"Over the past decade, Meta
—itself and through its flagship Social Media
Platforms Facebook and Instagram (its Social Media Platforms or Platforms)—has profoundly
altered the psychological and social realities of a generation of young Americans. Meta has
harnessed powerful and unprecedented technologies to entice, engage, and ultimately ensnare
youth and teens. Its motive is profit, and in seeking to maximize its financial gains, Meta has
repeatedly misled the public about the substantial dangers of its Social Media Platforms. It has
concealed the ways in which these Platforms exploit and manipulate its most vulnerable
consumers: teenagers and children.2
And it has ignored the sweeping damage these Platforms
have caused to the mental and physical health of our nation’s youth. In doing so, Meta engaged
in, and continues to engage in, deceptive and unlawful conduct in violation of state and federal
law"
