Concord, NH – New Hampshire Attorney General John M. Formella today announced the public release of the State’s unredacted complaint against Meta Platforms, Inc. and Instagram, LLC.  New Hampshire filed its lawsuit against Meta on October 24, 2023, as part of a bipartisan coalition of 41 attorneys general who filed lawsuits in state and federal courts across the country alleging that Meta intentionally designed and deployed harmful features on Instagram and Facebook that addict children and teens to their mental and physical detriment.  As originally filed, significant portions of the complaint included information that was redacted from public view.  Removing the redactions provides additional context for the misconduct New Hampshire alleges against Meta based on the company’s own documents.

“The people of New Hampshire can now see that Meta’s own documents acknowledge the harms its platforms inflict on kids,” said Attorney General Formella.  “Meta not only knows that its products exploit the vulnerabilities of children’s developing brains, it actively studies the most effective ways to ‘hack’ the brain chemistry of children for profit.  We will continue to prosecute this matter to stop Meta’s unlawful conduct and protect New Hampshire’s kids.”

Highlights from the newly unredacted portions of the complaint include:

• Two thirds of New Hampshire residents are active monthly users of Facebook and more than half are active monthly users of Instagram.  Complaint ¶ 27.
• Meta made over $540,000,000 in ad revenue from users that Meta tracks as having ties to New Hampshire in 2023 alone.  Complaint ¶ 40.
• Meta studies teen psychology and brain development and intentionally designs its products to exploit teen sensitivity to dopamine to encourage and promote compulsive, passive use of its platforms.  Complaint ¶¶ 122-28.
• Even as it represents to Congress that user well-being is a top priority, Meta continues to implement design elements that promote the passive use of its platforms to increase profits despite knowing that passive use is bad for users.  Complaint ¶¶ 138, 144, 206.
• Mark Zuckerberg unilaterally vetoed Meta’s plan to ban photo filters that simulate the effects of plastic surgery despite consensus among Meta employees and outside experts that the filters harm user mental health and, in the company’s own words, are “actively encouraging young girls into body dysmorphia.”  Complaint ¶¶ 222-31.
• Meta publicly touted misleading statistics about the safety of its platforms while hiding internal statistics that revealed higher instances of harmful experiences, with Meta’s former Director of Integrity calling the company’s practices “distorted” and “misleading,” and saying that Meta was “minimizing the harms that people are experiencing in the product.”  Complaint ¶¶ 147-65.

For the full Complaint, click here.