IN RE: SOCIAL MEDIA ADOLESCENT ADDICTION/PERSONAL INJURY PRODUCTS LIABILITY LITIGATION

4:22-md-03047Cand3 giu 2026

Testo completo

UNITED STATES JUDICIAL PANEL
on
MULTIDISTRICT LITIGATION
IN RE: SOCIAL MEDIA ADOLESCENT ADDICTION/
PERSONAL INJURY PRODUCTS LIABILITY
LITIGATION 	MDL No. 3047
IN RE: ROBLOX CORPORATION CHILD SEXUAL
EXPLOITATION AND ASSAULT LITIGATION 	MDL No. 3166
ORDER DENYING TRANSFER
Before the Panel: 	Defendants TikTok Inc., TikTok LLC, and ByteDance Inc. (together,
the TikTok defendants) in the Eastern District of Kentucky Seitz action listed on the attached
Schedule A move under 28 U.S.C. § 1407(c) to transfer the action to the Northern District of
California for inclusion in MDL No. 3047, In re Social Media Adolescent Addiction/Personal
Injury Products Liability Litigation (the Social Media Addiction MDL). Alternatively, the TikTok
defendants ask that we transfer the claims against them to MDL No. 3047 and separate and remand
the remaining claims. Defendant Discord Inc. opposes transfer of the claims against it to MDL
No. 3047. Defendant Roblox Corporation does not oppose transfer of all claims to MDL No. 3047
or the alternative suggestion to separate and remand the claims against Roblox and Discord.
Plaintiff agrees that the claims against the TikTok defendants should be transferred to MDL No.
3047 and opposes transfer of the claims against defendants Roblox and Discord to that MDL;
plaintiff moves to transfer those claims to the Northern District of California for inclusion in MDL
No. 3166, In re Roblox Corporation Child Sexual Exploitation and Assault Litigation (the Roblox
MDL). 	Roblox and Discord, joined by interested parties Snap, Inc., and Meta Platforms, Inc.,
oppose plaintiff’s motion. In response to plaintiff’s motion, the TikTok defendants maintain the
position taken in their motion for transfer. Together, the motions require that we decide whether
the Seitz action, or any part of it, should be transferred to the Social Media Addiction MDL or to
the Roblox MDL, or not transferred at all. 	Given the relatively unique allegations of the Seitz
complaint concerning “grooming for violence,” we choose the latter option.
I. Background of MDL Nos. 3047 and 3166
The actions in the Social Media Addiction MDL “present common factual questions arising
from allegations that defendants’ social media platforms are defective because they are designed
to maximize user screen time, which can encourage addictive behavior in adolescents.” 	In re
Judge Karen K. Caldwell and Madeline Cox Arleo did not participate in the decision of this
matter.
Case KYE/2:25-cv-00166 	Document 26 	Filed 06/03/26 	Page 1 of 5
FILED
Mark B. Busby
CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND
Jun 03 2026
Case 4:22-md-03047-YGR Document 3098 Filed 06/03/26 Page 1 of 5
-2-
Social Media Adolescent Addiction/Personal Injury Prods. Liab. Litig., 637 F. Supp. 3d 1377,
1378 (J.P.M.L. 2022). 	Plaintiffs in the MDL allege defendants were aware that their platforms
were harmful to minors but failed to warn the public. 	See id. 	Plaintiffs also allege that the
platforms fail to verify age, encourage adolescents to bypass parental controls, inadequately
safeguard against harmful content, and intentionally amplify harmful and exploitive content. Id.
We centralized the litigation in 2022 before Judge Yvonne Gonzalez Rogers in the Northern
District of California.
Plaintiffs in the Roblox MDL allege that “they (as minors), or their minor children, were
sexually exploited and, in some cases, assaulted by child predators who targeted and groomed
them through the Roblox gaming platform.” 	See In re Roblox Corp. Child Sexual Exploitation
and Assault Litig., 812 F. Supp. 3d 1355, 1356 (J.P.M.L. 2025). Plaintiffs contend that, “having
established a connection with the minor plaintiffs on Roblox, the predators then persuaded the
minors to continue their interactions, and often to exchange sexually explicit images, on a second
platform such as Discord, Snapchat, or Instagram, or via texting or video-calling on a cellular
phone.” Id. In December 2025, we centralized the litigation in the Northern District of California
before Judge Richard Seeborg.
After considering the argument of counsel, we conclude that transfer under 28 U.S.C.
§ 1407 to either MDL will not serve the convenience of the parties and witnesses or further the
just and efficient conduct of the litigation. Plaintiff in the Seitz action alleges that, while using the
Roblox platform, her daughter was exposed to material encouraging violence and homophobia,
and that she ultimately was pressured into committing suicide. She alleges that the “grooming for
violence” was also conducted on Discord and TikTok.
II. Plaintiff’s Motion to Transfer to the Roblox MDL (No. 3166)
Turning first to the motion for transfer to the Roblox MDL, plaintiff argues that the Roblox
and Discord claims overlap with the MDL because, like the MDL plaintiffs, she alleges that her
child was groomed and exploited by predators on Roblox and that the grooming and exploitation
continued via Discord. She further maintains that transfer is appropriate because discovery will
overlap as to the lack of adequate safety features on the Roblox and Discord apps and defendants’
failure to warn of the risks they pose. She notes that all claims asserted against Roblox and Discord
thus far in MDL No. 3047 have been stayed and no discovery has been conducted.
Roblox and Discord argue that none of the claims in the Seitz action fall within the scope
of the Roblox MDL as defined in the Panel’s initial transfer order because plaintiff does not allege
that her child was sexually exploited or assaulted. 	They contend that Seitz will not involve
common discovery with the MDL because Seitz will focus on defendants’ alleged failure to
monitor for and filter out violence-related material, whereas discovery in the MDL will focus on
defendants’ supposed failure to monitor for and screen out sexually-oriented content. Defendants
urge the Panel to maintain the “fence” that it established when it created the MDL, limiting its
scope to actions involving sexual exploitation or assault, and they argue that expanding the MDL’s
scope would result in an unwieldy and unmanageable MDL.
Case KYE/2:25-cv-00166 	Document 26 	Filed 06/03/26 	Page 2 of 5	Case 4:22-md-03047-YGR Document 3098 Filed 06/03/26 Page 2 of 5
-3-
We conclude that Seitz is not properly included in MDL No. 3166. As plaintiff concedes,
the Seitz action includes no allegations that plaintiff’s daughter was sexually exploited through the
Roblox platform or sexually assaulted by a predator whom she encountered on the platform. There
may be some degree of overlap in the discovery in Seitz and the MDL, as both will focus on Roblox
and Discord’s allegedly inadequate parental controls, safety features, and warnings regarding
potential risks to children, but we are not persuaded that this is sufficient reason to expand the
scope of the MDL as plaintiff suggests. Including cases that do not involve sexual exploitation,
predation, or assault could result in an overly broad MDL involving any plaintiff injured by
exposure to objectionable content on Roblox. Such an MDL would be unduly complicated and
difficult to manage.
III. TikTok’s Motion to Transfer to the Social Media Addiction MDL (No. 3047)
As for whether to include Seitz in the Social Media Addiction MDL, we are presented with
requests to transfer all or part of the action. As an initial matter, we do not find separation and
remand of the claims against Discord and Roblox to be appropriate here. 	We have found that
“[w]hether Section 1407(a) remand is available turns on a highly specific inquiry about how each
complaint is pled.” In re MOVEit Customer Data Sec. Breach Litig., 699 F. Supp. 3d 1402, 1406
n.6 (J.P.M.L. 2023). Each claim in Seitz is brought “against each defendant,” and plaintiff alleges
an indivisible injury, asserting that defendants are “jointly and severally responsible for the injuries
caused by any one of Defendants’ apps.” Seitz Am. Compl. at ¶¶ 277, 296, 319, 339, 365, 384.
Section 1407(a) grants the Panel authority to “separate any claim,” but it “does not authorize the
Panel to transfer one issue raised by a claim … while remanding another issue raised by the same
claim.” 	In re Nat’l Prescription Opiate Litig., 576 F. Supp. 3d 1378, 1381 (J.P.M.L. 2021)
(quoting In re Air Crash Disaster at Duarte, Cal. on June 6, 1971, 346 F. Supp. 529, 530 (J.P.M.L.
1972)). While we occasionally have separated and remanded cases on a per-defendant basis, we
have found that, where the underlying claims appear indivisible, separating and remanding such
claims may be “impracticable.” 	See id. at 1380; In re Soc. Media, 637 F. Supp. 3d at 1379
(“Opposing defendants alternatively request the Panel separate and remand the claims against them
to their transferor courts. 	We decline to do so, as plaintiffs allege common indivisible injuries
from multiple products, and severance and remand would complicate the litigation by multiplying
each plaintiff’s claims across different courts.”).
Viewing Seitz in its entirety, we do not find that including it in the Social Media Addiction
MDL would promote the just and efficient conduct of either Seitz or the actions in the MDL. We
find that any common discovery and pretrial proceedings between Seitz and the Social Media
Addiction MDL actions will be overshadowed by unique issues involving unrelated parties,
platforms, and claims. 	Plaintiff’s complaint is rooted in purportedly violent content allegedly
promoted to plaintiff’s daughter by three groups of defendants, only one of which (TikTok) is an
active defendant in the MDL. 	A small portion of plaintiff’s complaint alleges that TikTok is
designed to be addictive to adolescents, but TikTok’s conduct in that regard has a somewhat
tenuous connection to her claims. 	Plaintiff alleges that this conduct is part of TikTok’s
“engagement strategy,” to maximize user engagement and time spent on the platform, and that the
Case KYE/2:25-cv-00166 	Document 26 	Filed 06/03/26 	Page 3 of 5	Case 4:22-md-03047-YGR Document 3098 Filed 06/03/26 Page 3 of 5
-4-
resulting addiction knowingly makes children more susceptible to violent content. 1 While plaintiff
may seek some discovery relating to allegations that TikTok is designed to be addictive to
adolescents and that TikTok was incentivized to maximize users’ time spent on the platform,
plaintiff’s allegations are overwhelmingly focused on the promotion of violent content and the
encouragement of violence and self-harm. Plaintiff does not allege her daughter was addicted to
social media or spent excessive amounts of time on TikTok. While Seitz also includes allegations
that are at issue in other Social Media Addiction MDL actions—including that TikTok fails to
verify users’ ages, encourages adolescents to bypass parental controls, and inadequately safeguards
against and amplifies harmful and exploitive content—we have endeavored from the start to limit
this MDL to cases in which plaintiffs base their claims on allegations that social media platforms
were designed to be addictive to minors. Seitz is a clear outlier.
IT IS THEREFORE ORDERED that the motions for transfer of the action listed on
Schedule A are DENIED.
PANEL ON MULTIDISTRICT LITIGATION
_______________________________________
Matthew F. Kennelly
Acting Chair
David C. Norton 	Dale A. Kimball
M. Casey Rodgers
1 	See Seitz &RPSODW၁၁-06 (“It is precisely these young users’ heightened sensitivity to
rewards and stimuli that makes them both ideal targets for advertising and acutely susceptible to
rabbit holes of harmful content. TikTok takes advantage of both phenomena and seeks to capture
the attention of their minor users by amplifying content that plays heavily on users’ emotions,
regardless of whether they are positive or self-destructive.”).
Case KYE/2:25-cv-00166 	Document 26 	Filed 06/03/26 	Page 4 of 5	Case 4:22-md-03047-YGR Document 3098 Filed 06/03/26 Page 4 of 5
IN RE: SOCIAL MEDIA ADOLESCENT ADDICTION/
PERSONAL INJURY PRODUCTS LIABILITY
LITIGATION 	MDL No. 3047
IN RE: ROBLOX CORPORATION CHILD SEXUAL
EXPLOITATION AND ASSAULT LITIGATION 	MDL No. 3166
SCHEDULE A
Eastern District of Kentucky
SEITZ v. ROBLOX CORPORATION, ET AL., C.A. No. 2í00166
Case KYE/2:25-cv-00166 	Document 26 	Filed 06/03/26 	Page 5 of 5	Case 4:22-md-03047-YGR Document 3098 Filed 06/03/26 Page 5 of 5

Continua la tua ricerca in ChatGPT o Claude

Collega Omnilex per cercare nel corpus legale dal tuo assistente IA.