- with Inhouse Counsel
Regulators continue to focus on how companies interact with children online, as illustrated by the recent settlements Roblox entered into with different state AGs. The company has agreed to pay a total of almost $36 million to Alabama (April 21), Nevada (April 15), and West Virginia (April 21), with cases still pending in Florida, Iowa, Kentucky, Louisiana, and Texas.
The investigations arose as a result of alleged failures to verify ages and serve children with age-appropriate content. In these three settlement agreements, the company has agreed to not only pay significant civil penalties, but to modify many of its practices. From the measures the company has agreed to implement, others can derive three core lessons. Namely, to assess processes for age verification, parental controls, and restricting adult interactions with children.
In particular, we can learn from what the company has agreed to do in these three areas with Alabama, Nevada and West Virginia, which include:
Lesson One - Age Verification Measures
- Verifying all users’ ages before allowing chat access
- Implementing facial age estimation technology/using government IDs for age confirmation
- Defaulting users who are under 16 to a “safe content” mode
Lesson Two - Parental Controls
- Giving parents the ability to select who their children interact with in chat
- Allowing parents to restrict their kids’ payment of in-game currency to trusted adults
- Monitoring users to identify those who might have given an incorrect age
Lesson Three - Restricting Adult interactions
- Fencing adults such that they cannot interact with children under 16 unless they are a “trusted friend”
- Requiring trusted friends to be verified through parental consent for children under 13
- Allowing children between 13 and 15 to add trusted friends through QR codes/phone importer
The company will also pay, collectively, almost $36 million to these states, with $12.2 million to Alabama, $10 million to Nevada, and $11 to West Virginia. It has also agreed to pay millions more to fund online safety awareness campaigns and liaison positions to address concerns on the platform.
Putting It Into Practice: These initial settlements suggest what we might see in the future with the pending investigations. For companies that interact with children online, including “mixed audience” sites, now is a good time to review age verification, parental control, and cross-age user interactions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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