- States are using UDTP authority to drive platform design changes. The settlements require concrete operational steps — such as age verification, safer defaults and limits on adult-to-child communications — without waiting for new legislation.
- Settlement terms vary, and some include enforcement leverage. Differences include how states fund safety initiatives and whether agreements contain most-favored-nation clauses or additional damages for noncompliance.
- Roblox outcomes may set a baseline for future AG actions on kids’ safety and AI. Regulators may treat the settlements as a template for other platforms, especially as states expand scrutiny of how emerging technologies intersect with harms to minors.
Media Mention
Use of UDTP Laws in Roblox Settlements Offer Multiple Ways to Protect Minors, Lawyers Say
Privacy Daily
August 26, 2026Estimated Read Time: 1 min
Key Takeaways
Liisa Thomas was quoted in the Privacy Daily article, “Use of UDTP Laws in Roblox Settlements Offer Multiple Ways to Protect Minors, Lawyers Say” about how state attorneys general are increasingly using unfair and deceptive trade practice laws to pressure online platforms to change how they handle children’s safety, a strategy now reflected in a string of settlements with Roblox. Rather than pursuing new legislation that can face constitutional and other court challenges, the settlements use existing consumer-protection authority to require operational changes, including age verification and safer default content controls.
Five states — South Dakota, Alabama, Nevada, West Virginia and Mississippi — have reached agreements with Roblox that include penalties ranging from about $11 million to $15 million and mandates affecting how minors access and interact on the platform. Thomas said the settlements reflect a broader trend of regulators pushing platforms to modify product design and default settings, rather than relying primarily on parental involvement. She also pointed to state-by-state differences, including how settlement funds are directed and the inclusion in some states of most-favored-nation provisions that allow those states to benefit from better terms Roblox later offers elsewhere.
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