, a practice that many other applications employ. Doing so would

3 have restricted the content available to young users and prevented predators from easily

4 mispresenting their age, which is often their approach in targeting and grooming children. As one

5 father told the press after seeing other users solicit his avatar for sex, “There is nothing to stop

6 adults going on there and pretending they’re kids.” 128

7 123. Roblox could easily have restricted communications between adult accounts and

8 children’s accounts, something that many other platforms have done. It could also have restricted

9 adult accounts from sending Robux to children’s accounts, a feature that sexual predators
10 frequently use to lure children.

11 124. Roblox likewise could have created a separate, gated platform for younger children
12 that excludes adults. If supported by age verification using facial recognition (a service that is

13 widely commercially available), the company could create a space for young children to enjoy

14 Roblox games with very few, if any, adults present. Many digital service companies have adopted

15 separate platforms for children of young ages, including, for example, Amazon and Netflix.

16 125. Roblox could have placed a higher age rating on its application in the iOS App Store
17 and other app stores, to signal to parents that the app presented risks for children. Roblox also could

18 have provided clear warnings to parents about the presence of sexual predators on the platform, so

19 that parents could make an informed decision about allowing their child on the platform and/or

20 educate their child on how to stay safe on the platform. Roblox could also have provided clear

21 warnings to children about the presence of sexual predators on the platform, and instructed children

22 on how to stay safe on the platform.

23

24

25

26
128
Carl Stroud, Horrified Dad Found Sick Messages from Paedo Predator in His Eight-Year Old
27 Son’s Roblox iPad Game, The Sun (Feb. 15, 2017),
https://www.thesun.co.uk/news/2872376/horrified-dad-found-sick-messages-from-paedo-
28 predator-in-his-eight-year-old-sons-roblox-ipad-game/.

COMPLAINT AGAINST ROBLOX CORPORATION 39

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 43 of 81

1 126. Despite these glaring failures, Roblox aggressively markets and promotes itself as

2 an “industry leader” when it comes to child safety. 129 Central to this self-serving narrative is its

3 “accomplishments” of investing in artificial intelligence (“AI”) and machine learning systems

4 supposedly designed to scan and monitor all communications on the app and prevent the sharing

5 of inappropriate content and personally identifiable information. 130

6 127. Yet this technology has proven grossly inadequate and insufficient to protect

7 children. For example, Roblox’s filters have inexplicable omissions. While Roblox blocks certain

8 words, like “Snap” and “Snapchat,” to supposedly prevent off-app communications, it allows

9 workarounds such as the use of the ghost emoji (👻👻), which is widely recognized as a symbol for
10 Snapchat, or alternative spellings, like “Snappy” or “apchat.” Similarly, while the word “Discord”

11 is blocked, users can bypass this filter by using the disc emoji (💿💿) or typing variations, like

12 “iscord” or “cord.” 131 That Roblox selectively blocks the words “Snap,” “Snapchat,” and “Discord”

13 reveals that Roblox is fully aware of the dangers of off-app inappropriate communications yet

14 chooses not to close these loopholes. And while Roblox prevents users from sharing phone numbers

15 in numerical format, it does nothing to stop users from spelling out the numbers. 132

16 128. Similarly, while Roblox attempts to block the word “condo”—a term that, until

17 recently, was widely used to identify sexualized experiences—countless external groups on

18 platforms like Reddit and Discord are dedicated to helping users locate new explicit content on

19 Roblox. As soon as Roblox removes one game, its ineffective safeguards allow the same game to

20 be reuploaded almost immediately from a new account, perpetuating the cycle of explicit and

21 harmful content. External groups have capitalized on Roblox’s weak moderation by guiding

22

23

24
129
Q1 2021 Earnings Call (May 11, 2021).
25 130
Roblox, Safety Features: Chat, Privacy & Filtering,
26 https://web.archive.org/web/20240714130904/https://en.help.roblox.com/hc/en-
us/articles/203313120-Safety-Features-Chat-Privacy-Filtering (archived Jul. 14, 2024).
27 131 Edwin Dorsey, Problems at Roblox (RBLX) #5, The Bear Cave (Oct. 17, 2024),
https://thebearcave.substack.com/p/problems-at-roblox-rblx-5.
28 132 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 40

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 44 of 81

1 predators to these reuploaded games, with Fast Company easily identifying 150 Discord groups

2 dedicated to exploiting Roblox’s lack of robust enforcement. 133

3 129. Beyond Roblox’s ineffective technology, the company also employs a woefully

4 inadequate number of human moderators to analyze and manage content on its platform. With only

5 about 3,000 moderators, Roblox pales in comparison to platforms like TikTok, which, despite

6 having only three times the number of users, employs more than ten times the number of

7 moderators at 40,000. 134 Roblox attempts to justify this disparity by claiming “[y]ou really can’t

8 judge the quality of these moderation systems by the number of people.” 135 But the reality tells a

9 different story. Roblox’s moderators, many of them overseas contractors, report being
10 overwhelmed by an unmanageable volume of child safety reports, making it impossible to address

11 all concerns effectively and leaving countless safety issues unresolved. 136

12 130. Even the safety data that Roblox touts is flawed and only underscores the growing

13 dangers created by the company’s app. For example, Roblox proudly points to its low percentage

14 of reports to the National Center for Missing and Exploited Children (“NCMEC”)—the leading

15 U.S. nonprofit organization tasked with preventing child exploitation and assisting in the recovery

16 of missing children. Roblox claims that it accounts for less than .04% of reports made to

17 NCMEC. 137 But this data is entirely self-reported and therefore depends on Roblox’s ineffective

18 content moderation and safety team. This self-reported data to NCMEC—flawed and limited as it

19

20

21

22 133
Burt Helm, Sex, Lies and Video Games: Inside Roblox’s War on Porn, Fast Company (Aug.
23 19, 2020), https://www.fastcompany.com/90539906/sex-lies-and-video-games-inside-roblox-war-
on-porn.
24 134 Carville & D’Anastosio, supra note 8.
135
Scott Tong & James Perkins Mastromarino, Roblox Chief Safety Officer on New Safety
25
Features, Past Cases of Child Abuse on the Platform, WBUR (Nov. 18, 2024),
26 https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.
136
Carville & D’Anastosio, supra note 8.
27 137 Scott Tong & James Perkins Mastromarino, Roblox Attempts to Bar Child Predators as Short
Sellers Target the Popular Game Platform, WBUR (Oct. 21, 2024),
28 https://www.wbur.org/hereandnow/2024/10/21/roblox-child-predators-safety.

COMPLAINT AGAINST ROBLOX CORPORATION 41

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 45 of 81

1 is—also reveals a disturbing trend: Roblox’s reports about suspected child sexual exploitation have

2 surged over the years, from 675 reports in 2019 to 13,316 reports in 2023. 138

3 131. Roblox also boasts that just “0.0063% of [its] total content was flagged for

4 violating” policies. But Roblox itself controls the systems responsible for identifying and flagging

5 violative content. 139 These lower percentages are thus a reflection not of safety but of Roblox’s

6 ability to minimize the appearance of problems through its own inadequate reporting and

7 enforcement mechanisms. By hiding behind self-serving metrics and refusing to take meaningful

8 action, Roblox has fostered an environment where children are subjected to irreparable harm while

9 the company continues to reap financial rewards.

10 132. The very existence of Roblox’s trust and safety “data” on inappropriate
11 communications to train its AI systems contradicts its claim that “one is too many” when it comes

12 to the sexual exploitation of children. This data exists only because countless instances of abuse,

13 exploitation, and predatory interactions have already occurred. Roblox’s reliance on this data to

14 train its AI systems exposes the reality that its so-called safety measures are not designed to prevent

15 these atrocities but to react to them after the damage has been done. Instead of creating a secure

16 environment where such harm never occurs and ensuring that such interactions never happen in the

17 first place, Roblox uses the suffering and trauma of children as the foundation for its trust and safety

18 systems. This cycle underscores the company’s prioritization of optics over genuine protection,

19 leaving its youngest users at the mercy of its neglect.

20

21

22

23
138
National Center for Missing & Exploited Children, 2019 CyberTipline Reports by Electronic
24 Services Providers (ESP), https://www.missingkids.org/content/dam/missingkids/pdfs/2019-
reports-by-esp.pdf; see also National Center for Missing & Exploited Children, 2023 CyberTipline
25
Reports by Electronic Services Providers (ESP),
26 https://www.missingkids.org/content/dam/missingkids/pdfs/2023-reports-by-esp.pdf.
139
Vikki Blake, Roblox Reported Over 13,000 Incidents to the National Center for Missing and
27 Exploited Children in 2023, GamesIndustry.biz (Jul. 23, 2024),
https://www.gamesindustry.biz/roblox-reported-over-13000-incidents-to-the-national-center-for-
28 missing-and-exploited-children-in-2023.

COMPLAINT AGAINST ROBLOX CORPORATION 42

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 46 of 81

1 133. Roblox’s own developers even admit that Roblox is unsafe for children. 140 Online

2 forum discussion posts are replete with developers writing that they would not allow their own

3 children to use the platform, citing pervasive issues with Roblox’s child safety policies. Many of

4 these posts highlight the platform’s systemic failures and suggest straightforward changes Roblox

5 could implement to create a safer environment but has consistently ignored—for example:

6 a. “Unfortunately, it is worse now due to Roblox’s moderation being so abysmal and

7 Roblox being a far more widespread platform. Creeps flock aplenty when before the

8 creep: kid ratio was much much lower . . . . Roblox has no interest in actually fixing

9 the issues so long as the bad press doesn’t end up viral.” 141
10 b. “No. Roblox is not safe for children. The amount of NSFW [Not Safe for Work] I
11 see on this platform on a daily basis is unbelievable. I’m surprised COPPA hasn’t
12 taken any action.” 142
13 c. “I believe they need to automatically rate these games for older audiences, if not,

14 you know, removing them entirely. I could keep going on about this issue, but it’s

15 just beating a dead horse at this point.” 143

16 d. “Roblox got banned for bad moderation; Turkey banned it to ‘protect children,’ and

17 they are not wrong. The amount of visits from 10 of these games is, in summary,

18 100 million+. I don’t want to know how many of these children have seen nudity or

19 even developed a p*rn addiction. But that is a big problem with Roblox doing almost

20 nothing to prevent it.” 144

21 134. These statements, coming from individuals familiar with Roblox’s operations, paint

22 a picture of an environment rife with neglect, where harmful content flourishes, predators thrive,

23 and Roblox repeatedly fails to act—even in the face of widespread and urgent warnings.

24

25 140
Edwin Dorsey, Problems at Roblox (RBLX) #5, The Bear Cave (Oct. 17, 2024),
26 https://thebearcave.substack.com/p/problems-at-roblox-rblx-5.
141
Id.
27 142 Id.
143
Id.
28 144 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 43

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 47 of 81

1 3. Roblox’s recent safety changes are woefully inadequate and fail to address

2 years of neglect and harm caused by its app.

3 135. After years of mounting pressure, Roblox recently announced changes to its child

4 safety features. These changes were prompted not by the years of police reports and widespread

5 media coverage but by a scathing report published by a well-known short seller accusing the

6 platform of being a “pedophile hellscape for kids.” 145 Released on October 8, 2024, the report

7 sparked public outrage, detailing many of the issues described above that Roblox had long ignored.

8 136. A little more than a month later, Roblox announced a series of changes, including

9 permanently removing the ability to message others outside of games on its app for under 13-year-
10 old users; 146 giving parents a separate dashboard where they can monitor a child’s Roblox account,

11 view the child’s friend list, set spending control, and manage screen time; 147 preventing games

12 from using chalkboard writings where people could get around the censoring of

13 communications; 148 and implementing restrictions to stop under 13-year-old users from accessing

14 new Roblox games that are awaiting maturity ratings. 149

15 137. These changes could all have been implemented years ago. None of them involve

16 any new or groundbreaking technology. Roblox only moved forward when its stock was threatened.

17 138. And these changes are little more than window dressing—too little, too late, and

18 woefully inadequate. Most fundamentally, Roblox still allows adults to contact and message

19 children. Roblox only banned user-to-user messaging for users under the age of 13 outside of

20 games. Predators can still message children on public chats while playing games; indeed, Roblox

21

22
145
23 Hindenburg Research, supra note 1.
146
Roblox Tightens Messaging Rules for Under-13 Users Amid Abuse Concerns, Reuters (Nov.
24 18, 2024), https://www.reuters.com/technology/roblox-tightens-messaging-rules-under-13-users-
amid-abuse-concerns-2024-11-18/.
25 147
Robert Booth, Roblox to Give Parents More Control Over Children’s Activity After Warnings
26 Over Grooming, The Guardian, (Nov. 18, 2024),
https://www.theguardian.com/technology/2024/nov/18/roblox-to-hand-parents-more-control-over-
27 their-childrens-activity.
148
Id.
28 149
Id.
COMPLAINT AGAINST ROBLOX CORPORATION 44
 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 48 of 81

1 has left child predators’ blueprint for finding children on the application intact since predators have

2 always found children by playing games they know that children will frequent.

3 139. Roblox also failed to address core issues like the app’s lack of age verification and

4 refusal to require parental consent to make an account. The restrictions described above work only

5 if children correctly state their age during sign-up. Any child can easily bypass them—including

6 parental controls and limits on messaging—by lying about their birthday. Roblox likewise did not

7 commit to hiring more moderators or increasing its trust and safety budget, nor did it implement

8 any sort of identity check to prevent registered sex offenders from making accounts.

9 140. In fact, recently, in April 2025, a research firm in the U.K. demonstrated just how
10 easy it still is for predators to find children and move the conversation to another application, such

11 as Snapchat or Discord, despite Roblox’s ban on direct messaging with users under the age of 13. 150

12 Because Roblox still allows adult users to message children in games, predators can use the public

13 chat functions in games to groom child users and ask for their usernames on other platforms. And,

14 for chat within games, Roblox’s default settings for children under the age of 13 is to allow

15 “everyone” to chat with these children, seamlessly facilitating predators’ access to children. 151 The

16 key findings from this report included that “[a]dults and children can chat with no obvious

17 supervision” and that “[t]he safety controls that exist are limited in their effectiveness and there are

18 still significant risks for children on the platform.” 152

19

20

21

22

23

24

25
150
26 Revealing Reality, A Digital Playground: The Real Guide to Roblox (Apr. 13, 2025),
https://think.revealingreality.co.uk/roblox-real-guide.
27 151 Parental Controls Overview, Roblox, https://en.help.roblox.com/hc/en-
us/articles/30428310121620-Parental-Controls-Overview (last accessed May 10, 2025).
28 152 Revealing Reality, supra note 150.

COMPLAINT AGAINST ROBLOX CORPORATION 45

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 49 of 81

9 In April 2025, a research agency demonstrated how easy it was for a 42-year-old account to find
a five-year-old user on Roblox and get the child to move the conversation to Snapchat. 153
10

11 141. Just as Roblox rolled out these changes, it simultaneously introduced a new

12 “Parties” feature in an attempt to counteract any potential loss in user engagement. 154 Because

13 Roblox knew that users often turned to other apps like Discord to communicate while playing video

14 games and because Roblox knew that its safety changes would reduce key user engagement

15 metrics, it sought to capture that traffic (and revenue) and replace any loss of engagement with the

16 Parties feature. While the Parties feature is currently available only for users aged 13 and older,

17 such limitations are hollow without robust age verification. And the fact that Roblox has stated that

18 it is exploring making such a feature available to younger users demonstrates that, far from

19 prioritizing safety, Roblox’s real focus is protecting its bottom-line. 155

20 142. Roblox has also engaged in a deceptive public relations campaign using ostensibly

21 independent online safety organizations to influence the narrative around these changes. For

22 instance, Roblox has leveraged its ties to groups like the Family Online Safety Institute (“FOSI”).

23 An online parenting magazine favorably quoted Stephen Balkam, FOSI’s CEO, as endorsing

24

25

26
153
Id.
27 154
Rebecca Ruiz, Roblox’s New Party Feature Makes Discord Obsolete, Mashable (Dec. 2, 2024),
https://mashable.com/article/roblox-party-discord.
28 155 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 46

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 50 of 81

1 Roblox’s new features as a win for child safety. 156 What the article omitted, however, is that

2 Roblox’s own Vice President of Civility and Partnerships, Tami Bhaumik, serves as FOSI’s board

3 chair—an obvious conflict of interest. 157 This calculated relationship exposes how Roblox

4 manipulates public perception by using seemingly independent safety organizations as

5 mouthpieces to shape the narrative in its favor.

9
10

11

12

13

14

15

16

17

18
Stephen Balkam’s LinkedIn post revealing his connection to Roblox in a post
19 praising Roblox’s changes. 158

20 143. Most recently, in April 2025, Roblox repeated this same deceptive playbook of
21 bragging about new safety features that, in reality, are glaringly deficient. This update included

22 three new features: first, allowing parents to block children from playing specific games; second,

23

24
156
Anna Halkidis, What Roblox’s Latest Changes Mean for Your Kids’ Online Safety, Parents
25
(Nov. 18, 2024), https://www.parents.com/roblox-new-parental-controls-8747405.
157
26 FOSI Welcomes Roblox Vice President as New Board Chair, FOSI (Oct. 12, 2022),
https://www.fosi.org/about-press/fosi-welcomes-roblox-vice-president-as-new-board-chair.
27 158 LinkedIn, Stephen Balkam’s Post, https://www.linkedin.com/posts/stephenbalkam_what-
robloxs-latest-changes-mean-for-your-activity-7264409332950220801-WCDF (last visited Jan. 6,
28 2025).

COMPLAINT AGAINST ROBLOX CORPORATION 47

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 51 of 81

1 granting parents the power to block people on their child’s friends list; and third, giving parents

2 visibility into the games that their child spends the most time in.159

3 144. None of these parental controls address the underlying deficiency with Roblox that

4 facilitates grooming and predation on children—adult access to and communication with children.

5 Without allowing parents to see who their child is messaging and what the messages say, parents

6 lack the information necessary to determine which accounts to block on their child’s friend list. A

7 list of the top twenty games that a child plays does not tell a parent which games children are

8 interacting with adults in. Moreover, blocking specific games is ineffective when, as discussed

9 above, inappropriate games are re-posted as soon as they are taken down. Indeed, barely a week
10 later, the U.K. research firm discussed above demonstrated just how easy it is for adults to continue

11 to find children, groom them, and then move the communications off Roblox, even after Roblox

12 announced these safety updates. 160

13 145. And, yet again, all of these controls could have been introduced years ago, as none

14 are facilitated by previously unavailable technology.

15 146. Roblox’s deceptive playbook would not be complete without a misleading public

16 relations campaign, where industry-funded safety “experts” praise Roblox’s safety update. For

17 example, Roblox’s press release announcing these updates quotes Larry Magid, the CEO of

18 ConnectSafely, as saying, “Roblox has consistently provided parents with tools that enable their

19 children to enjoy the platform, while helping protect them against online risks. These new friend-

20 and experience-blocking tools provide parents with even more ways to help ensure their children

21 are using it safely. Safety, fun, and adventure are not mutually exclusive.” 161 What the press release

22

23

24

25
159
26 Matt Kaufman, New Tools for Parents to Personalize Their Child’s Experience on Roblox,
ROBLOX (Apr. 2, 2025), https://corp.roblox.com/newsroom/2025/04/new-parental-controls-on-
27 roblox.
160
A Digital Playground: The Real Guide to Roblox.
28 161 Matt Kaufman, New Tools for Parents to Personalize Their Child’s Experience on Roblox.

COMPLAINT AGAINST ROBLOX CORPORATION 48

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 52 of 81

1 did not say is that ConnectSafely—a non-profit ostensibly focused on educating people about

2 internet safety—is funded by tech companies and lists Roblox as one of its “supporters.” 162

9
10

11 ConnectSafely’s list of supporters on its website.

12 147. A few weeks later, Magid was quoted again in praise of Roblox, this time in a
13 Newsweek article championing Roblox as a “trusted playground” for kids: “I would put them very

14 high up on the list of companies that seem to care. They actually have a vice president of civility.

15 It’s unheard of to have somebody at that level of the company that focuses on civility. They really

16 work very hard to make it a friendly, comfortable, civil environment for young people.” 163 Again,

17 this article made no mention of Magid’s organization’s financial ties to Roblox.

18 148. FOSI CEO Stephen Balkam was also quoted in the Newsweek piece, claiming that
19 Roblox was “top-of-class” for its safety features and even repeating Roblox’s own party line that

20 safety is “part of [Roblox’s] DNA.” 164 Again, this article omitted FOSI’s ties to Roblox, financial

21 and otherwise, thereby deceptively pushing a narrative of Roblox as a “safe” application for kids.

22 / / /

23 / / /

24

25 162
ConnectSafely, Supporters, https://connectsafely.org/about-us/supporters/ (last accessed May
26 10, 2025).
163
Katherine Fung, How Roblox Became a Trusted Playground for Millions of Kids, Newsweek
27 (Apr. 23, 2025), https://www.newsweek.com/how-roblox-became-trusted-playground-millions-
kids-2057601.
28 164 Id.

COMPLAINT AGAINST ROBLOX CORPORATION 49

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 53 of 81

1 V. PLAINTIFF-SPECIFIC ALLEGATIONS

2 149. Plaintiff is an 8-year-old boy who was manipulated and groomed through

3 Defendant’s dangerous apps by a predator who ultimately solicited sexually explicit images from

4 him. Plaintiff has suffered devastating and life-altering psychological trauma. His life will never

5 be the same.

6 150. Plaintiff was 7 years old when he first started playing on Roblox. Plaintiff’s mother

7 believed that Roblox was safe for children because it was designed and marketed for kids. As

8 discussed above, Roblox spent considerable time and money publicly touting the safety and

9 security of the app, which created the public perception that Roblox had created a safe environment
10 for kids. Unbeknownst to Plaintiff’s mother at the time, this was nothing more than a false façade

11 of safety.

12 151. In 2025, when Plaintiff was 8 years old, he met a woman on Roblox who told
13 Plaitniff she was the same age as him, but was in fact an adult predator. On Roblox, the predator

14 groomed Plaintiff, exploiting his age and vulnerability to build a false emotional connection with

15 him.

16 152. After capturing Plaintiff’s trust, the predator intensified her grooming of Plaintiff,
17 and their interactions continued on Roblox. The predator convinced Plaintiff to provide his personal

18 phone number, which the preadtor used to send Plaintiff graphic messages and sexually explicit

19 images of herself. The predator ultimately convinced Plaintiff to send her a sexually explicit image

20 of himself. Throughout her interactions with Plaintiff on Roblox, the predator encouraged secretive

21 behavior, minimized the risks to Plaintiff, and ensured that Plaintiff would not reveal any of their

22 interactions to his parents.

23 153. Plaintiff has suffered profound harm from the grooming, manipulation, and
24 exploitation that he experienced on Defendant’s app. He continues to suffer from severe mental

25 health issues, including difficulty trusting others and persistent anxiety.

26 154. Defendant is directly responsible for the immense harm that Plaintiff has suffered.
27 Had Plaintiff’s mother known the truth about Defendant’s app, she never would have permitted

28 Plaintiff to use it without strict supervision. Had Defendant implemented even the most basic

COMPLAINT AGAINST ROBLOX CORPORATION 50

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 54 of 81

1 system of screening or age and identity verification, as well as effective parental controls, Plaintiff

2 never would have interacted with his dangerous predator and never would have suffered the harm

3 that he did. Plaintiff’s life has been devastated as a direct result of Defendant’s conduct.

4 VI. CAUSES OF ACTION

5 FIRST CAUSE OF ACTION

6 FRAUDULENT CONCEALMENT AND MISREPRESENTATIONS

7 (By Plaintiff Against Defendant)

8 155. Plaintiff incorporates each and every factual allegation set forth above.

9 156. This claim is brought against Defendant Roblox.

10 157. As set forth in more detail above, each Defendant knew about the defective
11 conditions of its app and that the app posed serious safety risks to child users.

12 158. Defendant was under a duty to tell the public the truth and to disclose the defective
13 conditions of its app and that the app posed serious safety risks to child users. Instead of disclosing

14 the truth, Defendant engaged in a widespread public campaign to tout the safety of its app in the

15 media, and in the materials provided to potential users of the app, as described above.

16 159. Defendant made numerous false representations about the safety of its app, as
17 described above, which were specific and widespread. Plaintiff’s mother and the public at large

18 relied on each Defendant’s false representations in deciding to allow children to play on the app.

19 160. Defendant was under a duty to tell the public, users, and their parents the truth and
20 to disclose the defective conditions of its app and that the app posed serious safety risks to child

21 users because Defendant possessed superior knowledge about the dangers of its app through

22 internal reviews, external studies known to Defendant, and parent and police reports made to

23 Defendant.

24 161. Defendant breached its duty to the public, users, and their parents by concealing and
25 failing to disclose the serious safety risks presented by its app. Even though Defendant knew of

26 those risks based on its internal reviews, external studies known to Defendant, and parent and police

27 reports made to Defendant, Defendant intentionally concealed those risks to not lose users and

28 revenue, and to induce parents to allow their children to use its app. Such risks were known only

COMPLAINT AGAINST ROBLOX CORPORATION 51

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 55 of 81

1 to Defendant, and the public, users, and their parents, including Plaintiff’s mother, could not have

2 discovered such serious safety risks.

3 162. The public, users, and their parents, including Plaintiff’s mother, did not know of

4 the serious safety risks posed by the design of Defendant’s app, which were known by Defendant.

5 163. By intentionally concealing and failing to disclose defects inherent in the design of

6 its app, Defendant knowingly and recklessly misled the public, users, and their parents, including

7 Plaintiff’s mother, into believing that its app was safe for children to use.

8 164. Defendant knew that its concealment, omissions, and misrepresentations were

9 material. A reasonable person, including Plaintiff’s mother, would find information about the risk
10 of grooming, sexual abuse, sexual exploitation, and other serious risks associated with the use of

11 Defendant’s app, to be important when deciding whether to allow children to use it.

12 165. Defendant intended to deceive the public, users, and their parents, including
13 Plaintiff’s mother, by making misrepresentations and concealing the defects in the design of its

14 app, which made the app unsafe.

15 166. As a direct and proximate result of Defendant’s concealment of material information

16 and misrepresentations, Plaintiff’s mother was not aware and could not have been aware of the

17 facts that Defendant concealed, and therefore justifiably and reasonably believed that Defendant’s

18 app was safe for children to use.

19 167. If the serious safety risks presented by the design of Defendant’s app had been
20 disclosed, the public, users, and their parents, including Plaintiff’s mother, reasonably would have

21 acted differently and/or would have not permitted children to use the app.

22 168. As a direct and proximate result of Defendant’s concealment of material information

23 and misrepresentations, Plaintiff sustained serious injuries and harm.

24 169. Defendant’s concealment of material information and misrepresentations were a

25 substantial factor in causing harm to Plaintiff.

26 170. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

27 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

28 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

COMPLAINT AGAINST ROBLOX CORPORATION 52

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 56 of 81

1 including to the health, safety, and welfare of its customers, and warrants an award of punitive

2 damages in an amount sufficient to punish Defendant and deter others from like conduct.

3 171. Plaintiff demands judgment against Defendant for compensatory and punitive

4 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

5 deems proper.

6 SECOND CAUSE OF ACTION

7 NEGLIGENT MISREPRESENTATION

8 (By Plaintiff Against Defendant)

9 172. Plaintiff incorporates each and every factual allegation set forth above.
10 173. This claim is brought against Defendant Roblox.
11 174. As set forth in more detail above, Defendant knew about the defective conditions of
12 its app and that the app posed serious safety risks to child users. Instead of disclosing the truth,

13 Defendant engaged in a widespread public campaign to tout the safety of its platform in the media,

14 and in the materials provided to potential users of the app, as described above.

15 175. Defendant made numerous false representations about the safety of its app, as
16 described above, which were specific and widespread. Plaintiff’s mother and the public at large

17 relied on Defendant’s false representations in deciding to allow children to play on the app.

18 176. By making numerous material representations downplaying any potential harm

19 associated with its app and reassuring the public, users, and their parents, including Plaintiff, that

20 its app was safe, Defendant negligently misled the public, users, and their parents, including

21 Plaintiff’s mother, into believing its app was safe for children to use.

22 177. Defendant had no reasonable grounds for believing that its misrepresentations that
23 its app was safe for children to use were true.

24 178. As a direct and proximate result of Defendant’s material omissions,

25 misrepresentations, and concealment of material information, Plaintiff’s mother was not aware and

26 could not have been aware of the facts that Defendant misstated, and therefore justifiably and

27 reasonably believed that Defendant’s app was safe for use.

28

COMPLAINT AGAINST ROBLOX CORPORATION 53

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 57 of 81

1 179. As a direct and proximate result of Defendant’s material omissions and

2 misrepresentations, Plaintiff sustained serious injuries and harm.

3 180. Plaintiff’s mother’s reliance on Defendant’s misrepresentations about the safety of

4 its app were substantial factors in causing harm to Plaintiff.

5 181. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

6 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

7 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

8 including to the health, safety, and welfare of their customers, and warrants an award of punitive

9 damages in an amount sufficient to punish them and deter others from like conduct.
10 182. Plaintiff demands judgment against Defendant for compensatory and punitive
11 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

12 deems proper.

13 THIRD CAUSE OF ACTION

14 NEGLIGENCE – GENERAL

15 (By Plaintiff Against Defendant)

16 183. Plaintiff incorporates each and every factual allegation set forth above.

17 184. This claim is brought against Defendant Roblox.

18 185. At all relevant times, Defendant developed, set up, managed, maintained, operated,

19 marketed, advertised, promoted, supervised, controlled, and benefited from its respective app used

20 by Plaintiff.

21 186. Defendant owed Plaintiff a duty to exercise reasonable care in the development,

22 setup, management, maintenance, operation, marketing, advertising, promotion, supervision, and

23 control of its app and not to create an unreasonable risk of harm from and in the use of its app

24 (including an unreasonable risk of grooming, sexual abuse, and sexual exploitation, and other

25 associated physical or mental injuries); to protect Plaintiff from unreasonable risk of injury from

26 and in the use of its app; and not to invite, encourage, or facilitate youth, such as Plaintiff, to

27 foreseeably engage in dangerous or risky behavior through, on, or as a reasonably foreseeable result

28

COMPLAINT AGAINST ROBLOX CORPORATION 54

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 58 of 81

1 of using its app. These duties govern Defendant’s own specific actions and are based on direct

2 actions Defendant took in developing its app and features.

3 187. In addition, Defendant owed a special relationship duty to Plaintiff to protect him

4 against harm caused by its app and employees or by other users. This special relationship duty is

5 based on the following:

6 a. As a business, Defendant owes a duty to protect customers against reasonably

7 foreseeable criminal acts of third parties and other dangers known to Defendant

8 on its app;

9 b. Plaintiff, as a minor, was vulnerable and dependent on Defendant for a safe

10 environment on their apps, and Defendant has superior ability and control to
11 provide that safety with respect to activities that they sponsor or control;
12 c. Plaintiff relied upon Defendant for protection against third-party misuse or
13 misconduct;
14 d. The special relationship Plaintiff had with Defendant substantially benefits
15 Defendant through profits and growth in users and user activity. Defendant
16 could not successfully operate without the growth in users and user activity
17 generated by children;
18 e. Defendant was far more to Plaintiff than a business. Defendant provided
19 Plaintiff with opportunities for social interaction and a discrete community of
20 other users. Plaintiff was dependent on Defendant to provide structure,
21 guidance, and a safe environment;
22 f. Defendant has superior control over its app environments and the ability to
23 protect its users. Defendant imposes a variety of rules and restrictions to
24 supposedly maintain a safe and orderly environment. Defendant employs
25 internal staff to enforce these rules and restrictions and can monitor and
26 discipline users when necessary. Defendant has the power to influence
27 Plaintiff’s values, consciousness, relationships, and behaviors; and
28

COMPLAINT AGAINST ROBLOX CORPORATION 55

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 59 of 81

1 g. Defendant has voluntarily undertaken a responsibility to keep children safe on

2 its app. As alleged above, Defendant has publicly stated that it takes steps to

3 keep children safe on its app and therefore has undertaken a duty to act

4 reasonably in taking such steps.

5 188. Plaintiff was a foreseeable user of Defendant’s app.

6 189. Defendant knew that minors such as Plaintiff would use its app.

7 190. Defendant invited, solicited, encouraged, or reasonably should have foreseen the

8 fact, extent, and manner of Plaintiff’s use of its app.

9 191. Defendant knew or, by the exercise of reasonable care, should have known, that the
10 reasonably foreseeable use of its app (as developed, set up, managed, maintained, supervised, and

11 operated by Defendant) was dangerous, harmful, and injurious when used by youth such as Plaintiff

12 in a reasonably foreseeable manner.

13 192. At all relevant times, Defendant knew or, by the exercise of reasonable care, should
14 have known that its app (as developed, set up, managed, maintained, supervised, and operated by

15 Defendant) posed unreasonable risks of harm to youth such as Plaintiff, which risks were known

16 and knowable, including in light of the internal data and knowledge Defendant had regarding its

17 app.

18 193. Defendant knew, or by the exercise of reasonable care, should have known, that
19 ordinary child users of its app, such as Plaintiff, would not have realized the potential risks and

20 dangers of using the app, including a risk of grooming, sexual abuse, and sexual exploitation, which

21 foreseeably can lead to a cascade of negative effects, including but not limited to physical injury,

22 damage to self-worth, stigma and social isolation, reduced academic performance, increased risky

23 behavior, susceptibility to future sexual exploitation, attachment issues, identity confusion, and

24 profound mental health issues for young consumers, including but not limited to depression,

25 anxiety, suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, eating disorders,

26 death, and other harmful effects.

27 194. Defendant’s conduct was closely connected to Plaintiff’s injuries, which were
28 highly certain to occur, as evidenced by the significance of Plaintiff’s injuries.

COMPLAINT AGAINST ROBLOX CORPORATION 56

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 60 of 81

1 195. Defendant could have avoided Plaintiff’s injuries with minimal cost, including, for

2 example, by not including certain features in its app which harmed Plaintiff.

3 196. Imposing a duty on Defendant would benefit the community at large.

4 197. Imposing a duty on Defendant would not be burdensome to them because they have

5 the technological and financial means to avoid the risks of harm to Plaintiff.

6 198. Defendant owed a heightened duty of care to youth users of its app because

7 children’s brains are not fully developed, meaning young people are more neurologically

8 vulnerable than adults to abusive contact facilitated by Defendant’s app because they have a hard

9 time distinguishing between patterns of genuine friendship and grooming relationships.

10 199. Defendant breached its duties of care owed to Plaintiff through its affirmative
11 malfeasance, actions, business decisions, and policies in the development, set up, management,

12 maintenance, operation, marketing, advertising, promotion, supervision, and control of its

13 respective app. These breaches are based on Defendant’s own actions in managing their own apps

14 made available to the public, independent of any actions taken by a third party. Those breaches

15 include but are not limited to:

16 a. Including features in its app that, as described above, are currently structured
17 and operated in a manner that unreasonably creates or increases the foreseeable
18 risk of grooming, sexual abuse, and sexual exploitation to youth, including
19 Plaintiff;
20 b. Including features in its app that, as described above, are currently structured
21 and operated in a manner that unreasonably creates or increases the foreseeable
22 risk of harm to the physical and mental health and well-being of youth users,
23 including Plaintiff, including but not limited to physical injury, damage to self-
24 worth, stigma and social isolation, reduced academic performance, increased
25 risky behavior, susceptibility to future sexual exploitation, attachment issues,
26 identity confusion, and profound mental health issues for young consumers,
27 including but not limited to depression, anxiety, suicidal ideation, self-harm,
28

COMPLAINT AGAINST ROBLOX CORPORATION 57

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 61 of 81

1 post-traumatic stress disorder, insomnia, eating disorders, death, and other

2 harmful effects;

3 c. Maintaining unreasonably dangerous features in its app after notice that such

4 features, as structured and operated, posed a foreseeable risk of harm to the

5 physical and mental health and well-being of youth users;

6 d. Facilitating unsupervised and/or hidden use of its app by youth, including by

7 adopting protocols that allow youth users to change its own safety settings or

8 parental controls, and create multiple and private accounts; and

9 e. Inviting children on its app and marketing to children when Defendant knew
10 that its app, as designed, was not safe for children.
11 200. Defendant breached its duties of care owed to Plaintiff through its nonfeasance,
12 failure to act, and omissions in the development, setup, management, maintenance, operation,

13 marketing, advertising, promotion, supervision, and control of its app. These breaches are based on

14 Defendant’s own actions in managing their own apps made available to the public, independent of

15 any actions taken by a third party. Those breaches include but are not limited to:

16 a. Failing to implement effective parental controls;

17 b. Failing to screen users before allowing them on the app;
18 c. Failing to implement effective parental notifications, such as when a child
19 messages another user, particularly an adult user, or when a child interacts with
20 accounts that have been blocked by other users or suspended in the past;
21 d. Failing to require adult users to provide a phone number when signing up for an
22 account;
23 e. Failing to implement pop-up safety notices within chats and games to warn users
24 about inappropriate behavior;
25 f. Failing to ban IP and MAC addresses of accounts associated with known
26 abusers;
27 g. Failing to set default safety settings to the most protective options;
28 h. Having an open chat function;

COMPLAINT AGAINST ROBLOX CORPORATION 58

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 62 of 81

1 i. Failing to provide a transcript of a child’s communications to the parent;

2 j. Failing to implement reasonably available means to monitor for, report, and

3 prevent the use of their apps by sexual predators to victimize, abuse, and exploit

4 youth users;

5 k. Failing to provide effective mechanisms for youth users and their

6 parents/guardians to report abuse or misuse of its app;

7 l. Failing to implement effective protocols to verify ages and identity of all users;

8 m. Failing to place reasonable age restrictions on its app;

9 n. Failing to separate adults from children on the apps by, for example, creating
10 separate apps for children;
11 o. Failing to adequately fund its trust and safety programs; and
12 p. Others as set forth herein.
13 201. A reasonable company under the same or similar circumstances as Defendant would
14 have developed, set up, managed, maintained, supervised, and operated its app in a manner that is

15 safer for and more protective of youth users like Plaintiff.

16 202. At all relevant times, Plaintiff used Defendant’s app in the manner in which it was
17 intended to be used.

18 203. As a direct and proximate result of each Defendant’s breach of one or more of its
19 duties, Plaintiff was harmed. Such harms include the sexual exploitation of Plaintiff by a child

20 predator and a cascade of resulting negative effects, including but not limited to damage to self-

21 worth, stigma and social isolation, reduced academic performance, increased risky behavior,

22 susceptibility to future sexual exploitation, attachment issues, and profound mental health issues

23 such as depression, anxiety, and other harmful effects.

24 204. Defendant’s breach of one or more of its duties was a substantial factor in causing
25 harms and injuries to Plaintiff.

26 205. Plaintiff was injured from using Defendant’s defective app through no fault of his
27 own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

28 responsible for the injuries caused by Defendant’s app and the burden shifts to Defendant to

COMPLAINT AGAINST ROBLOX CORPORATION 59

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 63 of 81

1 identify alternative causes of the alleged injuries and apportion responsibility for the alleged

2 injuries.

3 206. The nature of the fraudulent and unlawful acts that created safety concerns for

4 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

5 207. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

6 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

7 entire want of care and a conscious and depraved indifference to the consequences of their conduct,

8 including to the health, safety, and welfare of their customers, and warrants an award of punitive

9 damages in an amount sufficient to punish the Defendant and deter others from like conduct.
10 208. Plaintiff demands judgment against Defendant for compensatory and punitive
11 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

12 deems proper.

13 FOURTH CAUSE OF ACTION

14 NEGLIGENCE – FAILURE TO WARN

15 (By Plaintiff Against Defendant)

16 209. Plaintiff incorporates each and every factual allegation set forth above.

17 210. This claim is brought against Defendant Roblox.

18 211. At all relevant times, Defendant designed, developed, managed, operated, tested,

19 produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

20 benefited from its app used by Plaintiff.

21 212. Plaintiff was a foreseeable user of Defendant’s app.

22 213. Defendant knew, or by the exercise of reasonable care, should have known, that use

23 of its app was dangerous, harmful, and injurious when used in a reasonably foreseeable manner by

24 minors.

25 214. Defendant knew, or by the exercise of reasonable care, should have known, that

26 ordinary minor users, such as Plaintiff, would not have realized the potential risks and dangers of

27 its app, including a risk of grooming, sexual abuse, and sexual exploitation, which can lead to a

28 cascade of harms. Those harms include but are not limited to physical injury, damage to self-worth,

COMPLAINT AGAINST ROBLOX CORPORATION 60

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 64 of 81

1 stigma and social isolation, reduced academic performance, increased risky behavior, susceptibility

2 to future sexual exploitation, attachment issues, identity confusion, and profound mental health

3 issues for young consumers, including but not limited to depression, anxiety, suicidal ideation, self-

4 harm, post-traumatic stress disorder, insomnia, death, and other harmful effects.

5 215. Had Plaintiff received proper or adequate warnings about the risks of Defendant’s

6 app, Plaintiff would have heeded such warnings.

7 216. Defendant knew or, by the exercise of reasonable care, should have known that its

8 app posed risks of harm to youth. These risks were known and knowable in light of Defendant’s

9 own internal data and knowledge regarding its app at the time of development, design, marketing,
10 promotion, advertising, and distribution to Plaintiff.

11 217. Because Defendant’s conduct created the risk that child users of their apps would
12 be subject to grooming, sexual abuse, and sexual exploitation, Defendant owed a duty to all

13 reasonably foreseeable users, including but not limited to minor users and their parents, to provide

14 adequate warnings about the risk of using Defendant’s app that were known to Defendant, or that

15 Defendant should have known through the exercise of reasonable care.

16 218. In addition, as described above, Defendant owed a special relationship duty to

17 Plaintiff to protect him against harm caused by its app and employees or by other users.

18 219. Defendant owed a heightened duty of care to minor users and their parents to warn
19 about its app’s risks because children’s brains are not fully developed, resulting in a diminished

20 capacity to make responsible decisions regarding contact with strangers online. Children are also

21 more neurologically vulnerable than adults to abusive contact facilitated by Defendant’s app

22 because they have a hard time distinguishing between patterns of genuine friendship and grooming

23 relationships.

24 220. Defendant breached its duty by failing to use reasonable care in providing adequate
25 warnings to Plaintiff, such as failing to notify parents and the general public of the following,

26 among others:

27 a. Defendant fails to require that children have parental approval before signing up
28 for an account;

COMPLAINT AGAINST ROBLOX CORPORATION 61

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 65 of 81

1 b. Defendant fails to screen users before allowing them on their apps;

2 c. New users of Defendant’s app can identify themselves as minors, begin to use

3 the app, and do so indefinitely, without ever receiving a safety warning, and

4 without ever having to provide information so that Defendant can warn the

5 users’ parents or guardians;

6 d. Defendant’s app’s default safety settings allow adults and other strangers’

7 accounts to find, “friend,” and communicate with children’s accounts;

8 e. Defendant’s parental control settings allowed children to modify their own

9 parental control settings;

10 f. Defendant’s platforms recommend that adult users and other strangers “friend”
11 and contact child accounts;
12 g. Defendant fails to block the IP and MAC addresses of known abusers;
13 h. Adult predators use Defendant’s to target children for sexual exploitation,
14 sextortion, and CSAM;
15 i. Defendant’s app enables and increases risk of exposure to predators and can
16 result in grooming, sexual abuse, and sexual exploitation, as well as their
17 resultant physical and mental injuries;
18 j. Sexual predators use Robux to coerce children into sending them nude photos
19 or engaging in other types of sexually explicit behavior;
20 k. Usage of Defendant’s app can increase risky and uninhibited behavior in
21 children, making them easier targets to adult predators for sexual exploitation,
22 sextortion, and CSAM;
23 l. Usage of Defendant’s app can normalize abuse and pornography, leading
24 children to abuse other children either contemporaneously or later when the
25 children are older;
26 m. The likelihood and severity of harm is greater for children;
27 n. The likelihood and intensity of these harmful effects is exacerbated by the
28 interaction of the app’s features with one another;

COMPLAINT AGAINST ROBLOX CORPORATION 62

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 66 of 81

1 o. Defendant fails to verify ages, allowing adult predators to pose as children on

2 Defendant’s app;

3 p. Defendant’s failure to verify ages allows children to bypass parental controls,

4 safety features, and default settings; and

5 q. Others as set forth herein.

6 221. A reasonable company under the same or similar circumstances as Defendant would

7 have used reasonable care to provide adequate warnings to consumers, including the parents of

8 minor users, as described herein.

9 222. At all relevant times, Defendant could have provided adequate warnings to prevent
10 the harms and injuries described herein.

11 223. As a direct and proximate result of Defendant’s breach of its duty to provide
12 adequate warnings, Plaintiff was harmed and sustained the injuries set forth herein. Defendant’s

13 failure to provide adequate and sufficient warnings was a substantial factor in causing the harms to

14 Plaintiff.

15 224. As a direct and proximate result of Defendant’s failure to warn, Plaintiff requires
16 and/or will require more healthcare and services and did incur medical, health, incidental, and

17 related expenses.

18 225. Plaintiff was injured from using Defendant’s defective app through no fault of his
19 own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

20 responsible for the injuries caused Defendant’s app and the burden shifts to Defendants to identify

21 alternative causes of the alleged injuries and apportion responsibility for the alleged injuries.

22 226. The nature of the fraudulent and unlawful acts that created safety concerns for
23 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

24 227. The conduct of Defendant, as described above, was intentional, fraudulent, willful,
25 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

26 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

27 including to the health, safety, and welfare of their customers, and warrants an award of punitive

28 damages in an amount sufficient to punish Defendant and deter others from like conduct.

COMPLAINT AGAINST ROBLOX CORPORATION 63

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 67 of 81

1 228. Plaintiff demands judgment against Defendant for compensatory and punitive

2 damages, together with interest, costs of suit, attorneys' fees, and all such other relief as the Court

3 deems proper.

4 FIFTH CAUSE OF ACTION

5 NEGLIGENCE – UNREASONABLE DESIGN

6 (By Plaintiff Against Defendant)

7 229. Plaintiff incorporates each and every factual allegation set forth above.

8 230. This claim is brought against Defendant Roblox.

9 231. At all relevant times, Defendant designed, developed, managed, operated, tested,
10 produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

11 benefited from its app used by Plaintiff.

12 232. Defendant knew or, by the exercise of reasonable care, should have known, that its
13 app was dangerous, harmful, and injurious when used by youth in a reasonably foreseeable manner.

14 233. Defendant knew or, by the exercise of reasonable care, should have known that its
15 app posed risks of harm to youth. These risks were known and knowable in light of Defendant’s

16 own internal data and knowledge regarding their apps at the time of the app’s development, design,

17 marketing, promotion, advertising, and distribution to Plaintiff.

18 234. Defendant knew, or by the exercise of reasonable care, should have known, that
19 ordinary minor consumers such as Plaintiff would not have realized the potential risks and dangers

20 of its app. Those risks include grooming, sexual abuse, and sexual exploitation, which can lead to

21 a cascade of negative effects, including but not limited to physical injury, damage to self-worth,

22 stigma and social isolation, reduced academic performance, increased risky behavior, susceptibility

23 to future sexual exploitation, attachment issues, identity confusion, and profound mental health

24 issues for young consumers, including but not limited to depression, anxiety, suicidal ideation, self-

25 harm, post-traumatic stress disorder, insomnia, death, and other harmful effects.

26 235. Defendant owed a duty to all reasonably foreseeable users to design a safe app.
27 236. Defendant owed a heightened duty of care to minor users of its app because
28 children’s brains are not fully developed, resulting in a diminished capacity to make responsible

COMPLAINT AGAINST ROBLOX CORPORATION 64

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 68 of 81

1 decisions regarding contact with strangers online. Children are also more neurologically vulnerable

2 than adults to abusive contact facilitated by Defendant’s app because they have a hard time

3 distinguishing between patterns of genuine friendship and grooming relationships.

4 237. Plaintiff was a foreseeable user of Defendant’s app.

5 238. Defendant knew that minors such as Plaintiff would use its app.

6 239. Defendant breached its duty in designing its app.

7 240. Defendant breached its duty by failing to use reasonable care in the design of its app

8 by negligently designing the app with features that specifically allow predators to find, groom,

9 exploit, and abuse children, as described herein.

10 241. Defendant breached its respective duty by designing an app that was less safe to use
11 than an ordinary consumer would expect when used in an intended and reasonably foreseeable

12 manner.

13 242. Defendant breached its respective duty by failing to use reasonable care in the
14 design of its app by negligently designing its app with features as described above that created or

15 increased the risk of grooming, sexual abuse, and sexual exploitation for children, which can lead

16 to a cascade of negative effects, including but not limited to physical injury, damage to self-worth,

17 stigma and social isolation, reduced academic performance, increased risky behavior, susceptibility

18 to future sexual exploitation, attachment issues, identity confusion, and profound mental health

19 issues for young consumers, including but not limited to depression, anxiety, suicidal ideation, self-

20 harm, post-traumatic stress disorder, insomnia, death, and other harmful effects.

21 243. Defendant breached its duty by failing to use reasonable care to use cost-effective,
22 reasonably feasible alternative designs, including changes to the harmful features, and other safety

23 measures, to minimize the harms described herein, including but not limited to:

24 a. Requiring children have parental approval and a parent’s email address to sign-
25 up for an account;
26 b. Effective parental controls;
27 c. Effective parental notifications, including notifying parents any time a child
28 messages another user, particularly an adult user, or notifying parents when

COMPLAINT AGAINST ROBLOX CORPORATION 65

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 69 of 81

1 children interact with accounts that have been blocked by other users or

2 suspended in the past, among other controls;

3 d. Setting default safety settings to the most protective options, including blocking

4 direct messaging between child and adult users, or only allowing messaging

5 between adult users and a child with the parent’s explicit permission to message

6 the adult user;

7 e. Requiring adults to provide a phone number when signing up for an account;

8 f. Pop-up safety notices within chats and games to warn users about inappropriate

9 behavior;
10 g. Preventing strangers from sending Robux to child accounts, and preventing
11 children from sending Robux to strangers’ accounts;
12 h. Banning IP and MAC addresses of accounts associated with known abusers;
13 i. Controlled chat option;
14 j. Providing a transcript of a child’s communications to the parent;
15 k. Implementing reporting protocols to allow users or visitors of Defendants’ apps
16 to report CSAM and adult predator accounts specifically without the need to
17 create or log in to the apps prior to reporting;
18 l. Robust age and identity verification;
19 m. Reasonable age restrictions;
20 n. Separating adults from children by, for example, creating separate apps for
21 children; and
22 o. Others as set forth herein.
23 244. Alternative designs that would reduce the dangerous features of Defendant’s app
24 were available, would have served effectively the same purpose as Defendant’s defectively

25 designed app, and would have reduced the gravity and severity of danger Defendant’s app posed

26 minor Plaintiff.

27 245. A reasonable company under the same or similar circumstances as Defendant would
28 have designed a safer app.

COMPLAINT AGAINST ROBLOX CORPORATION 66

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 70 of 81

1 246. At all relevant times, Plaintiff used Defendant’s app in the manner in which it was

2 intended by Defendant to be used.

3 247. As a direct and proximate result of Defendant’s breached duties, Plaintiff was

4 harmed. Defendant’s design of its app was a substantial factor in causing Plaintiff’s harms and

5 injuries.

6 248. Plaintiff was injured from using Defendants’ defective app through no fault of his

7 own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

8 responsible for the injuries caused by Defendant’s app and the burden shifts to Defendant to

9 identify alternative causes of the alleged injuries and apportion responsibility for the alleged
10 injuries.

11 249. The nature of the fraudulent and unlawful acts that created safety concerns for
12 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

13 250. The conduct of Defendant, as described above, was intentional, fraudulent, willful,
14 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

15 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

16 including to the health, safety, and welfare of its customers, and warrants an award of punitive

17 damages in an amount sufficient to punish Defendant and deter others from like conduct.

18 251. Plaintiff demands judgment against Defendant for compensatory and punitive
19 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

20 deems proper.

21 SIXTH CAUSE OF ACTION

22 NEGLIGENT UNDERTAKING

23 (By Plaintiff Against Defendant)

24 252. Plaintiff incorporates each and every factual allegation set forth above.

25 253. This claim is brought against Defendant Roblox.

26 254. Defendant rendered parental control services and account safety services to

27 Plaintiff’s parents.

28

COMPLAINT AGAINST ROBLOX CORPORATION 67

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 71 of 81

1 255. Defendant made numerous statements, as outlined above, claiming in substance that

2 their parental controls and account safety services were highly effective at protecting users from

3 the type of harm Plaintiff suffered.

4 256. Defendant knew, or reasonably should have known, that effective parental control

5 and account safety services were necessary for the protection of minor users.

6 257. Defendant’s conduct was closely connected to Plaintiff’s injuries, which were

7 highly certain to occur, as evidenced by the significance of Plaintiff’s injuries.

8 258. Defendant could have avoided Plaintiff’s injuries with minimal cost, including, for

9 example, by implementing parental control and account safety services that were effective and that
10 would prevent child users from being contacted by adult accounts or strangers’ accounts generally.

11 259. Imposing a duty on Defendant would benefit the community at large.

12 260. Imposing a duty on Defendant would not be burdensome to them because it has the
13 technological and financial means to avoid the risks of harm to children.

14 261. Defendant owed a heightened duty of care to minor users and their parents to
15 implement parental control and account safety services that were effective and that would prevent

16 child users from being contacted by adult accounts or strangers’ accounts generally.

17 262. Plaintiff’s mother relied on Defendant exercising reasonable care in undertaking to

18 render parental control and account safety services.

19 263. Defendant breached its duty of undertaking by failing to use reasonable care in
20 rendering its parental control and account safety services to prevent child users from being

21 contacted by adult accounts or strangers’ accounts generally.

22 264. Defendant failed to exercise reasonable care in rendering these parental control and
23 account safety services.

24 265. Defendant’s failure to exercise reasonable care increased the risk of, and was a
25 substantial factor in causing harm to Plaintiff.

26 266. Plaintiff was harmed by his mother’s reliance on Defendant to provide effective
27 parental control and account safety services.

28

COMPLAINT AGAINST ROBLOX CORPORATION 68

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 72 of 81

1 267. Defendant’s breach of one or more of its duties was a substantial factor in causing

2 harms and injuries to Plaintiff.

3 268. Plaintiff was injured from using Defendant’s defective app through no fault of his

4 own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

5 responsible for the injuries caused by any one of Defendants’ apps and the burden shifts to

6 Defendant to identify alternative causes of the alleged injuries and apportion responsibility for the

7 alleged injuries.

8 269. The nature of the fraudulent and unlawful acts that created safety concerns for

9 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.
10 270. The conduct of Defendant, as described above, was intentional, fraudulent, willful,
11 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

12 entire want of care and a conscious and depraved indifference to the consequences of their conduct,

13 including to the health, safety, and welfare of its customers, and warrants an award of punitive

14 damages.

15 271. Plaintiff demands judgment against Defendant for compensatory and punitive
16 damages, together with interest, costs of suit, attorneys' fees, and all such other relief as the Court

17 deems proper.

18 SEVENTH CAUSE OF ACTION

19 STRICT LIABILITY – DESIGN DEFECT

20 (By Plaintiff Against Defendant)

21 272. Plaintiff incorporates each and every factual allegation set forth above.

22 273. This claim is brought against Defendant Roblox.

23 274. At all relevant times, Defendant designed, developed, managed, operated, tested,

24 produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

25 benefitted from its product used by Plaintiff.

26 275. These products were designed, manufactured, maintained, controlled, and

27 distributed from the California headquarters of Defendant.

28

COMPLAINT AGAINST ROBLOX CORPORATION 69

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 73 of 81

1 276. Defendant’s product was designed and intended to be a gaming and/or

2 communication product. The software and architecture of each product is the same for every user

3 that logs on or signs up for an account. These products are uniformly defective and pose the same

4 danger to each minor user.

5 277. Defendant’s product is distributed and sold to the public through retail channels

6 (e.g., the Apple App “Store” and the Google Play “Store”).

7 278. Defendant’s product is marketed and advertised to the public for the personal use of

8 the end-user/consumer.

9 279. Defendant defectively designed its product to allow children to come into contact
10 with child predators. Children are particularly unable to appreciate the risks posed by the products.

11 280. The defects in the design of Defendant’s product existed prior to the release of these
12 products to Plaintiff and the public, and there was no substantial change to Defendant’s products

13 between the time of their upload by each Defendant to public or retail channels (e.g., the App Store

14 or Google Play) and the time of their distribution to Plaintiff via download or URL access.

15 281. Plaintiff used these products as intended, and Defendant knew or, by the exercise of
16 reasonable care, should have known that Plaintiff would use these products without inspection for

17 its dangerous nature.

18 282. Defendant defectively designed its product to appeal to adult predators by making
19 it easy to find children and enabled their contact, grooming, sexual exploitation, and sexual abuse

20 of children, including Plaintiff.

21 283. Defendant failed to test the safety of the features it developed and implemented for
22 use on its product. When Defendant did perform some product testing and had knowledge of

23 ongoing harm, it failed to adequately remedy its product’s defects or warn Plaintiff.

24 284. Defendant’s product is defective in design and poses a substantial likelihood of harm
25 for the reasons set forth herein, because the products fail to meet the safety expectations of ordinary

26 consumers when used in an intended or reasonably foreseeable manner, and because the products

27 are less safe than an ordinary consumer would expect when used in such a manner. Children and

28 teenagers are among the ordinary consumers of Defendant’s products. Indeed, Defendant markets,

COMPLAINT AGAINST ROBLOX CORPORATION 70

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 74 of 81

1 promotes, and advertises its respective product to pre-teen and young consumers. Pre-teen and

2 young consumers, and their parents and guardians, do not expect Defendant’s products to expose

3 them to predators when the products are used in their intended manner by their intended audience.

4 They do not expect the features embedded by Defendant in their products to make it easy for child

5 predators to sign-up for accounts and find children, groom children, and sexually exploit children.

6 They do not expect Defendant’s revenue and profits to be directly tied to predators’ extortion of

7 children.

8 285. Defendant’s product is likewise defectively designed in that it creates an inherent

9 risk of danger; specifically, a risk of grooming, sexual abuse, and sexual exploitation, which can
10 lead to a cascade of harms. Those harms include but are not limited to physical injury, damage to

11 self-worth, stigma and social isolation, reduced academic performance, increased risky behavior,

12 susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

13 mental health issues for young consumers, including but not limited to depression, anxiety, suicidal

14 ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful effects.

15 286. The risks inherent in the design of Defendant’s product significantly outweigh any
16 benefits of such design.

17 287. Defendant could have utilized cost-effective, reasonably feasible alternative

18 designs, including changes to the problematic features described above, to minimize the harms

19 described herein, including, but not limited to:

20 a. Requiring children have parental approval and a parent’s email address to sign-
21 up for an account;
22 b. Effective parental controls;
23 c. Effective parental notifications, including notifying parents any time a child
24 messages another user, particularly an adult user, or notifying parents when
25 children interact with accounts that have been blocked by other users or
26 suspended in the past, among other controls;
27 d. Setting default safety settings to the most protective options, including blocking
28 direct messaging between child and adult users, or only allowing messaging

COMPLAINT AGAINST ROBLOX CORPORATION 71

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 75 of 81

1 between adult users and a child with the parent’s explicit permission to message

2 the adult user;

3 e. Requiring adults to provide a phone number when signing up for an account;

4 f. Pop-up safety notices within chats and games to warn users about inappropriate

5 behavior;

6 g. Preventing strangers from sending Robux to child accounts, and preventing

7 children from sending Robux to strangers’ accounts;

8 h. Banning IP and MAC addresses of accounts associated with known abusers;

9 i. Controlled chat option;

10 j. Providing a transcript of a child’s communications to the parent;
11 k. Implementing reporting protocols to allow users or visitors of Defendants’
12 products to report child sex abuse material and adult predator accounts
13 specifically without the need to create or log in to the products prior to reporting;
14 l. Robust age and identity verification;
15 m. Reasonable age restrictions;
16 n. Separating adults from children by, for example, creating separate apps for
17 children; and
18 o. Others as set forth herein.
19 288. Alternative designs were available that would prevent child predators from finding,
20 grooming, and exploiting children, and which would have served effectively the same purpose of

21 Defendant’s products while reducing the gravity and severity of danger posed by those products’

22 defects.

23 289. Plaintiff used Defendant’s respective products as intended or in reasonably

24 foreseeable ways.

25 290. The physical, emotional, and economic injuries of Plaintiff were reasonably
26 foreseeable to Defendant at the time of its products’ development, design, advertising, marketing,

27 promotion, and distribution.

28

COMPLAINT AGAINST ROBLOX CORPORATION 72

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 76 of 81

1 291. Defendant’s product was defective and unreasonably dangerous when it left each

2 Defendant’s respective possession and control. The defects continued to exist through the products’

3 distribution to and use by consumers, including Plaintiff, who used the products without any

4 substantial change in the products’ condition.

5 292. As manufacturer, designer and seller, Defendant had a duty to inform itself with the

6 best knowledge of the risks and the defects of its product and Defendant had such knowledge. Their

7 victims, including Plaintiff, were powerless to protect themselves against unknown harms, and

8 Defendant should bear the costs of their injuries.

9 293. Plaintiff was injured as a direct and proximate result of Defendant’s respective
10 defective designs as described herein. The defective design of the products used by Plaintiff was a

11 substantial factor in causing harms to Plaintiff.

12 294. As a direct and proximate result of Defendant’s product’s defective design, Plaintiff
13 suffered serious and dangerous injuries.

14 295. As a direct and proximate result of Defendant’s product’s defective design, Plaintiff
15 requires and/or will require more healthcare and services and did incur medical, health, incidental,

16 and related expenses.

17 296. Plaintiff was injured from using Defendant’s defective products through no fault of
18 his own. The fact that Plaintiff was injured by using Defendant’s products means that Defendant is

19 responsible for the injuries caused by any one of Defendant’s products and the burden shifts to

20 Defendant to identify alternative causes of the alleged injuries and apportion responsibility for the

21 alleged injuries.

22 297. The nature of the fraudulent and unlawful acts that created safety concerns for
23 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s products.

24 298. The conduct of Defendant, as described above, was intentional, fraudulent, willful,
25 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

26 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

27 including to the health, safety, and welfare of its customers, and warrants an award of punitive

28 damages in an amount sufficient to punish Defendant and deter others from like conduct.

COMPLAINT AGAINST ROBLOX CORPORATION 73

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 77 of 81

1 299. Plaintiff demands judgment against Defendant for compensatory and punitive

2 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

3 deems proper.

4 EIGHTH CAUSE OF ACTION

5 STRICT LIABILITY – FAILURE TO WARN

6 (By Plaintiff Against Each Defendant)

7 300. Plaintiff incorporates each and every factual allegation set forth above.

8 301. This claim is brought against Defendant Roblox.

9 302. At all relevant times, Defendant designed, developed, managed, operated, tested,
10 produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

11 benefitted from its product used by Plaintiff.

12 303. These products were designed, manufactured, maintained, controlled and

13 distributed from the California headquarters of Defendant.

14 304. Defendant’s product was designed and intended to be a gaming and/or

15 communication product. The software and architecture of each product is the same for every user

16 that logs on or signs up for an account. These products are uniformly defective and pose the same

17 danger to each minor user.

18 305. Defendant’s product is distributed and sold to the public through retail channels
19 (e.g., the Apple App “Store” and the Google Play “Store”).

20 306. Defendant sold and distributed its product to Plaintiff in a defective and
21 unreasonably dangerous condition by failing to adequately warn about the risk of harm to youth as

22 described herein, including a risk of grooming, sexual abuse, and sexual exploitation, which can

23 lead to a cascade of harms. Those harms include but are not limited to physical injury, damage to

24 self-worth, stigma and social isolation, reduced academic performance, increased risky behavior,

25 susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

26 mental health issues for young consumers including but not limited to depression, anxiety, suicidal

27 ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful effects.

28

COMPLAINT AGAINST ROBLOX CORPORATION 74

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 78 of 81

1 307. Defendant was in the best position to know the dangers its products posed to

2 consumers, including Plaintiff, as they had superior knowledge of the risks and dangers posed by

3 their products and had exclusive knowledge of these risks at the time of development, design,

4 marketing, promotion, advertising and distribution. Defendant had exclusive control of its products

5 at all times relevant to this litigation.

6 308. Defendant’s respective product is dangerous, to an extent beyond that contemplated

7 by the ordinary user who used Defendant’s products, because they enable predators to find, groom,

8 abuse, and exploit children.

9 309. Defendant knew or, by the exercise of reasonable care, should have known that its
10 respective product posed risks of harm to youth considering its own internal data and knowledge

11 regarding its product at the time of development, design, marketing, promotion, advertising, and

12 distribution.

13 310. These risks were known and knowable in light of Defendant’s own internal data and
14 knowledge regarding their products at the time of the products’ development, design, marketing,

15 promotion, advertising, and distribution to Plaintiff.

16 311. Defendant’s products are defective and unreasonably dangerous because, among
17 other reasons described herein, each Defendant failed to exercise reasonable care to inform users

18 that, among other things:

19 a. Sexual predators use Defendant’s products to find, contact, groom and abuse
20 children with alarming frequency;
21 b. Sexual predators use Defendant’s products to solicit, produce, and distribute
22 CSAM with alarming frequency;
23 c. Sexual predators target young children for CSAM on Defendant’s products with
24 alarming frequency;
25 d. Sexual predators use Robux to coerce children into sending them nude photos
26 or engaging in other types of sexually explicit behavior;
27 e. Defendant’s products are designed in a way that enables and increases risk of
28 exposure to predators and resulting sexual exploitation;

COMPLAINT AGAINST ROBLOX CORPORATION 75

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 79 of 81

1 f. Defendant’s products cause grooming, sexual abuse, and sexual exploitation,

2 and its resultant physical and mental injuries;

3 g. Use of Defendant’s products can increase risky and uninhibited behavior in

4 children, making them easier targets to adult predators for sexual exploitation,

5 sextortion, and CSAM;

6 h. Use of Defendant’s products can normalize abuse and pornography, leading

7 children to abuse other children either contemporaneously or later when the

8 children are older;

9 i. New users of Defendant’s product can identify themselves as minors, begin to

10 use the product, and do so indefinitely, without ever receiving a safety warning,
11 and without ever having to provide information so that Defendants can warn the
12 users’ parents or guardians;
13 j. Defendant’s failure to verify ages allows children to bypass parental controls,
14 safety features, and default settings;
15 k. The likelihood and severity of harms is greater for children;
16 l. The likelihood and intensity of these harmful effects is exacerbated by the
17 interaction of each product’s features with one another; and
18 m. Others as set forth herein.
19 312. Plaintiff was a foreseeable user of Defendant’s product.
20 313. Ordinary minor users would not have recognized the potential risks of Defendant’s
21 products when used in a manner reasonably foreseeable to Defendant.

22 314. Had Plaintiff received proper or adequate warnings or instructions as to the risks of
23 using Defendant’s product, Plaintiff would have heeded the warnings and/or followed the

24 instructions.

25 315. Defendant’s failures to adequately warn Plaintiff about the risks of their defective
26 products were a proximate cause and a substantial factor in the injuries sustained by Plaintiff.

27 316. Plaintiff was injured from using Defendants’ defective products through no fault of
28 his own. The fact that Plaintiff was injured by using Defendant’s products means that Defendant is

COMPLAINT AGAINST ROBLOX CORPORATION 76

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 80 of 81

1 responsible for the injuries caused by Defendant’s products and the burden shifts to Defendant to

2 identify alternative causes of the alleged injuries and apportion responsibility for the alleged

3 injuries.

4 317. The nature of the fraudulent and unlawful acts that created safety concerns for

5 Plaintiff are not the type of risks that are immediately apparent from using Defendant’s products.

6 318. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

7 wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

8 entire want of care and a conscious and depraved indifference to the consequences of its conduct,

9 including to the health, safety, and welfare of their customers, and warrants an award of punitive
10 damages in an amount sufficient to punish Defendant and deter others from like conduct.

11 319. Plaintiff demands judgment against Defendant for compensatory and punitive
12 damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

13 deems proper.

14 VII. PRAYER FOR RELIEF

15 WHEREFORE, Plaintiff demands judgment against Defendant for the above-referenced

16 claims and causes of action, and as follows:

17 1. Past, present, and future general damages, the exact amount of which has yet to be

18 ascertained, in an amount which will confirm to proof at time of trial, to compensate

19 Plaintiff for injuries sustained as a result of the use of Defendant’s products,

20 including but not limited to physical pain and suffering, mental anguish, loss of

21 enjoyment of life, emotional distress, and expenses for medical treatments;

22 2. Past, present, and future economic and special damages, according to proof at the

23 time of trial;

24 3. Impaired earning capacity according to proof at the time of trial;

25 4. Medical expenses, past and future, according to proof at the time of trial;

26 5. Punitive or exemplary damages according to proof at the time of trial;

27 6. Attorneys’ fees;

28 7. For costs of suit incurred herein;

COMPLAINT AGAINST ROBLOX CORPORATION 77

 Case 1:25-cv-00172 Document 1 Filed on 08/06/25 in TXSD Page 81 of 81

1 8. Pre-judgment and post-judgment interest as provided by law;

2 9. For nonmonetary injunctive relief; and

3 10. For such other and further relief as the Court may deem just and proper.

4 VIII. DEMAND FOR A JURY TRIAL

5 320. Plaintiff hereby demands a trial by jury on all claims so triable.

7 Date: August 6, 2025 Respectfully submitted,

8 DOLMAN LAW GROUP

9
10 By: /s/ Anthony J. Russo
Anthony J. Russo (Texas Bar No. 24140657)
11 [email protected]
Matthew A. Dolman*
12
[email protected]
13 R. Stanley Gipe*
[email protected]
14 Sara D. Beller*
[email protected]
15 800 N. Belcher Rd.
Clearwater, FL 33765
16
Telephone: (727) 451-6900
17 Facsimile: (727) 451-6907

18
Attorneys for Plaintiff John Doe and His Next
19 Friend Jane Doe
20
*Pro Hac Vice motions forthcoming
21

22

23

24

25

26

27

28

COMPLAINT AGAINST ROBLOX CORPORATION 78

JS 44 (Rev. 03/24) Case 1:25-cv-00172 Document 1-1 Filed
CIVIL COVER on 08/06/25 in TXSD
SHEET Page 1 of 2
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Jane Doe as guardian of minor John Doe Roblox Corporation
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant San Mateo, California
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Dolman Law Group (727) 451-6900

800 N. Belcher Rd., Clearwater, FL 33765
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ INTELLECTUAL 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity) :
28 U.S.C. § 1332ct Diversity-(Citizenship)
VI. CAUSE OF ACTION Brief description of cause:
Plaintiff brings this action to recover damages arising from injuries suffered because of Defendant's misrepresentations and failure to warn.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
Aug 6, 2025 /s/ Anthony J. Russo
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

 Case 1:25-cv-00172
JS 44 Reverse (Rev. 03/24) Document 1-1 Filed on 08/06/25 in TXSD Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statute.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related cases, if any. If there are related cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.