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`COMPLAINT AGAINST ROBLOX CORPORATION
`Sara D. Beller (Bar No. 316210)
`sara.beller@dolmanlaw.com
`Matthew A. Dolman (pro hac vice forthcoming)
`matt@dolmanlaw.com
`R. Stanley Gipe (pro hac vice forthcoming)
`stan.gipe@dolmanlaw.com
`DOLMAN LAW GROUP
`800 N. Belcher Rd.
`Clearwater, FL 33765
`Telephone: (727) 451-6900
`Facsimile: (727) 451-6907
`
`Attorneys for Plaintiff Jane Doe N.L. and Her Next Friend Jane Doe A.L.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`
`JANE DOE A.L., as guardian and next
`friend of minor plaintiff, JANE DOE N.L.,
`
`Plaintiff,
`
`v.
`
`ROBLOX CORPORATION,
`
`Defendant.
`Case No.:
`
`COMPLAINT
`
`(1) Fraudulent Concealment and
`Misrepresentations
`(2) Negligent Misrepresentation
`(3) Negligence – General
`(4) Negligence – Failure to Warn
`(5) Negligence – Unreasonable Design
`(6) Negligent Undertaking
`(7) Strict Liability – Design Defect
`(8) Strict Liability – Failure to Warn
`
`
`JURY TRIAL DEMANDED
`
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 1 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION i
`TABLE OF CONTENTS:
`I. INTRODUCTION ................................................................................................................. 1
`II. PARTIES ............................................................................................................................... 3
`A. Plaintiff ...................................................................................................................... 3
`B. Defendant .................................................................................................................. 3
`III. JURISDICTION AND VENUE ............................................................................................ 3
`IV. FACTUAL ALLEGATIONS AS TO ROBLOX .................................................................. 4
`A. Roblox Offers a Gaming App for Children. .............................................................. 4
`B. Roblox Lures Parents into Letting Their Kids Use Roblox with Promises of
`Safety. ........................................................................................................................ 8
`C. In Reality, Roblox Is a Digital and Real-Life Nightmare for Children. .................. 15
`1. Roblox hosts and promotes graphic, sexually explicit content. .................. 15
`2. Roblox provides a hunting ground for child-sex predators. ........................ 23
`D. Roblox Knowingly Causes and Facilitates the Sexual Exploitation of
`Children. .................................................................................................................. 31
`1. Roblox prioritizes growth over child safety. ............................................... 31
`2. Roblox facilitates child sexual exploitation through the design of its
`app, inadequate safety features, and refusal to invest in basic safety
`protections. .................................................................................................. 36
`3. Roblox’s recent safety changes are woefully inadequate and fail to
`address years of neglect and harm caused by its app. ................................. 45
`V. PLAINTIFF-SPECIFIC ALLEGATIONS .......................................................................... 51
`VI. CAUSES OF ACTION ....................................................................................................... 52
`FIRST CAUSE OF ACTION .............................................................................................. 52
`FRAUDULENT CONCEALMENT AND MISREPRESENTATIONS
`(By Plaintiff Against Defendant)
`
`SECOND CAUSE OF ACTION ......................................................................................... 54
`NEGLIGENT MISREPRESENTATION
`(By Plaintiff Against Defendant)
`
`THIRD CAUSE OF ACTION ............................................................................................ 55
`NEGLIGENCE – GENERAL
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 2 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION ii
`(By Plaintiff Against Defendant)
`
`FOURTH CAUSE OF ACTION ......................................................................................... 61
`NEGLIGENCE – FAILURE TO WARN
`(By Plaintiff Against Defendant)
`
`FIFTH CAUSE OF ACTION ............................................................................................. 65
`NEGLIGENCE – UNREASONABLE DESIGN
`(By Plaintiff Against Defendant)
`
`SIXTH CAUSE OF ACTION ............................................................................................. 68
`NEGLIGENT UNDERTAKING
`(By Plaintiff Against Defendant)
`
`SEVENTH CAUSE OF ACTION ...................................................................................... 70
`STRICT LIABILITY – DESIGN DEFECT
`(By Plaintiff Against Defendant)
`
`EIGHTH CAUSE OF ACTION .......................................................................................... 75
`STRICT LIABILITY – FAILURE TO WARN
`(By Plaintiff Against Each Defendant)
`
`VII. PRAYER FOR RELIEF ...................................................................................................... 78
`VIII. DEMAND FOR A JURY TRIAL ....................................................................................... 79
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 3 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION 1
` Jane Doe A.L., as guardian and next friend of minor Plaintiff Jane Doe N.L. (“Plaintiff”),
`brings this action against Roblox Corporation (“Roblox” or “Defendant”) to recover damages
`arising from the severe injuries that Plaintiff suffered because of Defendant’s conduct in creating,
`designing, marketing, and distributing its mobile- and web-based application (“app”), and alleges
`as follows:
`I. INTRODUCTION
`1. This action seeks to hold Roblox accountable for recklessly and deceptively
`operating its business in a way that led to the sexual exploitation of Plaintiff. The heinous acts
`against Plaintiff were committed by a dangerous child predator whose actions were possible only
`because of the egregiously tortious conduct of Defendant.
`2. Through its pervasive patterns of misrepresentations about safety, Defendant
`portrays its app as a safe and appropriate place for children to play. In reality, and as Defendant
`well knows, the design of its app makes children easy prey for pedophiles , and Defendant had no
`appropriate safeguards to ensure that children were in fact safe or that predators were screened .
`There are steps that Defendant could have taken to protect children and to make its app safer. But
`time and again Defendant has refused to invest in basic safety features to protect against exactly
`the kind of exploitation that Plaintiff suffered.
`3. The reason for Defendant ’s unlawful conduct is simple: Defendant prioritizes
`growing the number of users of its app over child safety. As one former Roblox employee explained
`in describing the company’s approach to child safety, “You have to make a decision, right? You
`can keep your players safe, but then it would be less of them on the platform. Or you just let them
`do what they want to do. And then the numbers all look good and investors will be happy.”
`1
`Defendant’s prioritization of growth over the safety of children has devastated the lives of children
`who use its app.
`
`1 Roblox: Inflated Key Metrics for Wall Street and a Pedophile Hellscape for Kids, Hindenburg
`Research (Oct. 8, 2024), https://hindenburgresearch.com/roblox/.
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 4 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION 2
`4. Plaintiff was an avid user of Defendant’s app for several years. She relied heavily
`on the app for entertainment and social interaction, making her a prime target for the countless
`child predators that Defendant knew were freely roaming the app looking for vulnerable children.
`5. Plaintiff was targeted on Roblox by a predator who posed as a fellow child and
`exploited Plaintiff’s age and vulnerability to build a false emotional connection with her by
`promising friendship and connection. After capturing her trust, the predator escalated his grooming
`of Plaintiff on Roblox. Through Roblox, he transitioned their interactions to text message, wherein
`the predator coerced and manipulated Plaintiff into sending explicit images of herself, including by
`giving her Robux—the virtual currency that drives Roblox’s online economy.
`6. Plaintiff suffered this sexual exploitation and abuse as the direct result of
`Defendant’s conduct. For years, Defendant has misrepresented and deliberately concealed
`information about the pervasive predatory conduct that its app enables and facilitate s. Had
`Defendant disclosed the truth of what was really occurring on its app , Plaintiff’s mother would
`never have permitted Plaintiff to use this app without her strict supervision. Had Defendant taken
`any steps to screen users before allowing them on the apps, Plaintiff would not have been exposed
`to the large number of predators trolling the platform. Had Defendant implemented even the most
`basic system of age and identity verification, as well as effective parental controls, Plaintiff would
`never have engaged with this predator and never been harmed.
`7. Plaintiff has suffered unimaginable harm. Her innocene has been snatched from her
`forever. Tragically, what happened to her is far from an isolated event. Indeed, Plaintiff is just one
`of countless children whose lives have been devastated as a result of Defendant’s gross negligence
`and defectively designed app This action, therefore, is not just a battle to vindicate Plaintiff’s
`rights—it is a stand against Defendant’s systemic failures to protect society’s most vulnerable from
`unthinkable harm in pursuit of financial gain over child safety.
`
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`COMPLAINT AGAINST ROBLOX CORPORATION 3
`II. PARTIES
`A. Plaintiff
`8. Minor Plaintiff Jane Doe N.L., and her mother and next friend Jane Doe A.L., are
`citizens and residents of the State of North Carolina, with a principal place of residence in Guilford
`County.
`9. Plaintiff has suffered profound and enduring harm. This includes significant
`emotional distress, psychological trauma, and mental anguish. Plaintiff’s experiences have led to a
`loss of trust, safety, and personal security, depriving her of the opportunity for a normal and healthy
`development. The injuries s he sustained are severe, ongoing, and permanent, affecting her daily
`life and emotional health in lasting and immeasurable ways.
`10. Plaintiff never entered into a ny contract with Defendant . To the extent Defendant
`claims that Plaintiff attempted to accept an electronic terms and conditions clause by clicking
`buttons on a screen that included language that Plaintiff did not read or understand, such an
`assertion is legally erroneous, invalid, and unenforceable , including because Plaintiff disaffirms
`any such contract, including any forced arbitration clause and any delegation clause in any contract.
`B. Defendant
`11. Defendant Roblox Corporation is a Delaware corporation with its principal place of
`business in San Mateo, California. Roblox owns, operates, controls, produces, designs, maintains,
`manages, develops, tests, labels, markets, advertises, promotes, supplies, and distributes the Roblox
`app. Roblox is widely available to consumers throughout the United States.
`III. JURISDICTION AND VENUE
`12. This Court has subject-matter jurisdiction over this action under 28 U.S.C. § 1332(a)
`because Plaintiff and Defendant are citizens of different states and the amount in controversy
`exceeds $75,000.
`13. This Court has personal jurisdiction over Defendant because it maintains its
`principal place of business within this District.
`14. Venue is proper here under 28 U.S.C. § 1391(b) because Defendant is a resident of
`California and resides in this District.
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 6 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION 4
`15. Divisional Assignment. Assignment to the San Francisco Division is proper under
`Civil L.R. 3-2(c) because Roblox is headquartered in San Mateo.
`IV. FACTUAL ALLEGATIONS AS TO ROBLOX
`A. Roblox Offers a Gaming App for Children.
`16. Launched in 2006, Roblox is an online gaming app that allows users to play myriad
`games, which the company refers to as “experiences.” There are currently more than 40 million
`experiences within the Roblox ecosystem. Most experiences on Roblox are created not by Roblox
`but by individuals (often Roblox users) or companies that develop their own games and make them
`available on Roblox for others to play.
`17. Roblox is easily accessible, including to children. It is free to download and play and
`is available on gaming consoles, computers, tablets, and cellular devices.
`18. Roblox is designed to be an interactive experience, allowing and encouraging users
`to communicate with each other. Gameplay interactions, user hubs, direct messaging, and voice chat
`all promote social interactions between users. Roblox’s co -founder and CEO David Baszucki has
`explained that his vision is for Roblox to bring about “the next phase of human interaction,” which
`he also has described as “a new category of human coexperience.”
`2 Roblox has similarly explained
`that it “operates a human co-experience platform . . . where users interact with each other to explore
`and develop immersive, user-generated, 3D experiences.”3
`19. Roblox designed its app for children. Roblox has marketed its app not only as the
`“#1 gaming site for kids and teens”4 but also as an educational experience for young users. Roblox
`claims that it provides “new gateways into learning” —from “chemistry to physics to robotics and
`more, Roblox experiences bring concepts to life in ways that immerse learners and motivate
`
`2 David Baszucki, Co-founder and CEO of Roblox, The CEO of Roblox on Scaling Community-
`Sourced Innovation, Har. Bus. Rev., The Magazine, (Mar-Apr 2022), https://hbr.org/2022/03/the-
`ceo-of-roblox-on-scaling-community-sourced-innovation.
`3 Roblox Corp., Quarterly Report (Form 10-Q) (Mar. 13, 2021).
`4 Roblox, What Is Roblox, http://web.archive.org/web/20170227121323/https://www.roblox.com/
`(archived Feb. 27, 2017).
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`COMPLAINT AGAINST ROBLOX CORPORATION 5
`exploration, play, and deep thinking.”5 These offerings, according to Roblox, include “high-quality,
`standards-aligned, immersive educational experiences designed by curriculum experts.”6
`
`Roblox webpage – “A New Era of Engaged Learning”
`20. Roblox’s popularity among children exploded during the pandemic when the app
`was flooded with millions of new users as kids were confined to their homes and glued to their
`devices. By September 2020, roughly 30 million people, more than half of them under 13, were on
`Roblox daily, making it the world’s biggest recreational zone for kids.
`21. That growth has continued unabated. In Roblox’s 2023 Annual Report, the company
`reported an average of 68.5 million daily active users, with 21% under 9 years of age; 21% from 9-
`12 years of age; 16% from 13-16 years of age; and 41% over 17 years of age.
`22. Today, Roblox is the most downloaded online game globally, and the average user
`spends 139 minutes a day on the app.
`7
`23. Individuals who wish to play Roblox must create an account. It is extremely easy to
`“SIGN UP AND START HAVING FUN!” Users must provide only a birthdate, username, and
`
`5 Roblox, A New Era of Engaged Learning, https://corp.roblox.com/education (last visited Feb.
`11, 2025).
`6 Id.
`7 Qustodio, Research by App Category – Gaming, https://www.qustodio.com/en/the-digital-
`dilemma/gaming/ (last visited Feb. 11, 2025).
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`COMPLAINT AGAINST ROBLOX CORPORATION 6
`password. Users of any age can create an account. There is no age minimum. Roblox does not
`require users to verify their age upon sign-up, so they can easily represent that they are younger or
`older than their actual age.
`
`Roblox Sign-up Screen
`
`24. Although Roblox states that children must have parental permission before signing
`up for an account, nothing prevents them from creating their own accounts and playing on Roblox.
`Roblox does nothing to confirm or document that parental permission has been given, no matter
`how young a child is. Nor does Roblox require a parent to confirm the age given when a child signs
`up to use Roblox.
`25. After creating an account, all users are assigned a default player avatar—a cartoonish
`character that represents the individual user within certain games.
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`COMPLAINT AGAINST ROBLOX CORPORATION 7
`
`Example default avatar on Roblox.
`26. They can then play in millions of experiences on the app. These games are sorted
`into different genres/categories, such as Sports, Role -Playing Games, Fighting, First Person
`Shooters, Fashion, Horror, Comedy, Military, and Naval. The games recommended to a user will
`vary based on the age the user entered when ge nerating their account and Roblox’s algorithm that
`recommends games to the user.
`
`Examples of games available on Roblox.
`27. Until November 2024, Roblox configured its app to default to settings that allowed
`adults to easily communicate with children. Adult strangers could “friend” and chat with a child of
`any age via direct ( i.e., private) message. Further, even without being “friends,” adults could also
`chat with a child of any age within a Roblox experience through direct messages.
`28. Now, under Roblox’s default settings, adults cannot directly message children under
`13, but Roblox still does nothing to prevent children this young from creating accounts with fake
`13+ birthdates, which gives them full access to Roblox’s direct -messaging options. Roblox still
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`COMPLAINT AGAINST ROBLOX CORPORATION 8
`relies on self -reported birthdates for age verification. Further, children 13 and over are still
`vulnerable to receiving friend requests—or direct messages within Roblox experiences—from adult
`strangers. There is also nothing that prohibits adults from entering fake birthdays and posing as
`children in their attempts to friend or otherwise communicate with children users.
`29. Roblox generates revenue largely by selling users an in-game digital currency called
`Robux, which they exchange for digital content such as online experiences and customized outfits
`and appearances for their avatars. Robux can be purchased in a single transaction or a user may
`subscribe to receive Robux on a recurring basis with a Roblox Premium membership. Roblox also
`offers Robux gift cards that anyone can purchase and send to any user.
`30. Children frequently become obsessed with purchasing or otherwise obtaining Robux
`to buy items for their avatars and to spend in their favorite experiences on Roblox. In Roblox’s
`Avatar Store, for example, the company sells rare items at astronomical prices , such as a type of
`hair for an avatar, which children seek to purchase to keep up with or outdo their peers on Roblox.
`As a result, children often tell others, including strangers, that they will do “Anything for Robux.”
`8
`B. Roblox Lures Parents into Letting Their Kids Use Roblox with Promises of
`Safety.
`31. Roblox’s success and continued growth have hinged on its constant, false assurances
`to parents that its app is safe for children. The company has offered such assurances throughout its
`history and in every forum possible —on its website, through public prom ises of its highest
`executives, in news articles, on podcasts, and on and on.
`32. Over the years, Roblox has repeatedly represented on its website that its app is safe
`for children and has touted the safety controls it has in place. As early as 2007, Roblox’s website
`assured parents that Roblox is an “online virtual playground . . . where kids of all ages can safely
`interact, create, have fun, and learn.”
`9
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`8 Olivia Carville & Cecilia D’Anastosio, Roblox’s Pedophile Problem, Bloomberg Businessweek
`(July 23, 2024), https://www.bloomberg.com/features/2024-roblox-pedophile-problem/.
`9 Roblox, Frequently Asked Questions (FAQs),
`
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`COMPLAINT AGAINST ROBLOX CORPORATION 9
`33. From 2008 to 2016, the website continued to promise parents, “We take every
`precaution possible to make sure kids are protected from inappropriate and offensive individuals as
`well as from indecent and distasteful content.” 10 It also assured parents that Roblox had a zero-
`tolerance policy for “swearing and obscenities, messages and content of a sexual or violent nature,
`and any sort of aggressive or threatening communication,” and “immediately suspended or
`permanently expelled” any offenders.
`11
`34. The website has consistently sought to paint Roblox as “family friendly” and safe for
`children of all ages. In 2017, Roblox began declaring that it “take[s] kids’ safety and privacy very
`seriously” and “strive[s] to continually develop new and innovative technologi es that will protect
`the safety of our community while allowing players to imagine, create, and play together in a family-
`friendly environment.”
`12 Roblox similarly has advertised its app as “a safe, moderated place to meet,
`play, chat, and collaborate on creative projects.”13
`
`https://web.archive.org/web/20071105104643/http://www.roblox.com/Parents/FAQs.aspx
`(archived Nov. 5, 2007).
`10 Roblox, Keeping Kids Safe,
`https://web.archive.org/web/20080501101437/http://www.roblox.com/Parents/KeepingKidsSafe.a
`spx (archived May 1, 2008); see also Roblox, Information for Parents,
`https://web.archive.org/web/20160131063648/http://corp.roblox.com/parents (archived Jan. 31,
`2016).
`11 Id.
`12 Roblox, Parents’ Guide,
`https://web.archive.org/web/20170716032712/https://corp.roblox.com/parents/ (archived Jul. 16,
`2017).
`13 Id.
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`COMPLAINT AGAINST ROBLOX CORPORATION 10
`
`Excerpt from Roblox Parent’s Guide in 2017
`35. Roblox’s website representations have remained largely unchanged since then. In
`2023, for example, Roblox assured parents that it “continually develop[s] cutting-edge technologies
`to ensure that the Roblox platform remains a safe and fun space for players all over the world.” 14
`Roblox claimed that the company was “dedicated to working together with parents and digital safety
`experts to promote a family-friendly environment that allows all players to imagine, create, and play
`online.”15 Roblox emphasized that it is “committed to ensur ing that Roblox is a safe and fun place
`for everyone.”16 According to Roblox, it “goes above and beyond to foster an environment where
`people of any age can create, play, learn, and imagine safely. We’ve kept children’s privacy and
`safety top-of-mind when designing our platform, especially through the implementation of advanced
`
`14 Roblox, For Parents,
`https://web.archive.org/web/20230405060048/https://corporate.roblox.com/parents/ (archived
`Apr. 5, 2023).
`15 Id.
`16 Roblox, Roblox FAQ,
`https://web.archive.org/web/20230328011957/https://corporate.roblox.com/faq/ (archived Mar.
`28, 2023).
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`COMPLAINT AGAINST ROBLOX CORPORATION 11
`text filters that block inappropriate language or other unsafe content.”17
`36. Roblox’s website today contains similar assurances. It claims, “Safety is in our DNA:
`when Dave Baszucki and Erik Cassel launched Roblox in 2006, they spent a few hours each day
`with the community, helping to ensure that Roblox was a safe and welcoming environment. Safety
`was their top priority, and they made constant improvements in their moderation, both for content
`and for communication on the platform.”
`18
`37. According to the current website, Roblox “won’t allow language that is used to
`harass, discriminate, incite violence, threaten others, or used in a sexual context.” 19 Roblox touts a
`“stringent safety system and policies,”20 which include its “expertly trained team with thousands of
`members dedicated to protecting our users and monitoring for inappropriate content”; its “safety
`review of every uploaded image, audio, and video file, using a combination of review by a large
`team of human moderators and machine detection before they become available on our platform”;
`and its chat filters for inappropriate content, which “are even stricter” for children under 13 and
`“include any potentially identifiable personal information, slang etc.”
` 21
`38. These false promises and assurances are not confined to Roblox’s website. They are
`repeated in statements by the company’s highest executives— including in direct response to
`concerns raised by parents.
`39. In 2009, a blogger wrote about blocking Roblox because he doubted its safety for his
`children. CEO David Baszucki responded to the blogger reassuring him that Roblox flags
`“obviously offensive content” and removes it, and if “something is marginal, but get s flagged as
`
`17 Roblox, Roblox & User Data FAQ, https://en.help.roblox.com/hc/en-
`us/articles/4406238486676-Roblox-User-Data-FAQ (last visited Feb. 11, 2025).
`18 Roblox, Safety Comes First on Roblox, https://corp.roblox.com/safety-civility-
`resources?section=news&article=safety-comes-first-on-roblox (last visited Feb. 11, 2025).
`19 Roblox, Safety Features: Chat, Privacy & Filtering, https://en.help.roblox.com/hc/en-
`us/articles/203313120-Safety-Features-Chat-Privacy-
`Filtering#:~:text=Players%20have%20different%20safety%20settings,and%20phrases%2%200tha
`n%20younger%20players (last visited Feb. 11, 2025).
`20 Roblox, Safety & Civility at Roblox, https://en.help.roblox.com/hc/en-
`us/articles/4407444339348-Safety-Civility-at-Roblox (last visited Feb. 11, 2025).
`21 Id.
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 14 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION 12
`inappropriate,” Roblox “investigate[s] immediately.”22
`40. In a 2013 Wired interview, when asked whether a parent should be concerned about
`whom his child was chatting with in-game, Baszucki declared, “We take every precaution possible
`to make sure kids are protected from inappropriate and offensive individuals as well as from
`indecent and distasteful content,” taking a sentence verbatim from Roblox’s webpage for parents.23
`41. Tami Bhaumik, Roblox’s current Vice President of Civility & Partnerships, has
`doubled down on these promises in statements to parenting magazines, news outlets, and podcasts—
`all aimed at persuading parents to let their children use Roblox. She also has contacted international
`online safety experts in an effort to sell Roblox’s safety story.
`42. As recently as 2024, Bhaumik told Parents Magazine that “[w]e have a responsibility
`to make sure our players can learn, create, and play safely. This continues to be our most important
`priority and that will never change.”
`24
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`43. Such statements by Bhaumik date back years. In 2018, Bhaumik told the Washington
`
`22 Eric Frenchman, Revisiting Roblox, Pardon My French (Oct. 5, 2009),
`https://pardonmyfrench.typepad.com/pardonmyfrench/2009/10/revisiting-roblox.html.
`23 Tony Sims, Interview with David Baszucki, Founder & CEO of Roblox, Wired (Feb. 7, 2013),
`https://www.wired.com/2013/02/roblox/.
`24 Maressa Brown, Is Roblox Safe for Kids? Here’s What the Experts Have to Say, Parents
`Magazine (Apr. 29, 2024), https://www.parents.com/kids/safety/internet/is-roblox-safe-forkids/.
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 15 of 82
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`COMPLAINT AGAINST ROBLOX CORPORATION 13
`Post that Roblox “focus[es] on making sure that everything is done in a safe and appropriate way.”25
`That year, she also claimed to another newspaper that Roblox’s “safety team reviews every uploaded
`image, video, and audio file used within our games to make sure they are safe and age appropriate.”26
`She also boasted that Roblox has “created extensive parental controls for our games and a detailed
`Roblox Parent’s Guide that provides information to parents to help create a Roblox experience that’s
`best for their child.”
`27
`44. In 2019, while presenting on a “Digital Civility Panel,” Bhaumik emphasized that
`“[w]e make sure there’s a safe environment,” citing Roblox’s “tremendous reporting system” and
`“incredible moderation and CS team that reacts very, very quickly.”
`28 On that same panel—and in
`contradiction to Roblox’s representation that it had always taken “every precaution possible” to
`protect children—Bhaumik conceded that “digital civility did not exist at Roblox a year and a half
`ago and we established this and made it a movement within our company.”
`29 She added later, “It’s
`still very early days for us. This whole digital civility focus for Roblox is still there, we’re just still
`establishing it.”
`30
`45. In a 2022 video interview about safety on Roblox, Bhaumik asserted that Roblox’s
`“number one priority” is “to create a safe, civil, and inclusive community” and that “[s]afety and
`civility has always been baked into everything that we do.”
`31 That year, on a podcast, she also
`
`25 Hayley Tsukayama, Roblox, an Online Kids Game, Explains How a Hack Allowed a
`Character’s Virtual ‘Rape’, Wash. Post. (Jul. 17, 2018),
`https://www.washingtonpost.com/technology/2018/07/17/roblox-an-online-kids-game-explains-
`how-hack-allowed-characters-virtual-rape/.
`26 Chris Pollard, Police Warn that Children as Young as Five-Years-Old are Seeing Naked Lego-
`Type Characters Having Sex on Roblox App, The Sun (Jan. 29, 2018),
`https://www.thesun.co.uk/news/5445444/roblox-app-children-danger-sex-warning/.
`27 Id.
`28 YouTube, Digital Civility Panel (Oct. 23, 2019),
`https://www.youtube.com/watch?v=XoUs1Js7WG0&list=PLcKphP00N1_kCLjvcOWdwbegJkNS
`L-CuL&index=6.
`29 Id.
`30 Id.
`31 Video Interview with Tami Bhaumik, Roblox’s VP of Digital Civility & Partnerships (2022),
`https://www.facebook.com/bedford.sheriff/videos/roblox-how-to-help-kids-use-itsafelyrobloxs-
`vp-of-digital-civility-partnerships/1338989609901259/.
`Case 3:25-cv-07676-SK Document 1 Filed 09/09/25 Page 16 of 82
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