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Roblox

TINA.org investigated the online gaming and creation platform Roblox, which is used by millions of young children on a daily basis, and found, among other things, that the company allows advertising to be surreptitiously interlaced with organic content in a multitude of ways, and uses atypical earnings claims to lure game developers to its platform.

Highlights

  • Filed complaint with FTC
  • Filed FOIA Appeal with FTC
  • Filed complaint with ASA
  • Sent letter to CARU, Roblox and Walmart regarding deceptive Walmart advergame on Roblox
  • Roblox issues new Advertising Standards
  • Walmart removed advergame from Roblox
  • Filed opposition to class-action settlement

Timeline

2023
October 5

The Court issues its decision granting final approval of the proposed settlement agreement, but also granting TINA.org’s motion for leave to file an amicus brief and allowing TINA.org to appear at the Final Approval Hearing. In addition, the approval order allows TINA.org to notify the Court if “Roblox fails to follow the Court-approved relief or otherwise fails to provide the ongoing value to class members.”

September 27

A final fairness hearing is held in the Northern District of California, during which the Court asks the parties to address the points and arguments in TINA.org’s amicus brief. However, the Court ultimately grants final approval of the proposed settlement agreement from the bench. A written decision will follow.

August 9

In a class-action lawsuit pending against Roblox for allegedly deceptively enticing millions of children to purchase in-game content on its platform and then deleting their purchased content without providing any refund or credit, TINA.org files brief as amicus curiae opposing the proposed settlement reached by the parties, as well as a Motion for Leave to file the brief.

June 15

Roblox’s new “Advertising Standards” take effect.

May 11

CARU determined that Roblox violated its Ad Guidelines by (1) failing to adequately disclose to children when advertising is present within experiences and videos on Roblox; and (2) failing to ensure that social media influencers clearly and conspicuously disclose their material connections to Roblox in a manner that is understandable to children. CARU recommended that Roblox ensure that proper disclosures are implemented. Roblox disagreed with some of CARU’s findings and recommendations but stated it would comply with CARU’s recommendations as they pertain to influencers.

March 27

TINA.org, along with Fairplay, Center for Digital Democracy, National Association of Consumer Advocates, and Common Sense Media, respond to CARU’s letter expressing ongoing concern about its decision regarding Walmart Universe of Play, as well as its COPPA Safe Harbor Program in general.

March 15

Roblox issues an onslaught of new “Community Standards” and “Advertising Standards,” which are to become effective on June 15, 2023.  Many of the new standards appear to be responding to issues TINA.org raised with the platform and the FTC last April. A discussion of the changes is available here.

As of March 10

Walmart removes its Universe of Play from Roblox search results and locked the experience on the platform so that children cannot access this undisclosed advergame.

January 31

CARU responds to advocacy groups’ letter regarding Walmart Universe of Play on Roblox and stands by its decision to admit the advergame into its COPPA Safe Harbor Program.

January 23

TINA.org, along with Fairplay, Center for Digital Democracy, and National Association of Consumer Advocates, sends a letter to the Children’s Advertising Review Unit (CARU) regarding Walmart Universe of Play advergame on Roblox.

2022
November 1

Just days after boasting to media outlets that “users under the age of 13 will no longer be eligible to see ads” on the platform, Roblox quietly removes its longstanding written policy that “Ads may not contain content intended for users under the age of 13.” Here’s the before and after.

October 27

TINA.org sends a follow-up letter to the FTC (and provides a copy to Roblox, as well as certain companies who advertise on the platform) regarding inaccurate statements made by Roblox about the platform blocking children from accessing advertisements.

August 23

The Advertising Standards Authority declines TINA.org’s complaint because, though Roblox is used by consumers in the UK, it is based in the U.S. and thus outside the ASA’s purview as it “can only take action against advertisers that are based in the UK, or are using a UK platform to advertise their products/services.”

August 10

TINA.org sends complaint letter to the Advertising Standards Authority in the UK urging the agency to take action.

May 12

The FTC responds to TINA.org’s FOIA appeal indicating that it will provide all of the nearly 1,300 consumer complaints filed with the FTC regarding Roblox.

April 19

TINA.org sends complaint letter to FTC urging the agency to take action.

April 18

TINA.org files a FOIA appeal with the FTC regarding the agency’s provision of only 200 of nearly 1,300 consumer complaints filed with the FTC regarding Roblox.

Evidence

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Class-Action Tracker

Roblox

Class Action

Roblox

Allegations: Failing to disclose the risk of criminal and predative activity on its platform and misleading parents into thinking that Roblox protects children from inappropriate content

Roblox In-Game Content

Class Action

Roblox In-Game Content

Allegations: Advertising in-game content without warning consumers that the platform deletes purchased content and does not provide refunds or credits for the deletions

Gambling on Roblox

Class Action

Gambling on Roblox

Allegations: Falsely representing that its platform and digital currency are safe and that experiences that simulate gambling are not allowed on the platform