IN THE CIRCUIT COURT OF CLAY COUNTY

STATE OF MISSOURI

Case No.:
JANE DOE R.S. as guardian and next
friend of minor plaintiff, JOHN DOE
H.M., (1) Fraudulent Concealment and
Misrepresentations
Plaintiff, (2) Negligent Misrepresentation
(3) Negligence – General
v. (4) Negligence – Failure to Warn
(5) Negligence – Unreasonable Design
ROBLOX CORPORATION, (6) Negligent Undertaking
(7) Strict Liability – Design Defect
Defendant. (8) Strict Liability – Failure to Warn

JURY TRIAL DEMANDED

COMPLAINT

COMES NOW the Plaintiff, Jane Doe R.S., as guardian and next friend of minor Plaintiff

John Doe H.M. (“Plaintiff”), by their attorneys, Wallace Miller and Dolman Law Group and

brings this action against Roblox Corporation (“Roblox” or “Defendant”) to recover damages

arising from the severe injuries that Plaintiff suffered because of Defendant’s conduct in creating,

designing, marketing, and distributing its mobile- and web-based application (“app”), and alleges

as follows:
I. INTRODUCTION

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

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

against Plaintiff were committed by a dangerous child predator whose actions were possible only

because of the egregiously tortious conduct of Defendant.

2. Through its pervasive patterns of misrepresentations about safety, Defendant

portrays its app as a safe and appropriate place for children to play. In reality, and as Defendant

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

1
appropriate safeguards to ensure that children were in fact safe or that predators were screened.

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

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

the kind of exploitation that Plaintiff suffered.

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

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

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

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

just let them do what they want to do. And then the numbers all look good and investors will be

happy.”1 Defendant’s prioritization of growth over the safety of children has devastated the lives

of children who use its app.

4. Plaintiff is a 15-year-old boy who was an avid user of Defendant’s app. He relied

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

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

children.

5. Plaintiff was targeted on Roblox by a male predator who posed as a young girl the

same age as Plaintiff and exploited Plaintiff’s age and vulnerability to build a false emotional

connection with him by promising friendship and connection. After capturing his trust cultivated

on Roblox, the predator transitioned their interactions to text message, wherein the predator sent
Plaintiff graphic messages, sent him sexually explicit images of young girls, and ultimately

convinced Plaintiff to send him sexually explicit images of himself.

6. Plaintiff suffered this sexual exploitation and abuse as the direct result of

Defendant’s conduct. For years, Defendant has misrepresented and deliberately concealed

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

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

2
Defendant disclosed the truth of what was really occurring on its app, Plaintiff’s mother would

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

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

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

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

never have engaged with this predator and never been harmed.

7. Plaintiff has suffered unimaginable harm. His innocence has been snatched from

him forever. Tragically, what happened to him is far from an isolated event. Indeed, Plaintiff is

just one of countless children whose lives have been devastated as a result of Defendant’s gross

negligence and defectively designed app This action, therefore, is not just a battle to vindicate

Plaintiff’s rights—it is a stand against Defendant’s systemic failures to protect society’s most

vulnerable from unthinkable harm in pursuit of financial gain over child safety.

II. PARTIES

A. Plaintiff

8. Minor Plaintiff John Doe H.M., and his mother and next friend Jane Doe R.S., are

citizens and residents of the State of Missouri, with a principal place of residence in Clay County.

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

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

a loss of trust, safety, and personal security, depriving him of the opportunity for a normal and
healthy development. The injuries he sustained are severe, ongoing, and permanent, affecting her

daily life and emotional health in lasting and immeasurable ways.

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

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

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

assertion is legally erroneous, invalid, and unenforceable, including because Plaintiff disaffirms

any such contract, including any forced arbitration clause and any delegation clause in any

contract.

3
 B. Defendant

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

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

maintains, manages, develops, tests, labels, markets, advertises, promotes, supplies, and

distributes the Roblox app. Roblox is widely available to consumers throughout the United States.

III. JURISDICTION AND VENUE

12. This Court has personal jurisdiction over Defendant because it has contacts with

Missouri that are so continuous and systematic that they are essentially at home in this State.

Defendant regularly conducts and solicits business in Missouri, provides products and/or services

by or to persons here, and derive substantial revenue from the same. Defendant affirmatively and

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

notifications, recommendations, and other communications.

13. Venue is proper here because this Complaint seeks damages arising and resulting

from Defendant’s acts and omissions which occurred in Clay County, Missouri.

IV. FACTUAL ALLEGATIONS AS TO ROBLOX

A. Roblox Offers a Gaming App for Children.

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

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

experiences within the Roblox ecosystem. Most experiences on Roblox are created not by Roblox
but by individuals (often Roblox users) or companies that develop their own games and make them

available on Roblox for others to play.

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

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

16. Roblox is designed to be an interactive experience, allowing and encouraging users

to communicate with each other. Gameplay interactions, user hubs, direct messaging, and voice

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

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

4
which he also has described as “a new category of human coexperience.”2 Roblox has similarly

explained that it “operates a human co-experience platform . . . where users interact with each

other to explore and develop immersive, user-generated, 3D experiences.”3

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

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

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

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

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

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

Roblox webpage – “A New Era of Engaged Learning”

18. Roblox’s popularity among children exploded during the pandemic when the app

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-ceo-of-roblox-on-scaling-community-sourced-innovation.
3
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/ (archived Feb. 27, 2017).
5
Roblox, A New Era of Engaged Learning, https://corp.roblox.com/education (last visited Feb.
11, 2025).
6
Id.

5
was flooded with millions of new users as kids were confined to their homes and glued to their

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

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

19. That growth has continued unabated. In Roblox’s 2023 Annual Report, the

company reported an average of 68.5 million daily active users, with 21% under 9 years of age;

21% from 9-12 years of age; 16% from 13-16 years of age; and 41% over 17 years of age.

20. Today, Roblox is the most downloaded online game globally, and the average user

spends 139 minutes a day on the app.7

21. Individuals who wish to play Roblox must create an account. It is extremely easy

to “SIGN UP AND START HAVING FUN!” Users must provide only a birthdate, username, and

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

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

older than their actual age.

Roblox Sign-up Screen

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

6
 22. Although Roblox states that children must have parental permission before signing

up for an account, nothing prevents them from creating their own accounts and playing on Roblox.

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

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

signs up to use Roblox.

23. After creating an account, all users are assigned a default player avatar—a

cartoonish character that represents the individual user within certain games.

Example default avatar on Roblox.

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

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

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

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

recommends games to the user.

7
 Examples of games available on Roblox.
25. Until November 2024, Roblox configured its app to default to settings that allowed

adults to easily communicate with children. Adult strangers could “friend” and chat with a child

of any age via direct (i.e., private) message. Further, even without being “friends,” adults could

also chat with a child of any age within a Roblox experience through direct messages.

26. Now, under Roblox’s default settings, adults cannot directly message children

under 13, but Roblox still does nothing to prevent children this young from creating accounts with

fake 13+ birthdates, which gives them full access to Roblox’s direct-messaging options. Roblox

still relies on self-reported birthdates for age verification. Further, children 13 and over are still

vulnerable to receiving friend requests—or direct messages within Roblox experiences—from

adult strangers. There is also nothing that prohibits adults from entering fake birthdays and posing

as children in their attempts to friend or otherwise communicate with children users.

27. Roblox generates revenue largely by selling users an in-game digital currency

called Robux, which they exchange for digital content such as online experiences and customized

outfits and appearances for their avatars. Robux can be purchased in a single transaction or a user

may subscribe to receive Robux on a recurring basis with a Roblox Premium membership. Roblox

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

28. Children frequently become obsessed with purchasing or otherwise obtaining

Robux to buy items for their avatars and to spend in their favorite experiences on Roblox. In

Roblox’s Avatar Store, for example, the company sells rare items at astronomical prices, such as
a type of hair for an avatar, which children seek to purchase to keep up with or outdo their peers

on Roblox. As a result, children often tell others, including strangers, that they will do “Anything

for Robux.”8

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

Safety.

8
Olivia Carville & Cecilia D’Anastosio, Roblox’s Pedophile Problem, Bloomberg Businessweek
(July 23, 2024), https://www.bloomberg.com/features/2024-roblox-pedophile-problem/.

8
 29. Roblox’s success and continued growth have hinged on its constant, false

assurances to parents that its app is safe for children. The company has offered such assurances

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

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

30. Over the years, Roblox has repeatedly represented on its website that its app is safe

for children and has touted the safety controls it has in place. As early as 2007, Roblox’s website

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

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

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

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

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

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

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

permanently expelled” any offenders.11

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

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

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

protect the safety of our community while allowing players to imagine, create, and play together

in a family-friendly environment.”12 Roblox similarly has advertised its app as “a safe, moderated

9
Roblox, Frequently Asked Questions (FAQs),
https://web.archive.org/web/20071105104643/http://www.roblox.com/Parents/FAQs.aspx
(archived Nov. 5, 2007).
10
Roblox, Keeping Kids Safe,
https://web.archive.org/web/20080501101437/http://www.roblox.com/Parents/KeepingKidsSafe.
aspx (archived May 1, 2008); see also Roblox, Information for Parents,
https://web.archive.org/web/20160131063648/http://corp.roblox.com/parents (archived Jan. 31,
2016).
11
Id.
12
Roblox, Parents’ Guide,
https://web.archive.org/web/20170716032712/https://corp.roblox.com/parents/ (archived Jul. 16,
2017).

9
place to meet, play, chat, and collaborate on creative projects.”13

Excerpt from Roblox Parent’s Guide in 2017

33. Roblox’s website representations have remained largely unchanged since then. In

2023, for example, Roblox assured parents that it “continually develop[s] cutting-edge

technologies to ensure that the Roblox platform remains a safe and fun space for players all over

the world.”14 Roblox claimed that the company was “dedicated to working together with parents

and digital safety experts to promote a family-friendly environment that allows all players to
imagine, create, and play online.”15 Roblox emphasized that it is “committed to ensuring that

Roblox is a safe and fun place for everyone.”16 According to Roblox, it “goes above and beyond

to foster an environment where people of any age can create, play, learn, and imagine safely.

13
Id.
14
Roblox, For Parents,
https://web.archive.org/web/20230405060048/https://corporate.roblox.com/parents/ (archived
Apr. 5, 2023).
15
Id.
16
Roblox, Roblox FAQ,
https://web.archive.org/web/20230328011957/https://corporate.roblox.com/faq/ (archived Mar.
28, 2023).

10
We’ve kept children’s privacy and safety top-of-mind when designing our platform, especially

through the implementation of advanced text filters that block inappropriate language or other

unsafe content.”17

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

DNA: when Dave Baszucki and Erik Cassel launched Roblox in 2006, they spent a few hours each

day with the community, helping to ensure that Roblox was a safe and welcoming environment.

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

content and for communication on the platform.”18

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

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

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

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

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

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

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

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

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

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

concerns raised by parents.

17
Roblox, Roblox & User Data FAQ, https://en.help.roblox.com/hc/en-
us/articles/4406238486676-Roblox-User-Data-FAQ (last visited Feb. 11, 2025).
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).
19
Roblox, Safety Features: Chat, Privacy & Filtering, https://en.help.roblox.com/hc/en-
us/articles/203313120-Safety-Features-Chat-Privacy-
Filtering#:~:text=Players%20have%20different%20safety%20settings,and%20phrases%2%200t
han%20younger%20players (last visited Feb. 11, 2025).
20
Roblox, Safety & Civility at Roblox, https://en.help.roblox.com/hc/en-
us/articles/4407444339348-Safety-Civility-at-Roblox (last visited Feb. 11, 2025).
21
Id.

11
 37. In 2009, a blogger wrote about blocking Roblox because he doubted its safety for

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

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

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

38. In a 2013 Wired interview, when asked whether a parent should be concerned about

whom his child was chatting with in-game, Baszucki declared, “We take every precaution possible

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

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

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

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

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

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

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

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

most important priority and that will never change.”24

22
Eric Frenchman, Revisiting Roblox, Pardon My French (Oct. 5, 2009),
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),
https://www.wired.com/2013/02/roblox/.
24
Maressa Brown, Is Roblox Safe for Kids? Here’s What the Experts Have to Say, Parents
Magazine (Apr. 29, 2024), https://www.parents.com/kids/safety/internet/is-roblox-safe-forkids/.

12
 41. Such statements by Bhaumik date back years. In 2018, Bhaumik told the

Washington Post that Roblox “focus[es] on making sure that everything is done in a safe and

appropriate way.”25 That year, she also claimed to another newspaper that Roblox’s “safety team

reviews every uploaded image, video, and audio file used within our games to make sure they are

safe and age appropriate.”26 She also boasted that Roblox has “created extensive parental controls

for our games and a detailed Roblox Parent’s Guide that provides information to parents to help

create a Roblox experience that’s best for their child.”27

42. In 2019, while presenting on a “Digital Civility Panel,” Bhaumik emphasized that

“[w]e make sure there’s a safe environment,” citing Roblox’s “tremendous reporting system” and

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

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

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

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

25
Hayley Tsukayama, Roblox, an Online Kids Game, Explains How a Hack Allowed a
Character’s Virtual ‘Rape’, Wash. Post. (Jul. 17, 2018),
https://www.washingtonpost.com/technology/2018/07/17/roblox-an-online-kids-game-explains-
how-hack-allowed-characters-virtual-rape/.
26
Chris Pollard, Police Warn that Children as Young as Five-Years-Old are Seeing Naked Lego-
Type Characters Having Sex on Roblox App, The Sun (Jan. 29, 2018),
https://www.thesun.co.uk/news/5445444/roblox-app-children-danger-sex-warning/.
27
Id.
28
YouTube, Digital Civility Panel (Oct. 23, 2019),
https://www.youtube.com/watch?v=XoUs1Js7WG0&list=PLcKphP00N1_kCLjvcOWdwbegJkN
SL-CuL&index=6.
29
Id.

13
still very early days for us. This whole digital civility focus for Roblox is still there, we’re just still

establishing it.”30

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

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

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

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

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

these and other measures, she exclaimed, “[a]ny sort of bad actor that comes onto the platform is

dealt with swiftly” and “[w]e remove any content that’s reported to us within minutes.”33

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

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

narrative.

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

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

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

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

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

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

foundational to everything we do at Roblox.”36

30
Id.
31
Video Interview with Tami Bhaumik, Roblox’s VP of Digital Civility & Partnerships (2022),
https://www.facebook.com/bedford.sheriff/videos/roblox-how-to-help-kids-use-itsafelyrobloxs-
vp-of-digital-civility-partnerships/1338989609901259/.
32
YouTube, Into the Metaverse, Podcast: EP.21: Tami Bhaumik (Roblox) - Building a Safe &
Resilient Metaverse, https://www.youtube.com/watch?v=LT5_bBOYS9A.
33
Id.
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.
35
Id.
36
Matt Kaufman, Chief Safety Officer, Major Updates to Our Safety Systems and Parental

14
 46. In a later blog post, Kaufman touted Roblox’s “track record of putting the safety of

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

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

puts them at risk is one too many.”38

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

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

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

advocates raise questions and concerns, the company’s highest executives respond with

comforting promises of safety.

49. This campaign of reassurance masks the truth about Roblox. Far from creating a

safe place for children, Roblox designed, built, and maintains a toxic environment that has

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

and sexually exploit children. What Roblox represents as a safe, appropriate space for children is,

in fact, a digital and real-life nightmare for kids.

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

50. Roblox is a vast ecosystem offering an endless array of not just online games but

also immersive virtual worlds where children’s customized avatars can engage in activities like

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

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

scripting capabilities, 3D modeling systems, and other software supply the infrastructure needed

Controls, Roblox (Nov. 18, 2024), https://corp.roblox.com/newsroom/2024/11/major-updates-to-

our-safety-systems-and-parental-controls.
37
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.
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),
https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.

15
to create content for the Roblox platform. Roblox has the power to control the use of these tools.

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

the tools to build what they want, with no meaningful oversight or safeguards. The results are

deplorable.

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

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

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

where avatars engaged in simulated sexual activity.39

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

reports of children’s avatars being raped by other users’ avatars. For example, in 2018, a seven-

year-old girl’s avatar was violently raped by two male avatars on a playground in a Roblox

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

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

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

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

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

environments, including houses, where users can remove their avatars’ virtual clothing, revealing

nudity, and engage in disturbing simulated sexual activities with other Roblox users.42 They can

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

39
See, e.g., YouTube, How to Do Roblox Sex Glitch,
https://www.youtube.com/watch?v=Zz97Q1SQE_k; see also YouTube, Roblox Sex?,
https://www.youtube.com/watch?v=hyqCHG6nUYI.
40
Savannah Levins, North Carolina Mom Outraged After Roblox Game Depicts Violent Acts,
Including Rape, WFMYNews2 (June 30, 2018),
https://www.wfmynews2.com/article/news/local/2-wants-to-know/north-carolina-mom-outraged-
after-roblox-game-depicts-violent-acts-including-rape/83-569498171.
41
Id.
42
EJ Dickson, Inside the Underground Strip-Club Scene on Kid-Friendly Gaming Site Roblox,
Rolling Stone (Sep. 12, 2021), https://www.rollingstone.com/culture/culture-features/roblox-
virtual-strip-clubs-condo-games-sex-1197237/.

16
as nine years old and enables users to simulate sexual activity in virtual bathrooms,43 as well as

virtual strip clubs, where child avatars perform sexually explicit acts, like giving lap dances to

patrons.44

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

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

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

“Survive Diddy,” “Run from Diddy Simulator,” and “Diddy Party,” which appear to recreate
reported incidents involving the music mogul Sean Combs, publicly known as “Diddy.” Diddy
was recently indicted and is on trial for sex trafficking of minors and other grievous criminal

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

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

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

43
Hindenburg, supra note 1.
44
Dickson, supra note 42.
45
Hindenburg Research, supra note 1.

17
 Examples of Roblox games modeled after Diddy’s sex trafficking ventures.46
56. This report also revealed that Roblox permitted more than 900 Roblox accounts
displaying variations of convicted sex trafficker Jeffrey Epstein’s name, such as
“JeffEpsteinSupporter,” whose account Roblox actively permitted to be openly engaged in
children’s games. Roblox also allowed games like “Escape to Epstein Island”—a title that
directly references one of the locations where for years Epstein trafficked minors and other non-
consenting individuals so he and others could sexually and physically abuse them.

46
Id.

18
 Example of Roblox game modeled after Jeffrey Epstein’s sex trafficking

ventures.47

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

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

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

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

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

avatars (i.e., allowing avatars to wear multiple layers of clothing), whether players could be
nude.48 By allowing this type of content to exist and be easily accessible, Roblox directly

contributed to the proliferation of games simulating sexual activity, such as condo games and

virtual strip clubs.

58. The effects of these games on children can be devastating. Playing video games

with explicit sexual content normalizes exploitative and predatory behavior, blurring the lines of

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

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

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

sexual exploitation is harmless or even acceptable.

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

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

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

47
Id.
48
Joseph Cox & Emanuel Malberg, Leaked Documents Reveal How Roblox Handles Grooming
and Mass Shooting Simulators, Vice (Aug. 1, 2022), https://www.vice.com/en/article/leaked-
documents-how-roblox-moderates-content-mass-shootings-grooming/.
49
Jonathan Burnay, Brad J. Bushman & Frank Larøi, Effects of Sexualized Video Games on
Online Sexual Harassment, 45 Aggressive Behavior 2, 214 (March/April 2019).

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

sexualized or exploitative content.50

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

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

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

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

these actions in real-world interactions.

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

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

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

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

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

implement any age restrictions on these criminal groups, deliberately leaving them accessible to

all users.53

50
Jay G. Hull et al., A Longitudinal Study of Risk-Glorifying Video Games and Behavior
Deviance, J. Pers. Soc. Psychol. 2014 August; 107(2): 300–325. doi:10.1037/a0036058.
51
Hindenburg Research, supra note 1.
52
Id.
53
Id.

20
 Public chat wall for a group named “Adult Studios,” where users openly solicited
child pornography.54
62. Roblox has also enabled individuals to create an entire category of pornographic

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

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

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

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

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

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

54
Id.

21
22
 This Roblox user advertised their Roblox account on porn website, XVideos, where
they had uploaded videos of their avatar having sex with other Roblox users.55

55
Id.

23
 Searching “Roblox” on XVideos, a porn website, yields more than 250,000 results.56

The comment section on a Roblox porn video on XVideos – Brookhaven is one of

Roblox’s most popular games and is available to users of all ages.57

63. In sum, the online environment that Roblox hosts and enables contradicts its

representations of providing a safe product, demonstrating Roblox’s blatant disregard for the

safety of its youngest users and revealing the company’s prioritization of user engagement over

its fundamental duty to protect young users.

2. Roblox provides a hunting ground for child-sex predators.

64. For years, Roblox has served as the online platform of choice for predators seeking
to find, groom, abuse, and exploit children. Roblox provides predators with easy access to tens of

millions of children and allows these predators to freely move between inappropriate content and

popular games to identify and target vulnerable young users. By doing so, Roblox has

56
Id.
57
Id.

24
demonstrated reckless indifference to its fundamental obligation not to create and foster an

environment that places children at significant risk of sexual exploitation.

65. These systematic patterns of exploitation on Roblox follow a predictable and

preventable sequence that the company has known about and facilitated for years: a predator

misrepresents their age to other users on the app, cosplaying as a fellow child, methodically

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

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

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

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

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

developing relationships with them that moved to other online platforms and, eventually,

offline.”58

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

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

predators.”59 The children, due to their underdeveloped brains, are more trusting and naïve, and

often fail to recognize the danger of providing their usernames on other sites.

68. Once on another app, like Discord or Snapchat, predators escalate their

exploitation by soliciting explicit material, like nude photos or videos of children doing sexually

inappropriate acts, all of which constitute child pornography. And while the ultimate solicitation
of explicit photos or other criminal acts may occur on other apps, Roblox serves as the critical

facilitator that enables these predators to first identify, target, and gain the trust of young victims

through its app’s design and inadequate safety measures.

69. Roblox’s app and profit-driven virtual currency system enable predators to exploit

children, often by trading or extorting Robux in exchange for explicit photos. Predators

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

25
commonly offer children Robux for these photos or demand Robux to avoid publicly releasing

them, directly tying Roblox’s profits to the sexual exploitation of children. Roblox’s manipulative

reward systems and social dynamics, intentionally designed to exploit children’s developmental

vulnerabilities, create psychological pressures that predators weaponize for extortion.

70. Despite full awareness of how its app facilitates such exploitation, Roblox

continues to profit from these tactics by collecting transaction fees on Robux exchanges. Its

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

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

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

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

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

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

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

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

photos, coercing young victims into complying with criminal demands.

72. Regardless of how the initial grooming relationship begins, which is often as

simple as someone asking the child to be their boyfriend or girlfriend, the predators also often

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

online app to real-world violence reveals the devastating consequences of the company’s product.
Roblox’s app enables predators to escalate from virtual contact to orchestrating physical

meetings, leading to harassment, kidnapping, trafficking, violence, and sexual assault of minors,

all instances of which these children suffered as a direct result of Roblox’s actions.

73. Through numerous well-documented and publicized cases, Roblox has long been

aware of the systemic exploitation that its app enables and facilitates. For years, countless children

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

26
 74. For example, in 2017, Roblox’s app enabled a predator to target an eight-year-old

child and solicit explicit photos, prompting one mother to observe that Roblox had created “the

perfect place for pedophiles.”60

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

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

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

also charged with soliciting sex from minors as part of a sting operation, where the New Jersey

State Police Lieutenant specifically called out Roblox as a place where “individuals are posing as

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

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

12, moving them to Discord to coerce the children into sending him naked pictures of

themselves.63 That year, a man in Wales encouraged 150 children to engage in sexual activity by

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

77. During the pandemic, reports of child sex abuse facilitated by Roblox accelerated.

In 2020, for example, Roblox enabled a 47-year-old predator to pose as a teenager, target a 16-

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

60
Pei-Sze Cheng, Evan Stulberger & Dave Manney, I-Team: Popular Online Gaming Site for
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-site-investigation-what-to-know/87438/.
61
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-how/12899346007/.
62
Cop, Firefighter Among 25 Charged in Child Luring Sting, FOX 13 TAMPA BAY (Sep. 25,
2018), 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
Children, TC Palm (Aug. 20, 2019), https://www.tcpalm.com/story/news/crime/indian-river-
county/2019/08/20/detectives-advise-online-safety-after-vero-beach-man-used-video-game-
platforms-target-minors/2059599001/.
64
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-
news/paedophile-groomed-150-children-engage-16258877.

27
constituted child pornography,65 and ultimately traffic her across state lines, raping her multiple

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

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

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

perpetrator was not the only convicted sex offender who was able to freely create accounts on

Roblox: in 2021, a convicted sex offender used Roblox to sexually solicit a 12-year-old child.68

And in 2022, a 33-year-old man groomed a 13-year-old girl on Roblox, transported her from her

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

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

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

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

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

known history of exploiting children via Roblox, was sentenced to 15 years in prison for grooming

a 15-year-old girl, transporting her to his house, and sexually abusing her.72

65
U.S. Dep’t of Justice, Magnolia Man Gets Life For Exploiting Young Female He Met and
Communicated With Via Roblox and Facebook (Oct. 15, 2020), https://www.justice.gov/usao-
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).
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-
inappropriate-relationship-with-8-year-old-bloomfield-twp-girl-through-roblox.
68
Jeff Bonty, Man Charged With Soliciting Juvenile Through Roblox, Daily Journal (Jul. 23,
2021), https://www.shawlocal.com/daily-journal/.
69
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),
https://www.fox5atlanta.com/news/clayton-county-man-charged-with-sex-trafficking-rape-of-
kansas-girl.
70
City of Fontana Police Department, Internet Predator Arrested, Facebook (Dec. 20, 2023),
https://www.facebook.com/watch/?v=338311109095057.
71
Man Charged in Kidnapping of 11-year-old He Met Through Roblox from Her NJ Home:
Police, ABC7 (Oct. 21, 2023), https://abc7ny.com/roblox-kidnapping-new-jersey-online-
grooming/13927383/.
72
U.S. Dep’t of Justice, New Jersey Man Sentenced to 15 Years in Federal Prison After

28
 79. Similar incidents continued throughout 2024. For example, a 21-year-old Chilean

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

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

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

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

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

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

teenager and then coerced the girl into sending multiple explicit photos of herself.76 And a 24-

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

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

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

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

in unlawful sexual conduct with 10-year-old girl whom he met and communicated with on

Grooming Minor Online and Transporting Her Across State Lines Via Uber for Sex (Aug. 30,
2023), https://www.justice.gov/usao-sdin/pr/new-jersey-man-sentenced-15-years-federal-prison-
after-grooming-minor-online-and.
73
Grace Toohey, Chilean Man Groomed 13-Year-Old Girl He Met on Roblox Before Flying to
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.
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-
year-old-on-roblox-pleads-guilty-in-butte-county.
75
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-
catfishing-girl-on-roblox-convincing-her-to-send-explicit-images/.
76
Michael Martin, Roblox Predator: School Staffer Accused of Grooming West Michigan Child
for Illicit Photos, Fox17 West Michigan (Jan. 16, 2025),
https://www.fox17online.com/news/local-news/roblox-predator-school-staffer-accused-of-
grooming-west-michigan-child-for-illicit-photos.
77
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), https://www.dailymail.co.uk/news/article-14278563/Roblox-predator-raped-10-year-old-
girl.html.

29
Roblox.78 The next month, a 17-year-old Florida teenager was arrested after authorities learned

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

old, over the course of a year, and convinced them to send him sexually explicit images of

themselves.79 And just a few days later, a New York man who used Roblox to connect with 11-

and 13-year-old girls was arrested and federally charged with enticement and possession of child

pornography.80

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

also be children, many predators do not even hide their intentions, roaming Roblox with

usernames like “@Igruum_minors,” “@RavpeTinyK1dsJE,” and “@EarlBrianBradley”—a

reference to one of the most prolific pedophiles ever, who raped and molested hundreds of

children.

78
Elk Grove Man Accused of Kidnapping Kern County Girl He Communicated with on Roblox,
CBS News (Apr. 18, 2025), https://www.cbsnews.com/sacramento/news/elk-grove-man-
accused-kidnapping-kern-county-girl-roblox/.
79
Briana Trujillo, Ocala 17-Year-Old Convinced Kids to Send Him Sex Abuse Material on
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/.
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-roblox-attempt-communicate-minors-sex-arrested.

30
 Results from an account search for “earlbrianbradley.”81

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

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

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

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

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

are met, Roblox remains too high risk for kids.”83

83. Parent reviews of Roblox on sites like Common Sense Media also document

disturbing incidents of naked avatars, sexting, simulated sexual assault, and adult predators.84
84. The harm from this child abuse and exploitation extends beyond the initial victims.

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

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

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

perpetrators. Indeed, researchers have repeatedly confirmed this victim-victimizer pipeline: when

children are exposed to and victimized by sexual content, they are more likely to become

desensitized teenagers and adults who then exploit younger users in the same ways.85 In effect,

Roblox contributes to this “raising of” predators who perpetuate the cycle of exploitation.

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

81
Hindenburg Research, supra note 1.
82
National Center on Sexual Exploitation, supra note 59.
83
Id.
84
Common Sense Media, Parent Reviews of Roblox,
https://www.commonsensemedia.org/website-reviews/roblox/user-reviews/adult (last visited
Feb. 11, 2025).
85
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
& 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
Becoming a Perpetrator, British J. Psychiatry (2001).

31
public statements. Roblox’s Chief Safety Officer, Matt Kaufman, attempting to deflect attention

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

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

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

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

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

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

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

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

protect children.

D. Roblox Knowingly Causes and Facilitates the Sexual Exploitation of

Children.

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

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

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

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

1. Roblox prioritizes growth over child safety.

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

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

positioning itself as a place where kids can learn and play games in a safe environment.

86
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),
https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.
87
Id.
88
Roblox Corp., S-1 (Securities Registration Statement) 24 (Nov. 19, 2020).

32
Recognizing that children have more free time, underdeveloped cognitive functioning, and

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

92. Roblox’s business model allowed the company to attract significant venture

capital funding from big-name investors like Kleiner Perkins and Andreessen Horowitz, putting

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

Roblox made deliberate decisions that placed children at risk. For example, while other digital

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

communications between children and adults, Roblox did not require age verification and did not

restrict communications between children and adults. Similarly, while other digital platforms

required children’s accounts to be connected to the account of a parent or guardian during set-up,

with various parental controls turned on by default, it is easy for children (including very young

children) to download and install Roblox without involving an adult. While other platforms

implemented reliable, accurate age ratings for games and videos that correctly informed parents

about the type of content their children would see, Roblox’s deeply flawed “content label” system

gave parents a false sense of security, incorrectly labeling graphic sexual and violent games as

safe for kids. And while other platforms restricted access if a child fell below a certain age, Roblox

welcomed and encouraged children of any age, despite its knowledge of significant harms that

children routinely experience there.

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

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

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

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

33
the app—on the theory that profitability would follow once the business achieved sufficient scale

and operating costs decreased as a percentage of revenue.89

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

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

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

Employees also reported feeling explicit pressure to avoid any changes that could reduce platform

engagement, even when those changes would protect children from predators.91

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

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

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

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

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

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

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

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

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

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

89
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
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,
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 expect the rates of growth in 2021 will be well below the rates in 2020, however, we believe
we will see absolute growth in most of our core metrics for the full year.” Id.
90
Hindenburg Research, supra note 1.
91
Id.
92
Id.
93
Id.

34
younger demographic . . . becom[ing] a drag on [earnings] margins.”94 Barclays also wrote that it

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

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

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

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

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

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

98. For example, on Roblox’s 2023 fourth quarter earnings call, an analyst praised the

“really high level of efficiency” seen in the numbers for infrastructure and trust and safety

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

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

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

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

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

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

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

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

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

94
Ross Sandler, Trevor Young & Alex Hughes, Back on Track Following the 1H Hiccup,
Barclays (Aug. 1, 2024)
95
Ross Sandler, Trevor Young & Alex Hughes, Everything Accelerating, Safety & Security a
Top Priority, Barclays (Nov. 1, 2024)
96
Q4 2023 Earnings Call (Feb. 7, 2024).
97
Id. (emphasis added).
98
Id.
99
Q4 2022 Earnings Call (Feb. 15, 2023)
100
Q3 2022 Earnings Cal (Nov. 8, 2023).

35
 100. Similarly, in the second quarter of 2024, CEO Baszucki highlighted that,

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

year.”101

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

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

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

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

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

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

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

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

contrast, older users, who “have more direct control over their spend” and “monetize better,” are

far more lucrative—an outcome that Roblox said it predicted when it started to target older

users.104

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

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

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

of nine to twelve year-olds,” and was focused on adding users over the age of 13.105 One plan was

to “improve the search algorithms such that older users were finding older content,” or content
tailored to their age-related demographic.106

101
Q2 2024 Earnings Call (Aug. 1, 2024).
102
Roblox, What Is Roblox,
http://web.archive.org/web/20170227121323/https://www.roblox.com/ (archived Feb. 27, 2017).
103
Roblox Corp., S-1 (Securities Registration Statement) 7 (Nov. 19, 2020).
104
Q2 2022 Earnings Call (Aug. 10, 2022).
105
Roblox at Goldman Sachs Communicopia Conference (Sep. 9, 2021),
https://ir.roblox.com/events-and-presentations/events/event-details/2021/Goldman-Sachs-
Communicopia/default.aspx.
106
Id.

36
 104. And at its annual Developer Conference, CEO David Baszucki encouraged

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

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

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

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

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

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

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

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

up. We are a platform for all ages.”108 He also revealed that developers had started to “build

specific 17-plus experiences.”109 This progress was praised by Wall Street investment banks, who

noted that aged-up experiences were a promising indicator of “potential sustainable growth

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

106. Despite Roblox’s deliberate targeting of older users, it failed to implement any

meaningful restrictions on contact between adult and child users or limit the mature content and

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

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

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

the top thousand experiences having a majority of 13-plus [users] but those are still experiences
that are open to all ages.”111 Similarly, despite urging developers to build more mature

experiences, Roblox continued to allow users to set up accounts without any type of age

107
Roblox Developers Conference 2023 Keynote (Sep. 8, 2023),
https://www.youtube.com/watch?v=CwLThCghzA4.
108
Q2 2023 Earnings Call (Aug. 9, 2023).
109
Q2 2023 Earnings Call (Aug. 9, 2023).
110
Benjamin Black et al., Bookings Back on Track, Deutsche Bank (Nov. 4, 2024).
111
Q3 2021 Earnings Call (Nov. 9, 2021) (emphasis added).

37
verification.112 Even investors recognized the connection between older users and the increased

risks for children, questioning how Roblox planned to prevent inappropriate content from

reaching younger users.113

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

strategy posed to children, but it also sought to encourage relationships between users. At

Roblox’s 2023 Developers Conference, CEO Baszucki revealed Roblox’s strategy to facilitate

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

“dating,” he then announced plans to build a product to support it: “I’m not going to use the D

word but subsequent[] real-life relationships is going to happen, okay? And we’re going to build

a platform to support that.”114

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

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

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

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

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

longstanding issue for the company—in pursuit of growth and profit. This systematic

subordination of child safety to business objectives reflects Roblox’s continued choice to

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

2. Roblox facilitates child sexual exploitation through the design of its app,
inadequate safety features, and refusal to invest in basic safety

protections.

112
Q4 2022 Earnings Call (Feb. 15, 2023).
113
Q3 2021 Earnings Call, supra note 111.
114
Roblox Developers Conference 2023 Keynote (Sep. 8, 2023),
https://www.youtube.com/watch?v=CwLThCghzA4.
115
Roblox Developers Conference 2024 Keynote (Sep. 6, 2024);
https://www.youtube.com/watch?v=HwbcWc2CwnM.

38
 110. Roblox’s pursuit of growth and profit over child safety is reflected in numerous

actions it took and decisions it made related to the design and safety of its app. Had Roblox acted

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

111. Roblox designed its app so that anyone can easily communicate with children,

creating a virtual world where predators can freely target and groom children. Until November

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

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

Roblox offered some adjustable parental controls for users under the age of 13, these children

could bypass those controls simply by creating an alternate account falsely identifying as a 13+-

year-old user. By designing its app this way, Roblox stripped parents of basic protective options

to prevent adult strangers from communicating with their children.

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

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

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

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

information or send any coercive or sexually suggestive messages.

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

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

their avatars in real time. Concerns were immediately raised about this feature. For example, one
user emphasized, “This is a bad idea Roblox, and especially on your platform because this is

where most predators are coming from, and it makes it way easier for predators to prey on

children.” 117

116
Carville & D’Anastosio, supra note 8.
117
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-call-feature-2384564/.

39
 114. As Roblox contemplated and rolled out Roblox Connect, it knew that this feature

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

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

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

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

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

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

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

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

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

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

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

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

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

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

verification, Roblox instead chose to allow users to create accounts without providing their name

or email address—a policy that enables predators to easily create multiple anonymous accounts.

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

which would have ensured that known predators are not permitted on the app.
116. Roblox also could have required children to provide their names and email

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

to do so. This decision allowed the company to bypass certain protections that are mandated by

federal law and designed to protect children. The Children’s Online Privacy Protection Act

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

118
Omegle, https://www.omegle.com/ (last visited Feb. 11, 2025).
119
Id.

40
information of children under 13 without verifiable parental consent. COPPA was enacted because

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

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

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

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

Regulation (GDPR) requires verifiable parental consent for children under 16.121

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

parental consent. These include: (a) providing a form for parents to sign and return; (b) requiring

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

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

parental verification; (e) asking knowledge-based questions to confirm identity; or (f) verifying a

parent’s photo-ID by comparing it to a second photo using facial recognition technology.122

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

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

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

employees revealed that Roblox considered requiring verifiable consent, but ultimately resisted

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

120
Federal Trade Commission, Privacy Online: A Report to Congress (1998),
https://www.ftc.gov/sites/default/files/documents/reports/privacy-online-report-congress/priv-
23a.pdf.
121
Art. 8 GDPR; see also Consent to Use Data on Children, EU Agency for Fundamental Rights
(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 or 15 if they choose.
122
Federal Trade Commission, Complying with COPPA: Frequently Asked Questions, July 2020,
https://www.ftc.gov/business-guidance/resources/complying-coppa-frequently-asked-questions.
123
Hindenburg Research, supra note 1.

41
creating a Roblox account is alarmingly easy, requiring less than sixty seconds and no meaningful

oversight—a choice that prioritizes growth over the safety of its youngest users.124

119. Another easy-to-implement feature that would have improved safety is adding

pop-up safety notices within chats and games to warn users about their behavior or the dangerous

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

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

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

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

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

Access Control or MAC addresses) that could prevent predators from creating multiple

accounts.126

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

which would create significant barriers to predators creating multiple accounts—despite knowing

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

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

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

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

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

father told the press after seeing other users solicit his avatar for sex, “There is nothing to stop
adults going on there and pretending they’re kids.”128

124
Scott Tong & James Perkins Mastromarino, Roblox Attempts to Bar Child Predators as Short
Sellers Target the Popular Game Platform, WBUR (Oct. 21, 2024),
https://www.wbur.org/hereandnow/2024/10/21/roblox-child-predators-safety.
125
Carville & D’Anastosio, supra note 8.
126
Id.
128
Carl Stroud, Horrified Dad Found Sick Messages from Paedo Predator in His Eight-Year Old
Son’s Roblox iPad Game, The Sun (Feb. 15, 2017),
https://www.thesun.co.uk/news/2872376/horrified-dad-found-sick-messages-from-paedo-
predator-in-his-eight-year-old-sons-roblox-ipad-game/.

42
 123. Roblox could easily have restricted communications between adult accounts and

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

adult accounts from sending Robux to children’s accounts, a feature that sexual predators

frequently use to lure children.

124. Roblox likewise could have created a separate, gated platform for younger

children that excludes adults. If supported by age verification using facial recognition (a service

that is widely commercially available), the company could create a space for young children to

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

adopted separate platforms for children of young ages, including, for example, Amazon and

Netflix.

125. Roblox could have placed a higher age rating on its application in the iOS App

Store and other app stores, to signal to parents that the app presented risks for children. Roblox

also could have provided clear warnings to parents about the presence of sexual predators on the

platform, so that parents could make an informed decision about allowing their child on the

platform and/or educate their child on how to stay safe on the platform. Roblox could also have

provided clear warnings to children about the presence of sexual predators on the platform, and

instructed children on how to stay safe on the platform.

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

an “industry leader” when it comes to child safety.129 Central to this self-serving narrative is its
“accomplishments” of investing in artificial intelligence (“AI”) and machine learning systems

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

of inappropriate content and personally identifiable information.130

129
Q1 2021 Earnings Call (May 11, 2021).
130
Roblox, Safety Features: Chat, Privacy & Filtering,
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).

43
 127. Yet this technology has proven grossly inadequate and insufficient to protect

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

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

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

is blocked, users can bypass this filter by using the disc emoji (💿) or typing variations, like
“iscord” or “cord.”131 That Roblox selectively blocks the words “Snap,” “Snapchat,” and

“Discord” reveals that Roblox is fully aware of the dangers of off-app inappropriate

communications yet chooses not to close these loopholes. And while Roblox prevents users from

sharing phone numbers in numerical format, it does nothing to stop users from spelling out the

numbers.132

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

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

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

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

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

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

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

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

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

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

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

131
Edwin Dorsey, Problems at Roblox (RBLX) #5, The Bear Cave (Oct. 17, 2024),
https://thebearcave.substack.com/p/problems-at-roblox-rblx-5.
132
Id.
133
Burt Helm, Sex, Lies and Video Games: Inside Roblox’s War on Porn, Fast Company (Aug.
19, 2020), https://www.fastcompany.com/90539906/sex-lies-and-video-games-inside-roblox-
war-on-porn.

44
despite having only three times the number of users, employs more than ten times the number of

moderators at 40,000.134 Roblox attempts to justify this disparity by claiming “[y]ou really can’t

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

different story. Roblox’s moderators, many of them overseas contractors, report being

overwhelmed by an unmanageable volume of child safety reports, making it impossible to address

all concerns effectively and leaving countless safety issues unresolved.136

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

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

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

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

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

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

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

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

have surged over the years, from 675 reports in 2019 to 13,316 reports in 2023.138

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

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

134
Carville & D’Anastosio, supra note 8.
135
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),
https://www.wbur.org/hereandnow/2024/11/18/roblox-safety-features.
136
Carville & D’Anastosio, supra note 8.
137
Scott Tong & James Perkins Mastromarino, Roblox Attempts to Bar Child Predators as Short
Sellers Target the Popular Game Platform, WBUR (Oct. 21, 2024),
https://www.wbur.org/hereandnow/2024/10/21/roblox-child-predators-safety.
138
National Center for Missing & Exploited Children, 2019 CyberTipline Reports by Electronic
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 Reports by Electronic Services Providers (ESP),
https://www.missingkids.org/content/dam/missingkids/pdfs/2023-reports-by-esp.pdf.

45
violative content.139 These lower percentages are thus a reflection not of safety but of Roblox’s

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

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

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

while the company continues to reap financial rewards.

132. The very existence of Roblox’s trust and safety “data” on inappropriate

communications to train its AI systems contradicts its claim that “one is too many” when it comes

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

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

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

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

secure environment where such harm never occurs and ensuring that such interactions never

happen in the first place, Roblox uses the suffering and trauma of children as the foundation for

its trust and safety systems. This cycle underscores the company’s prioritization of optics over

genuine protection, leaving its youngest users at the mercy of its neglect.

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

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

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

these posts highlight the platform’s systemic failures and suggest straightforward changes Roblox
could implement to create a safer environment but has consistently ignored—for example:

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

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

139
Vikki Blake, Roblox Reported Over 13,000 Incidents to the National Center for Missing and
Exploited Children in 2023, GamesIndustry.biz (Jul. 23, 2024),
https://www.gamesindustry.biz/roblox-reported-over-13000-incidents-to-the-national-center-for-
missing-and-exploited-children-in-2023.
140
Edwin Dorsey, Problems at Roblox (RBLX) #5, The Bear Cave (Oct. 17, 2024),
https://thebearcave.substack.com/p/problems-at-roblox-rblx-5.

46
 the creep: kid ratio was much much lower . . . . Roblox has no interest in actually

fixing the issues so long as the bad press doesn’t end up viral.”141

b. “No. Roblox is not safe for children. The amount of NSFW [Not Safe for Work] I

see on this platform on a daily basis is unbelievable. I’m surprised COPPA hasn’t

taken any action.”142

c. “I believe they need to automatically rate these games for older audiences, if not,

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

just beating a dead horse at this point.”143

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

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

summary, 100 million+. I don’t want to know how many of these children have

seen nudity or even developed a p*rn addiction. But that is a big problem with

Roblox doing almost nothing to prevent it.”144

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

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

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

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

years of neglect and harm caused by its app.

135. After years of mounting pressure, Roblox recently announced changes to its child
safety features. These changes were prompted not by the years of police reports and widespread

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

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

141
Id.
142
Id.
143
Id.
144
Id.
145
Hindenburg Research, supra note 1.

47
sparked public outrage, detailing many of the issues described above that Roblox had long

ignored.

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

permanently removing the ability to message others outside of games on its app for under 13-

year-old users;146 giving parents a separate dashboard where they can monitor a child’s Roblox

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

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

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

new Roblox games that are awaiting maturity ratings.149

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

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

threatened.

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

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

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

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

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

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

139. Roblox also failed to address core issues like the app’s lack of age verification and
refusal to require parental consent to make an account. The restrictions described above work

146
Roblox Tightens Messaging Rules for Under-13 Users Amid Abuse Concerns, Reuters (Nov.
18, 2024), https://www.reuters.com/technology/roblox-tightens-messaging-rules-under-13-users-
amid-abuse-concerns-2024-11-18/.
147
Robert Booth, Roblox to Give Parents More Control Over Children’s Activity After Warnings
Over Grooming, The Guardian, (Nov. 18, 2024),
https://www.theguardian.com/technology/2024/nov/18/roblox-to-hand-parents-more-control-
over-their-childrens-activity.
148
Id.
149
Id.

48
only if children correctly state their age during sign-up. Any child can easily bypass them—

including parental controls and limits on messaging—by lying about their birthday. Roblox

likewise did not commit to hiring more moderators or increasing its trust and safety budget, nor

did it implement any sort of identity check to prevent registered sex offenders from making

accounts.

140. In fact, recently, in April 2025, a research firm in the U.K. demonstrated just how

easy it still is for predators to find children and move the conversation to another application, such

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

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

public chat functions in games to groom child users and ask for their usernames on other

platforms. And, for chat within games, Roblox’s default settings for children under the age of 13

is to allow “everyone” to chat with these children, seamlessly facilitating predators’ access to

children.151 The key findings from this report included that “[a]dults and children can chat with

no obvious supervision” and that “[t]he safety controls that exist are limited in their effectiveness

and there are still significant risks for children on the platform.”152

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

49
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

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

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

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

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

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

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

older, such limitations are hollow without robust age verification. And the fact that Roblox has
stated that it is exploring making such a feature available to younger users demonstrates that, far

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

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

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

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

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

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

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

chair—an obvious conflict of interest.157 This calculated relationship exposes how Roblox
manipulates public perception by using seemingly independent safety organizations as

mouthpieces to shape the narrative in its favor.

153
Id.
154
Rebecca Ruiz, Roblox’s New Party Feature Makes Discord Obsolete, Mashable (Dec. 2,
2024), https://mashable.com/article/roblox-party-discord.
155
Id.
156
Anna Halkidis, What Roblox’s Latest Changes Mean for Your Kids’ Online Safety, Parents
(Nov. 18, 2024), https://www.parents.com/roblox-new-parental-controls-8747405.
157
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.

50
 Stephen Balkam’s LinkedIn post revealing his connection to Roblox in a post
praising Roblox’s changes.158

143. Most recently, in April 2025, Roblox repeated this same deceptive playbook of

bragging about new safety features that, in reality, are glaringly deficient. This update included

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

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

visibility into the games that their child spends the most time in.159
144. None of these parental controls address the underlying deficiency with Roblox that

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

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

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, 2025).
159
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-
roblox.

51
lack the information necessary to determine which accounts to block on their child’s friend list.

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

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

above, inappropriate games are re-posted as soon as they are taken down. Indeed, barely a week

later, the U.K. research firm discussed above demonstrated just how easy it is for adults to

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

Roblox announced these safety updates.160

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

are facilitated by previously unavailable technology.

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

relations campaign, where industry-funded safety “experts” praise Roblox’s safety update. For

example, Roblox’s press release announcing these updates quotes Larry Magid, the CEO of

ConnectSafely, as saying, “Roblox has consistently provided parents with tools that enable their

children to enjoy the platform, while helping protect them against online risks. These new friend-

and experience-blocking tools provide parents with even more ways to help ensure their children

are using it safely. Safety, fun, and adventure are not mutually exclusive.”161 What the press

release did not say is that ConnectSafely—a non-profit ostensibly focused on educating people

about internet safety—is funded by tech companies and lists Roblox as one of its “supporters.”162

160
A Digital Playground: The Real Guide to Roblox.
161
Matt Kaufman, New Tools for Parents to Personalize Their Child’s Experience on Roblox.
162
ConnectSafely, Supporters, https://connectsafely.org/about-us/supporters/ (last accessed May
10, 2025).

52
 ConnectSafely’s list of supporters on its website.

147. A few weeks later, Magid was quoted again in praise of Roblox, this time in a

Newsweek article championing Roblox as a “trusted playground” for kids: “I would put them very

high up on the list of companies that seem to care. They actually have a vice president of civility.

It’s unheard of to have somebody at that level of the company that focuses on civility. They really

work very hard to make it a friendly, comfortable, civil environment for young people.”163 Again,

this article made no mention of Magid’s organization’s financial ties to Roblox.

148. FOSI CEO Stephen Balkam was also quoted in the Newsweek piece, claiming that

Roblox was “top-of-class” for its safety features and even repeating Roblox’s own party line that

safety is “part of [Roblox’s] DNA.”164 Again, this article omitted FOSI’s ties to Roblox, financial

and otherwise, thereby deceptively pushing a narrative of Roblox as a “safe” application for kids.

V. PLAINTIFF-SPECIFIC ALLEGATIONS

149. Plaintiff was approximately 13 years old when he first started playing on Roblox.

Plaintiff’s mother believed that Roblox was safe for children because it was designed and

marketed for kids. As discussed above, Roblox spent considerable time and money publicly

touting the safety and security of the app, which created the public perception that Roblox had

163
Katherine Fung, How Roblox Became a Trusted Playground for Millions of Kids, Newsweek
(Apr. 23, 2025), https://www.newsweek.com/how-roblox-became-trusted-playground-millions-
kids-2057601.
164
Id.

53
created a safe environment for kids. Unbeknownst to Plaintiff’s mother at the time, this was

nothing more than a false façade of safety.

150. In 2023, when Plaintiff was 13 years old, he was identified and targeted through

Defendant’s dangerous app by a man who presented himself as a peer, falsely claiming to be a

young girl of Plaintiff’s age. Unbeknownst to Plaintiff at the time, the man was in fact an adult

predator.

151. Because of Roblox’s defectively designed features and inadequate safety

measures, the predator was able to target and message Plaintiff. He employed well-documented

grooming tactics—techniques that Roblox has long recognized as common predatory behavior on

its platform yet failed to prevent—to communicate with Plaintiff through Roblox’s direct

messaging feature. On Roblox, the predator groomed and manipulated Plaintiff, exploiting his

age and vulnerability to build a false emotional connection with him—under the false pretense

that he was Plaintiff’s peer.

152. Leveraging the trust cultivated on Roblox, the predator manipulated Plaintiff into

exchanging phone numbers and continuing their interactions through text messages. He sent

Plaintiff graphic messages and sent him sexually explicit images of a young girl. Exploiting the

trust and relationship he had been allowed to build through Defendant’s defective app, the

predator ultimately convinced Plaintiff to send him sexually explicit images of himself. The

predator encouraged secretive behavior, minimized the risks to Plaintiff, and ensured that Plaintiff
would not reveal any of their interactions to his parents.

153. Plaintiff has suffered, and continues to suffer, profound harm from the grooming,

manipulation, and exploitation that he experienced on Defendant’s app. He continues to suffer

life-altering psychological and emotional injuries, including severe mental anguish and pain, and

loss of enjoyment of life. Plaintiff has endured, and continues to endure, humiliation, shame,

persistent anxiety, intrusive sexual ideation, and a profound loss of trust, safety, and innocenc.

154. Defendant is directly responsible for the immense harm that Plaintiff has suffered.

Had Plaintiff’s mother known the truth about Defendant’s app, she never would have permitted

54
Plaintiff to use it without strict supervision. Had Defendant implemented even the most basic

system of screening or age and identity verification, as well as effective parental controls, Plaintiff

never would have interacted with this predator and never would have suffered the harm that he

did. Plaintiff’s life has been devastated as a direct result of Defendant’s conduct.

VI. CAUSES OF ACTION

FIRST CAUSE OF ACTION

FRAUDULENT CONCEALMENT AND MISREPRESENTATIONS

(By Plaintiff Against Defendant)

155. Plaintiff incorporates each and every factual allegation set forth above.

156. This claim is brought against Defendant Roblox.

157. As set forth in more detail above, each Defendant knew about the defective

conditions of its app and that the app posed serious safety risks to child users.

158. Defendant was under a duty to tell the public the truth and to disclose the defective

conditions of its app and that the app posed serious safety risks to child users. Instead of disclosing

the truth, Defendant engaged in a widespread public campaign to tout the safety of its app in the

media, and in the materials provided to potential users of the app, as described above.

159. Defendant made numerous false representations about the safety of its app, as

described above, which were specific and widespread. Plaintiff’s mother and the public at large

relied on each Defendant’s false representations in deciding to allow children to play on the app.
160. Defendant was under a duty to tell the public, users, and their parents the truth and

to disclose the defective conditions of its app and that the app posed serious safety risks to child

users because Defendant possessed superior knowledge about the dangers of its app through

internal reviews, external studies known to Defendant, and parent and police reports made to

Defendant.

161. Defendant breached its duty to the public, users, and their parents by concealing

and failing to disclose the serious safety risks presented by its app. Even though Defendant knew

of those risks based on its internal reviews, external studies known to Defendant, and parent and

55
police reports made to Defendant, Defendant intentionally concealed those risks to not lose users

and revenue, and to induce parents to allow their children to use its app. Such risks were known

only to Defendant, and the public, users, and their parents, including Plaintiff’s mother, could not

have discovered such serious safety risks.

162. The public, users, and their parents, including Plaintiff’s mother, did not know of

the serious safety risks posed by the design of Defendant’s app, which were known by Defendant.

163. By intentionally concealing and failing to disclose defects inherent in the design

of its app, Defendant knowingly and recklessly misled the public, users, and their parents,

including Plaintiff’s mother, into believing that its app was safe for children to use.

164. Defendant knew that its concealment, omissions, and misrepresentations were

material. A reasonable person, including Plaintiff’s mother, would find information about the risk

of grooming, sexual abuse, sexual exploitation, and other serious risks associated with the use of

Defendant’s app, to be important when deciding whether to allow children to use it.

165. Defendant intended to deceive the public, users, and their parents, including

Plaintiff’s mother, by making misrepresentations and concealing the defects in the design of its

app, which made the app unsafe.

166. As a direct and proximate result of Defendant’s concealment of material

information and misrepresentations, Plaintiff’s mother was not aware and could not have been

aware of the facts that Defendant concealed, and therefore justifiably and reasonably believed
that Defendant’s app was safe for children to use.

167. If the serious safety risks presented by the design of Defendant’s app had been

disclosed, the public, users, and their parents, including Plaintiff’s mother, reasonably would have

acted differently and/or would have not permitted children to use the app.

168. As a direct and proximate result of Defendant’s concealment of material

information and misrepresentations, Plaintiff sustained serious injuries and harm.

169. Defendant’s concealment of material information and misrepresentations were a

substantial factor in causing harm to Plaintiff.

56
 170. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of its customers, and warrants an award of punitive

damages in an amount sufficient to punish Defendant and deter others from like conduct.

171. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

deems proper.

SECOND CAUSE OF ACTION

NEGLIGENT MISREPRESENTATION

(By Plaintiff Against Defendant)

172. Plaintiff incorporates each and every factual allegation set forth above.

173. This claim is brought against Defendant Roblox.

174. As set forth in more detail above, Defendant knew about the defective conditions

of its app and that the app posed serious safety risks to child users. Instead of disclosing the truth,

Defendant engaged in a widespread public campaign to tout the safety of its platform in the media,

and in the materials provided to potential users of the app, as described above.

175. Defendant made numerous false representations about the safety of its app, as

described above, which were specific and widespread. Plaintiff’s mother and the public at large
relied on Defendant’s false representations in deciding to allow children to play on the app.

176. By making numerous material representations downplaying any potential harm

associated with its app and reassuring the public, users, and their parents, including Plaintiff, that

its app was safe, Defendant negligently misled the public, users, and their parents, including

Plaintiff’s mother, into believing its app was safe for children to use.

177. Defendant had no reasonable grounds for believing that its misrepresentations that

its app was safe for children to use were true.

57
 178. As a direct and proximate result of Defendant’s material omissions,

misrepresentations, and concealment of material information, Plaintiff’s mother was not aware

and could not have been aware of the facts that Defendant misstated, and therefore justifiably and

reasonably believed that Defendant’s app was safe for use.

179. As a direct and proximate result of Defendant’s material omissions and

misrepresentations, Plaintiff sustained serious injuries and harm.

180. Plaintiff’s mother’s reliance on Defendant’s misrepresentations about the safety of

its app were substantial factors in causing harm to Plaintiff.

181. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of their customers, and warrants an award of punitive

damages in an amount sufficient to punish them and deter others from like conduct.

182. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

deems proper.

THIRD CAUSE OF ACTION

NEGLIGENCE – GENERAL

(By Plaintiff Against Defendant)

183. Plaintiff incorporates each and every factual allegation set forth above.

184. This claim is brought against Defendant Roblox.

185. At all relevant times, Defendant developed, set up, managed, maintained, operated,

marketed, advertised, promoted, supervised, controlled, and benefited from its respective app

used by Plaintiff.

186. Defendant owed Plaintiff a duty to exercise reasonable care in the development,

setup, management, maintenance, operation, marketing, advertising, promotion, supervision, and

control of its app and not to create an unreasonable risk of harm from and in the use of its app

58
(including an unreasonable risk of grooming, sexual abuse, and sexual exploitation, and other

associated physical or mental injuries); to protect Plaintiff from unreasonable risk of injury from

and in the use of its app; and not to invite, encourage, or facilitate youth, such as Plaintiff, to

foreseeably engage in dangerous or risky behavior through, on, or as a reasonably foreseeable

result of using its app. These duties govern Defendant’s own specific actions and are based on

direct actions Defendant took in developing its app and features.

187. In addition, Defendant owed a special relationship duty to Plaintiff to protect her

against harm caused by its app and employees or by other users. This special relationship duty is

based on the following:

a. As a business, Defendant owes a duty to protect customers against reasonably

foreseeable criminal acts of third parties and other dangers known to

Defendant on its app;

b. Plaintiff, as a minor, was vulnerable and dependent on Defendant for a safe

environment on their apps, and Defendant has superior ability and control to

provide that safety with respect to activities that they sponsor or control;

c. Plaintiff relied upon Defendant for protection against third-party misuse or

misconduct;

d. The special relationship Plaintiff had with Defendant substantially benefits

Defendant through profits and growth in users and user activity. Defendant
could not successfully operate without the growth in users and user activity

generated by children;

e. Defendant was far more to Plaintiff than a business. Defendant provided

Plaintiff with opportunities for social interaction and a discrete community of

other users. Plaintiff was dependent on Defendant to provide structure,

guidance, and a safe environment;

f. Defendant has superior control over its app environments and the ability to

protect its users. Defendant imposes a variety of rules and restrictions to

59
 supposedly maintain a safe and orderly environment. Defendant employs

internal staff to enforce these rules and restrictions and can monitor and

discipline users when necessary. Defendant has the power to influence

Plaintiff’s values, consciousness, relationships, and behaviors; and

g. Defendant has voluntarily undertaken a responsibility to keep children safe on

its app. As alleged above, Defendant has publicly stated that it takes steps to

keep children safe on its app and therefore has undertaken a duty to act

reasonably in taking such steps.

188. Plaintiff was a foreseeable user of Defendant’s app.

189. Defendant knew that minors such as Plaintiff would use its app.

190. Defendant invited, solicited, encouraged, or reasonably should have foreseen the

fact, extent, and manner of Plaintiff’s use of its app.

191. Defendant knew or, by the exercise of reasonable care, should have known, that

the reasonably foreseeable use of its app (as developed, set up, managed, maintained, supervised,

and operated by Defendant) was dangerous, harmful, and injurious when used by youth such as

Plaintiff in a reasonably foreseeable manner.

192. At all relevant times, Defendant knew or, by the exercise of reasonable care,

should have known that its app (as developed, set up, managed, maintained, supervised, and

operated by Defendant) posed unreasonable risks of harm to youth such as Plaintiff, which risks
were known and knowable, including in light of the internal data and knowledge Defendant had

regarding its app.

193. Defendant knew, or by the exercise of reasonable care, should have known, that

ordinary child users of its app, such as Plaintiff, would not have realized the potential risks and

dangers of using the app, including a risk of grooming, sexual abuse, and sexual exploitation,

which foreseeably can lead to a cascade of negative effects, including but not limited to physical

injury, damage to self-worth, stigma and social isolation, reduced academic performance,

increased risky behavior, susceptibility to future sexual exploitation, attachment issues, identity

60
confusion, and profound mental health issues for young consumers, including but not limited to

depression, anxiety, suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, eating

disorders, death, and other harmful effects.

194. Defendant’s conduct was closely connected to Plaintiff’s injuries, which were

highly certain to occur, as evidenced by the significance of Plaintiff’s injuries.

195. Defendant could have avoided Plaintiff’s injuries with minimal cost, including, for

example, by not including certain features in its app which harmed Plaintiff.

196. Imposing a duty on Defendant would benefit the community at large.

197. Imposing a duty on Defendant would not be burdensome to them because they

have the technological and financial means to avoid the risks of harm to Plaintiff.

198. Defendant owed a heightened duty of care to youth users of its app because

children’s brains are not fully developed, meaning young people are more neurologically

vulnerable than adults to abusive contact facilitated by Defendant’s app because they have a hard

time distinguishing between patterns of genuine friendship and grooming relationships.

199. Defendant breached its duties of care owed to Plaintiff through its affirmative

malfeasance, actions, business decisions, and policies in the development, set up, management,

maintenance, operation, marketing, advertising, promotion, supervision, and control of its

respective app. These breaches are based on Defendant’s own actions in managing their own apps

made available to the public, independent of any actions taken by a third party. Those breaches
include but are not limited to:

a. Including features in its app that, as described above, are currently structured

and operated in a manner that unreasonably creates or increases the foreseeable

risk of grooming, sexual abuse, and sexual exploitation to youth, including

Plaintiff;

b. Including features in its app that, as described above, are currently structured

and operated in a manner that unreasonably creates or increases the foreseeable

risk of harm to the physical and mental health and well-being of youth users,

61
 including Plaintiff, including but not limited to physical injury, damage to self-

worth, stigma and social isolation, reduced academic performance, increased

risky behavior, susceptibility to future sexual exploitation, attachment issues,

identity confusion, and profound mental health issues for young consumers,

including but not limited to depression, anxiety, suicidal ideation, self-harm,

post-traumatic stress disorder, insomnia, eating disorders, death, and other

harmful effects;

c. Maintaining unreasonably dangerous features in its app after notice that such

features, as structured and operated, posed a foreseeable risk of harm to the

physical and mental health and well-being of youth users;

d. Facilitating unsupervised and/or hidden use of its app by youth, including by

adopting protocols that allow youth users to change its own safety settings or

parental controls, and create multiple and private accounts; and

e. Inviting children on its app and marketing to children when Defendant knew

that its app, as designed, was not safe for children.

200. Defendant breached its duties of care owed to Plaintiff through its nonfeasance,

failure to act, and omissions in the development, setup, management, maintenance, operation,

marketing, advertising, promotion, supervision, and control of its app. These breaches are based

on Defendant’s own actions in managing their own apps made available to the public, independent
of any actions taken by a third party. Those breaches include but are not limited to:

a. Failing to implement effective parental controls;

b. Failing to screen users before allowing them on the app;

c. Failing to implement effective parental notifications, such as when a child

messages another user, particularly an adult user, or when a child interacts with

accounts that have been blocked by other users or suspended in the past;

d. Failing to require adult users to provide a phone number when signing up for

an account;

62
 e. Failing to implement pop-up safety notices within chats and games to warn

users about inappropriate behavior;

f. Failing to ban IP and MAC addresses of accounts associated with known

abusers;

g. Failing to set default safety settings to the most protective options;

h. Having an open chat function;

i. Failing to provide a transcript of a child’s communications to the parent;

j. Failing to implement reasonably available means to monitor for, report, and

prevent the use of their apps by sexual predators to victimize, abuse, and

exploit youth users;

k. Failing to provide effective mechanisms for youth users and their

parents/guardians to report abuse or misuse of its app;

l. Failing to implement effective protocols to verify ages and identity of all users;

m. Failing to place reasonable age restrictions on its app;

n. Failing to separate adults from children on the apps by, for example, creating

separate apps for children;

o. Failing to adequately fund its trust and safety programs; and

p. Others as set forth herein.

201. A reasonable company under the same or similar circumstances as Defendant

would have developed, set up, managed, maintained, supervised, and operated its app in a manner

that is safer for and more protective of youth users like Plaintiff.

202. At all relevant times, Plaintiff used Defendant’s app in the manner in which it was

intended to be used.

203. As a direct and proximate result of each Defendant’s breach of one or more of its

duties, Plaintiff was harmed. Such harms include the sexual exploitation of Plaintiff by a child

predator and a cascade of resulting negative effects, including but not limited to damage to self-

worth, stigma and social isolation, reduced academic performance, increased risky behavior,

63
susceptibility to future sexual exploitation, attachment issues, and profound mental health issues

such as depression, anxiety, and other harmful effects.

204. Defendant’s breach of one or more of its duties was a substantial factor in causing

harms and injuries to Plaintiff.

205. Plaintiff was injured from using Defendant’s defective app through no fault of her

own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

responsible for the injuries caused by Defendant’s app and the burden shifts to Defendant to

identify alternative causes of the alleged injuries and apportion responsibility for the alleged

injuries.

206. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

207. Defendant’s conduct, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of their

conduct, including to the health, safety, and welfare of their customers, and warrants an award of

punitive damages in an amount sufficient to punish the Defendant and deter others from like

conduct.

208. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court
deems proper.

FOURTH CAUSE OF ACTION

NEGLIGENCE – FAILURE TO WARN

(By Plaintiff Against Defendant)

209. Plaintiff incorporates each and every factual allegation set forth above.

210. This claim is brought against Defendant Roblox.

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 211. At all relevant times, Defendant designed, developed, managed, operated, tested,

produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

benefited from its app used by Plaintiff.

212. Plaintiff was a foreseeable user of Defendant’s app.

213. Defendant knew, or by the exercise of reasonable care, should have known, that

use of its app was dangerous, harmful, and injurious when used in a reasonably foreseeable

manner by minors.

214. Defendant knew, or by the exercise of reasonable care, should have known, that

ordinary minor users, such as Plaintiff, would not have realized the potential risks and dangers of

its app, including a risk of grooming, sexual abuse, and sexual exploitation, which can lead to a

cascade of harms. Those harms include but are not limited to physical injury, damage to self-

worth, stigma and social isolation, reduced academic performance, increased risky behavior,

susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

mental health issues for young consumers, including but not limited to depression, anxiety,

suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful

effects.

215. Had Plaintiff received proper or adequate warnings about the risks of Defendant’s

app, Plaintiff would have heeded such warnings.

216. Defendant knew or, by the exercise of reasonable care, should have known that its
app posed risks of harm to youth. These risks were known and knowable in light of Defendant’s

own internal data and knowledge regarding its app at the time of development, design, marketing,

promotion, advertising, and distribution to Plaintiff.

217. Because Defendant’s conduct created the risk that child users of their apps would

be subject to grooming, sexual abuse, and sexual exploitation, Defendant owed a duty to all

reasonably foreseeable users, including but not limited to minor users and their parents, to provide

adequate warnings about the risk of using Defendant’s app that were known to Defendant, or that

Defendant should have known through the exercise of reasonable care.

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 218. In addition, as described above, Defendant owed a special relationship duty to

Plaintiff to protect him against harm caused by its app and employees or by other users.

219. Defendant owed a heightened duty of care to minor users and their parents to warn

about its app’s risks because children’s brains are not fully developed, resulting in a diminished

capacity to make responsible decisions regarding contact with strangers online. Children are also

more neurologically vulnerable than adults to abusive contact facilitated by Defendant’s app

because they have a hard time distinguishing between patterns of genuine friendship and

grooming relationships.

220. Defendant breached its duty by failing to use reasonable care in providing adequate

warnings to Plaintiff, such as failing to notify parents and the general public of the following,

among others:

a. Defendant fails to require that children have parental approval before signing

up for an account;

b. Defendant fails to screen users before allowing them on their apps;

c. New users of Defendant’s app can identify themselves as minors, begin to use

the app, and do so indefinitely, without ever receiving a safety warning, and

without ever having to provide information so that Defendant can warn the

users’ parents or guardians;

d. Defendant’s app’s default safety settings allow adults and other strangers’
accounts to find, “friend,” and communicate with children’s accounts;

e. Defendant’s parental control settings allowed children to modify their own

parental control settings;

f. Defendant’s platforms recommend that adult users and other strangers “friend”

and contact child accounts;

g. Defendant fails to block the IP and MAC addresses of known abusers;

h. Adult predators use Defendant’s to target children for sexual exploitation,

sextortion, and CSAM;

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 i. Defendant’s app enables and increases risk of exposure to predators and can

result in grooming, sexual abuse, and sexual exploitation, as well as their

resultant physical and mental injuries;

j. Sexual predators use Robux to coerce children into sending them nude photos

or engaging in other types of sexually explicit behavior;

k. Usage of Defendant’s app can increase risky and uninhibited behavior in

children, making them easier targets to adult predators for sexual exploitation,

sextortion, and CSAM;

l. Usage of Defendant’s app can normalize abuse and pornography, leading

children to abuse other children either contemporaneously or later when the

children are older;

m. The likelihood and severity of harm is greater for children;

n. The likelihood and intensity of these harmful effects is exacerbated by the

interaction of the app’s features with one another;

o. Defendant fails to verify ages, allowing adult predators to pose as children on

Defendant’s app;

p. Defendant’s failure to verify ages allows children to bypass parental controls,

safety features, and default settings; and

q. Others as set forth herein.

221. A reasonable company under the same or similar circumstances as Defendant

would have used reasonable care to provide adequate warnings to consumers, including the

parents of minor users, as described herein.

222. At all relevant times, Defendant could have provided adequate warnings to prevent

the harms and injuries described herein.

223. As a direct and proximate result of Defendant’s breach of its duty to provide

adequate warnings, Plaintiff was harmed and sustained the injuries set forth herein. Defendant’s

67
failure to provide adequate and sufficient warnings was a substantial factor in causing the harms

to Plaintiff.

224. As a direct and proximate result of Defendant’s failure to warn, Plaintiff requires

and/or will require more healthcare and services and did incur medical, health, incidental, and

related expenses.

225. Plaintiff was injured from using Defendant’s defective app through no fault of her

own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

responsible for the injuries caused Defendant’s app and the burden shifts to Defendants to identify

alternative causes of the alleged injuries and apportion responsibility for the alleged injuries.

226. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

227. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of their customers, and warrants an award of punitive

damages in an amount sufficient to punish Defendant and deter others from like conduct.

228. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys' fees, and all such other relief as the Court

deems proper.
FIFTH CAUSE OF ACTION

NEGLIGENCE – UNREASONABLE DESIGN

(By Plaintiff Against Defendant)

229. Plaintiff incorporates each and every factual allegation set forth above.

230. This claim is brought against Defendant Roblox.

231. At all relevant times, Defendant designed, developed, managed, operated, tested,

produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

benefited from its app used by Plaintiff.

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 232. Defendant knew or, by the exercise of reasonable care, should have known, that

its app was dangerous, harmful, and injurious when used by youth in a reasonably foreseeable

manner.

233. Defendant knew or, by the exercise of reasonable care, should have known that its

app posed risks of harm to youth. These risks were known and knowable in light of Defendant’s

own internal data and knowledge regarding their apps at the time of the app’s development,

design, marketing, promotion, advertising, and distribution to Plaintiff.

234. Defendant knew, or by the exercise of reasonable care, should have known, that

ordinary minor consumers such as Plaintiff would not have realized the potential risks and dangers

of its app. Those risks include grooming, sexual abuse, and sexual exploitation, which can lead

to a cascade of negative effects, including but not limited to physical injury, damage to self-worth,

stigma and social isolation, reduced academic performance, increased risky behavior,

susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

mental health issues for young consumers, including but not limited to depression, anxiety,

suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful

effects.

235. Defendant owed a duty to all reasonably foreseeable users to design a safe app.

236. Defendant owed a heightened duty of care to minor users of its app because

children’s brains are not fully developed, resulting in a diminished capacity to make responsible
decisions regarding contact with strangers online. Children are also more neurologically

vulnerable than adults to abusive contact facilitated by Defendant’s app because they have a hard

time distinguishing between patterns of genuine friendship and grooming relationships.

237. Plaintiff was a foreseeable user of Defendant’s app.

238. Defendant knew that minors such as Plaintiff would use its app.

239. Defendant breached its duty in designing its app.

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 240. Defendant breached its duty by failing to use reasonable care in the design of its

app by negligently designing the app with features that specifically allow predators to find, groom,

exploit, and abuse children, as described herein.

241. Defendant breached its respective duty by designing an app that was less safe to

use than an ordinary consumer would expect when used in an intended and reasonably foreseeable

manner.

242. Defendant breached its respective duty by failing to use reasonable care in the

design of its app by negligently designing its app with features as described above that created or

increased the risk of grooming, sexual abuse, and sexual exploitation for children, which can lead

to a cascade of negative effects, including but not limited to physical injury, damage to self-worth,

stigma and social isolation, reduced academic performance, increased risky behavior,

susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

mental health issues for young consumers, including but not limited to depression, anxiety,

suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful

effects.

243. Defendant breached its duty by failing to use reasonable care to use cost-effective,

reasonably feasible alternative designs, including changes to the harmful features, and other safety

measures, to minimize the harms described herein, including but not limited to:

a. Requiring children have parental approval and a parent’s email address to sign-
up for an account;

b. Effective parental controls;

c. Effective parental notifications, including notifying parents any time a child

messages another user, particularly an adult user, or notifying parents when

children interact with accounts that have been blocked by other users or

suspended in the past, among other controls;

d. Setting default safety settings to the most protective options, including

blocking direct messaging between child and adult users, or only allowing

70
 messaging between adult users and a child with the parent’s explicit

permission to message the adult user;

e. Requiring adults to provide a phone number when signing up for an account;

f. Pop-up safety notices within chats and games to warn users about

inappropriate behavior;

g. Preventing strangers from sending Robux to child accounts, and preventing

children from sending Robux to strangers’ accounts;

h. Banning IP and MAC addresses of accounts associated with known abusers;

i. Controlled chat option;

j. Providing a transcript of a child’s communications to the parent;

k. Implementing reporting protocols to allow users or visitors of Defendants’

apps to report CSAM and adult predator accounts specifically without the need

to create or log in to the apps prior to reporting;

l. Robust age and identity verification;

m. Reasonable age restrictions;

n. Separating adults from children by, for example, creating separate apps for

children; and

o. Others as set forth herein.

244. Alternative designs that would reduce the dangerous features of Defendant’s app
were available, would have served effectively the same purpose as Defendant’s defectively

designed app, and would have reduced the gravity and severity of danger Defendant’s app posed

minor Plaintiff.

245. A reasonable company under the same or similar circumstances as Defendant

would have designed a safer app.

246. At all relevant times, Plaintiff used Defendant’s app in the manner in which it was

intended by Defendant to be used.

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 247. As a direct and proximate result of Defendant’s breached duties, Plaintiff was

harmed. Defendant’s design of its app was a substantial factor in causing Plaintiff’s harms and

injuries.

248. Plaintiff was injured from using Defendants’ defective app through no fault of her

own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

responsible for the injuries caused by Defendant’s app and the burden shifts to Defendant to

identify alternative causes of the alleged injuries and apportion responsibility for the alleged

injuries.

249. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

250. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of its customers, and warrants an award of punitive

damages in an amount sufficient to punish Defendant and deter others from like conduct.

251. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

deems proper.

SIXTH CAUSE OF ACTION

NEGLIGENT UNDERTAKING

(By Plaintiff Against Defendant)

252. Plaintiff incorporates each and every factual allegation set forth above.

253. This claim is brought against Defendant Roblox.

254. Defendant rendered parental control services and account safety services to

Plaintiff’s parents.

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 255. Defendant made numerous statements, as outlined above, claiming in substance

that their parental controls and account safety services were highly effective at protecting users

from the type of harm Plaintiff suffered.

256. Defendant knew, or reasonably should have known, that effective parental control

and account safety services were necessary for the protection of minor users.

257. Defendant’s conduct was closely connected to Plaintiff’s injuries, which were

highly certain to occur, as evidenced by the significance of Plaintiff’s injuries.

258. Defendant could have avoided Plaintiff’s injuries with minimal cost, including, for

example, by implementing parental control and account safety services that were effective and

that would prevent child users from being contacted by adult accounts or strangers’ accounts

generally.

259. Imposing a duty on Defendant would benefit the community at large.

260. Imposing a duty on Defendant would not be burdensome to them because it has

the technological and financial means to avoid the risks of harm to children.

261. Defendant owed a heightened duty of care to minor users and their parents to

implement parental control and account safety services that were effective and that would prevent

child users from being contacted by adult accounts or strangers’ accounts generally.

262. Plaintiff’s mother relied on Defendant exercising reasonable care in undertaking

to render parental control and account safety services.

263. Defendant breached its duty of undertaking by failing to use reasonable care in

rendering its parental control and account safety services to prevent child users from being

contacted by adult accounts or strangers’ accounts generally.

264. Defendant failed to exercise reasonable care in rendering these parental control

and account safety services.

265. Defendant’s failure to exercise reasonable care increased the risk of, and was a

substantial factor in causing harm to Plaintiff.

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 266. Plaintiff was harmed by her mother’s reliance on Defendant to provide effective

parental control and account safety services.

267. Defendant’s breach of one or more of its duties was a substantial factor in causing

harms and injuries to Plaintiff.

268. Plaintiff was injured from using Defendant’s defective app through no fault of her

own. The fact that Plaintiff was injured by using Defendant’s app means that Defendant is

responsible for the injuries caused by any one of Defendants’ apps and the burden shifts to

Defendant to identify alternative causes of the alleged injuries and apportion responsibility for

the alleged injuries.

269. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s app.

270. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of their

conduct, including to the health, safety, and welfare of its customers, and warrants an award of

punitive damages.

271. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys' fees, and all such other relief as the Court

deems proper.
SEVENTH CAUSE OF ACTION

STRICT LIABILITY – DESIGN DEFECT

(By Plaintiff Against Defendant)

272. Plaintiff incorporates each and every factual allegation set forth above.

273. This claim is brought against Defendant Roblox.

274. At all relevant times, Defendant designed, developed, managed, operated, tested,

produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

benefitted from its product used by Plaintiff.

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 275. These products were designed, manufactured, maintained, controlled, and

distributed from the California headquarters of Defendant.

276. Defendant’s product was designed and intended to be a gaming and/or

communication product. The software and architecture of each product is the same for every user

that logs on or signs up for an account. These products are uniformly defective and pose the same

danger to each minor user.

277. Defendant’s product is distributed and sold to the public through retail channels

(e.g., the Apple App “Store” and the Google Play “Store”).

278. Defendant’s product is marketed and advertised to the public for the personal use

of the end-user/consumer.

279. Defendant defectively designed its product to allow children to come into contact

with child predators. Children are particularly unable to appreciate the risks posed by the products.

280. The defects in the design of Defendant’s product existed prior to the release of

these products to Plaintiff and the public, and there was no substantial change to Defendant’s

products between the time of their upload by each Defendant to public or retail channels (e.g., the

App Store or Google Play) and the time of their distribution to Plaintiff via download or URL

access.

281. Plaintiff used these products as intended, and Defendant knew or, by the exercise

of reasonable care, should have known that Plaintiff would use these products without inspection
for its dangerous nature.

282. Defendant defectively designed its product to appeal to adult predators by making

it easy to find children and enabled their contact, grooming, sexual exploitation, and sexual abuse

of children, including Plaintiff.

283. Defendant failed to test the safety of the features it developed and implemented

for use on its product. When Defendant did perform some product testing and had knowledge of

ongoing harm, it failed to adequately remedy its product’s defects or warn Plaintiff.

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 284. Defendant’s product is defective in design and poses a substantial likelihood of

harm for the reasons set forth herein, because the products fail to meet the safety expectations of

ordinary consumers when used in an intended or reasonably foreseeable manner, and because the

products are less safe than an ordinary consumer would expect when used in such a manner.

Children and teenagers are among the ordinary consumers of Defendant’s products. Indeed,

Defendant markets, promotes, and advertises its respective product to pre-teen and young

consumers. Pre-teen and young consumers, and their parents and guardians, do not expect

Defendant’s products to expose them to predators when the products are used in their intended

manner by their intended audience. They do not expect the features embedded by Defendant in

their products to make it easy for child predators to sign-up for accounts and find children, groom

children, and sexually exploit children. They do not expect Defendant’s revenue and profits to be

directly tied to predators’ extortion of children.

285. Defendant’s product is likewise defectively designed in that it creates an inherent

risk of danger; specifically, a risk of grooming, sexual abuse, and sexual exploitation, which can

lead to a cascade of harms. Those harms include but are not limited to physical injury, damage to

self-worth, stigma and social isolation, reduced academic performance, increased risky behavior,

susceptibility to future sexual exploitation, attachment issues, identity confusion, and profound

mental health issues for young consumers, including but not limited to depression, anxiety,

suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other harmful
effects.

286. The risks inherent in the design of Defendant’s product significantly outweigh any

benefits of such design.

287. Defendant could have utilized cost-effective, reasonably feasible alternative

designs, including changes to the problematic features described above, to minimize the harms

described herein, including, but not limited to:

a. Requiring children have parental approval and a parent’s email address to sign-

up for an account;

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b. Effective parental controls;

c. Effective parental notifications, including notifying parents any time a child

messages another user, particularly an adult user, or notifying parents when

children interact with accounts that have been blocked by other users or

suspended in the past, among other controls;

d. Setting default safety settings to the most protective options, including

blocking direct messaging between child and adult users, or only allowing

messaging between adult users and a child with the parent’s explicit

permission to message the adult user;

e. Requiring adults to provide a phone number when signing up for an account;

f. Pop-up safety notices within chats and games to warn users about

inappropriate behavior;

g. Preventing strangers from sending Robux to child accounts, and preventing

children from sending Robux to strangers’ accounts;

h. Banning IP and MAC addresses of accounts associated with known abusers;

i. Controlled chat option;

j. Providing a transcript of a child’s communications to the parent;

k. Implementing reporting protocols to allow users or visitors of Defendants’

products to report child sex abuse material and adult predator accounts
specifically without the need to create or log in to the products prior to

reporting;

l. Robust age and identity verification;

m. Reasonable age restrictions;

n. Separating adults from children by, for example, creating separate apps for

children; and

o. Others as set forth herein.

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 288. Alternative designs were available that would prevent child predators from

finding, grooming, and exploiting children, and which would have served effectively the same

purpose of Defendant’s products while reducing the gravity and severity of danger posed by those

products’ defects.

289. Plaintiff used Defendant’s respective products as intended or in reasonably

foreseeable ways.

290. The physical, emotional, and economic injuries of Plaintiff were reasonably

foreseeable to Defendant at the time of its products’ development, design, advertising, marketing,

promotion, and distribution.

291. Defendant’s product was defective and unreasonably dangerous when it left each

Defendant’s respective possession and control. The defects continued to exist through the

products’ distribution to and use by consumers, including Plaintiff, who used the products without

any substantial change in the products’ condition.

292. As manufacturer, designer and seller, Defendant had a duty to inform itself with

the best knowledge of the risks and the defects of its product and Defendant had such knowledge.

Their victims, including Plaintiff, were powerless to protect themselves against unknown harms,

and Defendant should bear the costs of their injuries.

293. Plaintiff was injured as a direct and proximate result of Defendant’s respective

defective designs as described herein. The defective design of the products used by Plaintiff was
a substantial factor in causing harms to Plaintiff.

294. As a direct and proximate result of Defendant’s product’s defective design,

Plaintiff suffered serious and dangerous injuries.

295. As a direct and proximate result of Defendant’s product’s defective design,

Plaintiff requires and/or will require more healthcare and services and did incur medical, health,

incidental, and related expenses.

296. Plaintiff was injured from using Defendant’s defective products through no fault

of her own. The fact that Plaintiff was injured by using Defendant’s products means that

78
Defendant is responsible for the injuries caused by any one of Defendant’s products and the

burden shifts to Defendant to identify alternative causes of the alleged injuries and apportion

responsibility for the alleged injuries.

297. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s products.

298. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of its customers, and warrants an award of punitive

damages in an amount sufficient to punish Defendant and deter others from like conduct.

299. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

deems proper.

EIGHTH CAUSE OF ACTION

STRICT LIABILITY – FAILURE TO WARN

(By Plaintiff Against Each Defendant)

300. Plaintiff incorporates each and every factual allegation set forth above.

301. This claim is brought against Defendant Roblox.

302. At all relevant times, Defendant designed, developed, managed, operated, tested,
produced, labeled, marketed, advertised, promoted, controlled, sold, supplied, distributed, and

benefitted from its product used by Plaintiff.

303. These products were designed, manufactured, maintained, controlled and

distributed from the California headquarters of Defendant.

304. Defendant’s product was designed and intended to be a gaming and/or

communication product. The software and architecture of each product is the same for every user

that logs on or signs up for an account. These products are uniformly defective and pose the same

danger to each minor user.

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 305. Defendant’s product is distributed and sold to the public through retail channels

(e.g., the Apple App “Store” and the Google Play “Store”).

306. Defendant sold and distributed its product to Plaintiff in a defective and

unreasonably dangerous condition by failing to adequately warn about the risk of harm to youth

as described herein, including a risk of grooming, sexual abuse, and sexual exploitation, which

can lead to a cascade of harms. Those harms include but are not limited to physical injury, damage

to self-worth, stigma and social isolation, reduced academic performance, increased risky

behavior, susceptibility to future sexual exploitation, attachment issues, identity confusion, and

profound mental health issues for young consumers including but not limited to depression,

anxiety, suicidal ideation, self-harm, post-traumatic stress disorder, insomnia, death, and other

harmful effects.

307. Defendant was in the best position to know the dangers its products posed to

consumers, including Plaintiff, as they had superior knowledge of the risks and dangers posed by

their products and had exclusive knowledge of these risks at the time of development, design,

marketing, promotion, advertising and distribution. Defendant had exclusive control of its

products at all times relevant to this litigation.

308. Defendant’s respective product is dangerous, to an extent beyond that

contemplated by the ordinary user who used Defendant’s products, because they enable predators

to find, groom, abuse, and exploit children.

309. Defendant knew or, by the exercise of reasonable care, should have known that its

respective product posed risks of harm to youth considering its own internal data and knowledge

regarding its product at the time of development, design, marketing, promotion, advertising, and

distribution.

310. These risks were known and knowable in light of Defendant’s own internal data

and knowledge regarding their products at the time of the products’ development, design,

marketing, promotion, advertising, and distribution to Plaintiff.

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 311. Defendant’s products are defective and unreasonably dangerous because, among

other reasons described herein, each Defendant failed to exercise reasonable care to inform users

that, among other things:

a. Sexual predators use Defendant’s products to find, contact, groom and abuse

children with alarming frequency;

b. Sexual predators use Defendant’s products to solicit, produce, and distribute

CSAM with alarming frequency;

c. Sexual predators target young children for CSAM on Defendant’s products

with alarming frequency;

d. Sexual predators use Robux to coerce children into sending them nude photos

or engaging in other types of sexually explicit behavior;

e. Defendant’s products are designed in a way that enables and increases risk of

exposure to predators and resulting sexual exploitation;

f. Defendant’s products cause grooming, sexual abuse, and sexual exploitation,

and its resultant physical and mental injuries;

g. Use of Defendant’s products can increase risky and uninhibited behavior in

children, making them easier targets to adult predators for sexual exploitation,

sextortion, and CSAM;

h. Use of Defendant’s products can normalize abuse and pornography, leading

children to abuse other children either contemporaneously or later when the

children are older;

i. New users of Defendant’s product can identify themselves as minors, begin to

use the product, and do so indefinitely, without ever receiving a safety

warning, and without ever having to provide information so that Defendants

can warn the users’ parents or guardians;

j. Defendant’s failure to verify ages allows children to bypass parental controls,

safety features, and default settings;

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 k. The likelihood and severity of harms is greater for children;

l. The likelihood and intensity of these harmful effects is exacerbated by the

interaction of each product’s features with one another; and

m. Others as set forth herein.

312. Plaintiff was a foreseeable user of Defendant’s product.

313. Ordinary minor users would not have recognized the potential risks of Defendant’s

products when used in a manner reasonably foreseeable to Defendant.

314. Had Plaintiff received proper or adequate warnings or instructions as to the risks

of using Defendant’s product, Plaintiff would have heeded the warnings and/or followed the

instructions.

315. Defendant’s failures to adequately warn Plaintiff about the risks of their defective

products were a proximate cause and a substantial factor in the injuries sustained by Plaintiff.

316. Plaintiff was injured from using Defendants’ defective products through no fault

of her own. The fact that Plaintiff was injured by using Defendant’s products means that

Defendant is responsible for the injuries caused by Defendant’s products and the burden shifts to

Defendant to identify alternative causes of the alleged injuries and apportion responsibility for

the alleged injuries.

317. The nature of the fraudulent and unlawful acts that created safety concerns for

Plaintiff are not the type of risks that are immediately apparent from using Defendant’s products.
318. The conduct of Defendant, as described above, was intentional, fraudulent, willful,

wanton, reckless, malicious, fraudulent, oppressive, extreme, and outrageous, and displayed an

entire want of care and a conscious and depraved indifference to the consequences of its conduct,

including to the health, safety, and welfare of their customers, and warrants an award of punitive

damages in an amount sufficient to punish Defendant and deter others from like conduct.

319. Plaintiff demands judgment against Defendant for compensatory and punitive

damages, together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court

deems proper.

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VII. PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment against Defendant for the above-referenced

claims and causes of action, and as follows:

1. Past, present, and future general damages, the exact amount of which has yet to be

ascertained, in an amount which will confirm to proof at time of trial, to

compensate Plaintiff for injuries sustained as a result of the use of Defendant’s

products, including but not limited to physical pain and suffering, mental anguish,

loss of enjoyment of life, emotional distress, and expenses for medical treatments;

2. Past, present, and future economic and special damages, according to proof at the

time of trial;

3. Impaired earning capacity according to proof at the time of trial;

4. Medical expenses, past and future, according to proof at the time of trial;

5. Punitive or exemplary damages according to proof at the time of trial;

6. Attorneys’ fees;

7. For costs of suit incurred herein;

8. Pre-judgment and post-judgment interest as provided by law;

9. For nonmonetary injunctive relief; and

10. For such other and further relief as the Court may deem just and proper.

VIII. DEMAND FOR A JURY TRIAL

320. Plaintiff hereby demands a trial by jury on all claims so triable.

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Date: August 27, 2025 Respectfully submitted,

By: /s/ Laci M. Whitley

Laci Whitley #66675
Edward Wallace
WALLACE MILLER
150 N. Wacker Drive, Suite 1100
Chicago, IL 60606
T: 312.261.6193
F: 312-275-8174
[email protected]

Matthew A. Dolman*
[email protected]
R. Stanley Gipe*
[email protected]
Sara D. Beller*
[email protected]
DOLMAN LAW GROUP
800 N. Belcher Rd.
Clearwater, FL 33765
Telephone: (727) 451-6900
Facsimile: (727) 451-6907

Attorneys for Plaintiff John Doe and His

Next Friend and Guardian Jane Doe R.S.

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