Case: 1:22-cv-02968 Document #: 1 Filed: 06/07/22 Page 1 of 96 PageID #:1
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`VIRGINIA ROTH, individually and as next
`friend to minor J.R.,
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` Plaintiff,
`v.
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`META PLATFORMS, INC.,
`FACEBOOK HOLDINGS, LLC,
`FACEBOOK OPERATIONS, LLC,
`FACEBOOK PAYMENTS, INC.,
`FACEBOOK TECHNOLOGIES, LLC,
`INSTAGRAM, LLC, AND
`SICULUS, INC.,
`
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` Defendants.
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`COMPLAINT
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`JURY TRIAL DEMANDED
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`Case: 1:22-cv-02968 Document #: 1 Filed: 06/07/22 Page 2 of 96 PageID #:2
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`I.
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`II.
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`III.
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`IV.
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`V.
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`VI.
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`TABLE OF CONTENTS
`INTRODUCTION .........................................................................................................1
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`JURISDICTION AND VENUE ....................................................................................5
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`PARTIES .......................................................................................................................6
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`GENERAL FACTUAL ALLEGATIONS .....................................................................8
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`A.
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`B.
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`C.
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`Teenagers Are Particularly Vulnerable to the Perils of Excessive
`Social Media Use. ..............................................................................................8
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`Meta Knowingly Exploits Teenage Vulnerabilities for Unjust Gain...............15
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`Plaintiff Expressly Disclaims Any and All Claims Seeking to Hold
`Defendants Liable as the Publisher or Speaker of Any Content
`Provided, Posted, or Created by Third Parties. ................................................21
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`PLAINTIFF-SPECIFIC ALLEGATIONS ..................................................................21
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`CAUSES OF ACTION ................................................................................................23
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`VII. TIMELINESS AND TOLLING OF STATUTES OF LIMITATIONS ......................92
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`VIII. DEMAND FOR A JURY TRIAL ...............................................................................93
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`IX.
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`PRAYER FOR RELIEF ..............................................................................................93
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`I.
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`INTRODUCTION
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`Over the last two decades, more and more of our lives have moved onto social
`1.
`media platforms and other digital public spaces. In this vast, still largely unregulated universe of
`digital public spaces, which are privately owned and primarily run for profit, there exists tension
`between what is best for technology companies’ profit margins and what is best for the individual
`user (especially the predictable adolescent user) and for society. Business models are often built
`around maximizing user engagement, not to ensure that users engage with the platform and one
`another in safe and healthy ways. Technology companies focus on maximizing time spent, not
`time well spent. In recent years, there has been growing concern about the impact of digital
`technologies, particularly social media, on the mental health and wellbeing of adolescents. Many
`researchers argue that social media facilitates cyberbullying, contributes to obesity and eating
`disorders, instigates sleep deprivation to achieve around-the-clock platform engagement,
`encourages children to negatively compare themselves to others and develop a broad
`discontentment for life, and has been connected to depression, anxiety, self-harm, and ultimately
`suicide ideation, suicide attempts, and completed suicide.
`This matter arises from an egregious breach of the public trust by Defendant Meta
`2.
`Platforms, Inc. (“Meta”). Meta was originally incorporated in Delaware on July 29, 2004, as
`“TheFacebook, Inc.” On September 20, 2005, the company changed its name to “Facebook, Inc.”
`On October 28, 2021, the company assumed its current designation. While Plaintiff has attempted
`to identify the specific Meta subsidiary(s) that committed each of the acts alleged in this
`Complaint, Plaintiff was not always able to do so, in large part due to ambiguities in Meta’s and
`its subsidiaries’ own documents, public representations, and lack of public information. However,
`upon information and belief, Meta oversees the operations of its various platforms and
`subsidiaries, some of which have been identified and are listed below. For this reason, unless
`otherwise specified, the shorthand “Meta” contemplates the apparent control that Defendant Meta
`Platforms, Inc. wields over the subject social networks’ overall operations and, therefore, further
`refers to its various subsidiaries and predecessors. To the extent this assumption is incorrect, the
`knowledge of which Meta subsidiary, current or former, is responsible for specific conduct is
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`knowledge solely within Defendants’ possession, the details of which Plaintiff should be
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`permitted to elucidate during the discovery phase.
`Meta knowingly exploited its most vulnerable users—children throughout the
`3.
`world—to drive corporate profit. Meta operates the world’s largest family of social networks,
`enabling billions of users worldwide to connect, view, and share content through mobile devices,
`personal computers, and virtual reality headsets. A user does not have to pay to create an account.
`Instead of charging account holders to access the platform, Meta became one of the world’s most
`valuable companies from the sale of advertisement placements to marketers across its various
`platforms and applications. For example, upon information and belief, Meta generated $69.7
`billion from advertising in 2019, more than 98% of its total revenue for the year. Meta can
`generate such revenues by marketing its user base to advertisers. Meta collects and analyzes data
`to assemble virtual dossiers on its users, covering hundreds if not thousands of user-specific data
`segments. This data collection and analysis allows advertisers to micro-target advertising and
`advertising dollars to very specific categories of users, who can be segregated into pools or lists
`using Meta’s data segments. Only a fraction of these data segments come from content that is
`explicitly designated by users for publication or explicitly provided by users in their account
`profiles. Many of these data segments are collected by Meta through surveillance of each user’s
`activity on the platform and off the platform, including behavioral surveillance that users are not
`even aware of, like navigation paths, watch time, and hover time. At bottom, the larger Meta’s
`user database grows, the more time the users spend on the database, and the more detailed
`information that Meta can extract from its users, the more money Meta makes.
`Defendants have intentionally designed their products to maximize users’ screen
`4.
`time, using complex algorithms designed to exploit human psychology and driven by advanced
`computer algorithms and artificial intelligence available to two of the largest technology
`companies in the world. Defendants have progressively modified their products to promote
`problematic and excessive use that they know threatens the actuation of addictive and self-
`destructive behavioral patterns.
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`and
`(“Facebook”)
`the www.Facebook.com
`products,
`Two Meta
`5.
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`www.Instagram.com (“Instagram”) websites and respective interrelated apps (collectively “Meta
`2”), rank among the most popular social networking products, with more than two billion
`combined users worldwide. It is estimated that nine out of ten teens use social media platforms,
`with the average teen using the platforms roughly three hours per day. Given the delicate,
`developing nature of the teenage brain and Meta’s creation of social media platforms designed to
`be addictive, it comes as no surprise that we are now grappling with the ramifications of Meta’s
`growth-at-any-cost approach, to wit, a generation of children physiologically entrapped by
`products the effects of which collectively result in long-lasting adverse impact on their rapidly
`evolving and notoriously precarious mental health.
`As of October 2021, Facebook had roughly 2.91 billion monthly active users, thus
`6.
`reaching 59% of the world’s social networking population, the only social media platform to reach
`over half of all social media users. Instagram has become the most popular photo sharing social
`media platform amongst teenagers and young adults in the United States, with over 57 million
`users below the age of eighteen, meaning that 72 percent of America’s youth use Instagram.
`A user’s “feed” on both Facebook and Instagram is comprised of an endless series
`7.
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`of photos, videos, text captions, and comments posted by accounts that the user follows, along
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`with advertising and content specifically selected and promoted by Instagram and Facebook.
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`8.
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`Instagram also features a “discover” page where a user is shown an endless feed of
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`content that is selected by an algorithm designed by Instagram based upon the users’ data profile:
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`demographics, prior activity in the platform, and other data points. Meta has added similar features
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`to Facebook on the apps “menu” and “watch” sections.
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`9.
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`Over the past decade or so, Meta has added features and promoted the use of auto-
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`playing short videos and temporary posts on Facebook and Instagram, with the former being
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`referred to as “Reels” while the latter is referred to as Instagram “Stories.”
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`10.
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`Facebook and Instagram notify users through text and email of activity that might
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`be of interest, which is designed to and does prompt users to open Facebook and Instagram and be
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`exposed to content selected by the platforms to maximize the length of time and amount of content
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`viewed by the user. Facebook and Instagram include many other harm causing features, as
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`discussed below.
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`11.
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`Plaintiff brings claims of strict liability based upon Defendants’ defective design of
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`their social media products that renders such products not reasonably safe for ordinary consumers
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`in general and minors in particular. It is technologically feasible to design social media products
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`that substantially decrease the incidence and magnitude of harm to ordinary consumers and minors
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`arising from their foreseeable use of Defendants’ products with a negligible increase in production
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`cost.
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`12.
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`Plaintiff also brings claims for strict liability based on Defendants’ failure to
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`provide adequate warnings to minor users and their parents of the danger of mental, physical, and
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`emotional harms arising from the foreseeable use of their social media products.
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`13.
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`Plaintiff also brings claims for common law negligence arising from Defendants’
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`unreasonably dangerous social media products and their failure to warn of such dangers.
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`Defendants knew or, in the exercise of ordinary care, should have known that their social media
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`products were harmful to a significant percentage of their minor users and failed to re-design their
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`products to ameliorate these harms or warn minor users and their parents of dangers arising out of
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`the foreseeable use of their products. Defendants intentionally created an attractive nuisance to
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`children, but simultaneously failed to provide adequate safeguards from the harmful effects they
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`knew were occurring.
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`14.
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`The addictive qualities of Defendants’ products and their harmful algorithms are
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`not fully known or appreciated by minor users or their parents. Like others, Plaintiff only recently
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`learned the truth about Meta’s increasingly detrimental effect on teenagers when Frances Haugen,
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`a former Facebook employee turned whistleblower, came forward with internal documents
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`showing that Meta was aware that its platforms and products cause significant harm to its users,
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`especially children. Rather than making meaningful changes to safeguard the health and safety of
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`its adolescent users, Meta has consistently chosen to prioritize profit over safety by continuing to
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`implement and require its users to submit to product components that increase the frequency and
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`duration of users’ engagement, resulting in the pernicious harms described in greater detail below.
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`II.
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`JURISDICTION AND VENUE
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`15.
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`This Court has subject-matter jurisdiction over this case under 28 U.S.C. § 1332(a)
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`because the amount in controversy exceeds $75,000 and Plaintiff and Defendants are residents of
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`different states.
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`16.
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`This Court has specific personal jurisdiction over Defendants Facebook and
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`Instagram because these Defendants transact business in the State of Illinois and purposely avail
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`themselves of the benefits of transacting business with Illinois residents. Plaintiff’s claims set forth
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`herein arise out of and/or relate to Defendants’ activities in the State of Illinois and purposeful
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`availment of the benefits of transacting business here and the exercise of personal jurisdiction by
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`this Court comports with traditional notions of fair play and substantial justice.
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`17.
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`Defendants interface with a significant percentage of the population of the State of
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`Illinois relating to use of the products at issue in this case, and interact extensively with—send
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`messages, notifications, and communications to—and provide a myriad of other interactive
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`services and recommendations to users Defendants expect and know to be in the State of Illinois.
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`18.
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`Defendants advertise extensively in Illinois, through contractual relationships with
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`third-party “partners” who advertise on their behalf via electronic and internet-based platforms and
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`devices. Meta also has agreements with cell phone manufacturers and/or providers and/or retailers,
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`who often pre-install its products on mobile devices prior to sale and without regard to the age of
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`the intended user of each such device. That is, even though Defendants are prohibited from
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`providing their products to users under the age of 13, by encouraging and allowing its product to
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`be installed indiscriminately on mobile devices, it actively promotes and provides access to its
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`product to the underage users in Illinois for whom those devices are intended.
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`19.
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`Defendants have earned millions of dollars in annual revenue from their Illinois-
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`related activities over the last several years arising from their defective and inherently dangerous
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`social media products by Illinois residents, including Plaintiff.
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`20.
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`Venue is proper in this District under 28 U.S.C. § 1391(b)(2) because a substantial
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`part of the events or omissions giving rise to Plaintiff’s claims occurred in the Northern District of
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`Illinois.
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`Plaintiff
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`III.
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`PARTIES
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`21.
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`Plaintiff Virginia Roth is an individual residing in Bloomingdale, Illinois, and the
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`mother and custodial parent of her sixteen-year-old daughter J.R. Plaintiff brings this suit on behalf
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`of herself and on behalf of J.R., pursuant to FED. R. CIV. P. 17.
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`Defendant Meta Platforms, Inc.
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`22. Meta is a Delaware corporation and multinational technology conglomerate,
`having its principal place of business in Menlo Park, California.
`23. Meta develops and maintains social media platforms, communication platforms,
`and electronic devices. These platforms and products include Facebook (its self-titled app,
`Messenger, Messenger Kids, Marketplace, Workplace, etc.), Instagram (and its self-titled app),
`and a line of electronic virtual reality devices called Oculus Quest (soon to be renamed “Meta
`Quest”). Meta’s subsidiaries include, but may not be limited to: Facebook Holdings, LLC
`(Delaware); Facebook Operations, LLC (Delaware); Facebook Payments Inc. (Delaware);
`Facebook Technologies, LLC (Delaware); FCL Tech Limited (Ireland); Instagram, LLC
`(Delaware); Novi Financial, Inc. (Delaware); Runways Information Services Limited (Ireland);
`Scout Development LLC (Delaware); Siculus, Inc. (Delaware); and a dozen other entities whose
`identity or relevance is presently unclear.
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`Subsidiary Defendants
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`24.
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`Facebook Holdings, LLC (“Facebook 1”) was incorporated in Delaware on March
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`11, 2020, and is a wholly owned subsidiary of Meta Platforms, Inc. Facebook 1 is primarily a
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`holding company for entities involved in Meta’s supporting and international endeavors, and its
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`principal place of business is in Menlo Park, California.
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`25.
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`Facebook Operations, LLC (“Facebook 2”) was incorporated in Delaware on
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`January 8, 2012, and is a wholly owned subsidiary of Meta Platforms, Inc. Facebook 2 is likely a
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`managing entity for Meta’s other subsidiaries, and its principal place of business is in Menlo Park,
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`California.
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`26.
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`Facebook Payments, Inc. (“Facebook 3”) was incorporated in Florida on December
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`10, 2010, and is a wholly owned subsidiary of Meta Platforms, Inc. Facebook 3 manages, secures,
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`and processes payments made through Meta, among other activities, and its principal place of
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`business is in Menlo Park, California.
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`27.
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`Facebook Technologies, LLC (“Facebook 4”) was incorporated in Delaware as
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`“Oculus VR, LLC” on March 21, 2014, and acquired by Meta on March 25, 2014. Facebook 4’s
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`principal place of business is in Menlo Park, California, and it develops Meta’s virtual and
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`augmented reality technology, such as the Oculus Quest line of products (soon to be renamed
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`“Meta Quest”), among other technologies related to Meta’s various platforms.
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`28.
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`Instagram, LLC (“Instagram”) was founded by Kevin Systrom and Mike Krieger
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`in October 2010. In April 2021, Meta purchased the company for $1 billion (later statements from
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`Meta have indicated the purchase price was closer to $2 billion). Meta reincorporated the company
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`on April 7, 2012, in Delaware. Currently, the company’s principal place of business is in in Menlo
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`Park, CA. Instagram is a social media platform tailored for photo and video sharing.
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`29.
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`a wholly owned subsidiary of Meta. Siculus supports Meta platforms by constructing data facilities
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`Siculus, Inc., (“Siculus”) was incorporated in Delaware on October 19, 2011 and is
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`and other projects. Siculus’s principal place of business is in Menlo Park, CA.
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`IV. GENERAL FACTUAL ALLEGATIONS
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`A.
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`Teenagers Are Particularly Vulnerable to the Perils of Excessive Social Media Use.
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`30.
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`Emerging research shows that the human brain is still developing during
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`adolescence in ways consistent with adolescents’ demonstrated psychosocial immaturity.
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`Specifically, adolescents’ brains are not yet fully developed in regions related to risk evaluation,
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`emotion regulation, and impulse control. The frontal lobes—and, in particular, the prefrontal
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`cortex—of the brain play an essential part in higher-order cognitive functions, impulse control,
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`and executive decision-making. These regions of the brain are central to the process of planning
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`and decision-making, including the evaluation of future consequences and the weighing of risk
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`and reward. They are also essential to the ability to control emotions and inhibit impulses. MRI
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`studies have shown that the prefrontal cortex is one of the last regions of the brain to mature.
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`During childhood and adolescence, the brain is maturing in at least two major ways. First, the brain
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`undergoes myelination, the process through which the neural pathways connecting different parts
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`of the brain become insulated with white fatty tissue called myelin. Second, during childhood and
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`adolescence, the brain is undergoing “pruning”—the paring away of unused synapses, leading to
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`more efficient neural connections. Through myelination and pruning, the brain’s frontal lobes
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`change to help the brain work faster and more efficiently, improving the “executive” functions of
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`the frontal lobes, including impulse control and risk evaluation. This shift in the brain’s
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`composition continues throughout adolescence and into young adulthood. In late adolescence,
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`important aspects of brain maturation remain incomplete, particularly those involving the brain’s
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`executive functions and the coordinated activity of regions involved in emotion and cognition. As
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`such, the part of the brain that is critical for control of impulses and emotions and mature,
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`considered decision-making is still developing during adolescence, consistent with the
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`demonstrated behavioral and psychosocial immaturity of juveniles.
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`31.
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`Because adolescence is the period when sophisticated, essential inhibitory control
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`functions are being established, the onset of prolonged exposure to toxic content during
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`adolescence is particularly concerning. The extended development of the prefrontal cortex results
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`in an adolescent brain that is largely undeveloped, highly malleable, and overwhelmingly
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`vulnerable to long-term, irremediable effects of adverse influences, including addiction and a
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`fractured psychological well-being.
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`32.
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`The algorithms in Defendants’ social media products exploit minor users’
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`diminished decision-making capacity, impulse control, emotional maturity, and psychological
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`resiliency caused by users’ incomplete brain development. Defendants know, or in the exercise of
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`reasonable care should know, that because their minor users’ frontal lobes are not fully developed,
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`such users are much more likely to sustain serious physical and psychological harm through their
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`social media use than adult users. Nevertheless, Defendants have failed to design their products
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`with any protections to account for and ameliorate the psychosocial immaturity of their minor
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`users.
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`33.
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`Adolescents see themselves as increasingly unique. Paradoxically, as part of their
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`individuation, they conform by faithfully mimicking the behavior of peers. Indeed, in defining
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`their own emerging identity, adolescents aspire to be viewed as mature adults, and this leads them
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`to affiliate with and emulate the personalities, images, behaviors, and preferences of those that
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`they would like to become. During the teenage years, relationships with family members often
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`take a back seat to peer groups and appearance. Teens crave to identify with their peer group,
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`achieve social approval, and become “popular.” Many teens feel deep insecurity and are self‐
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`conscious. They feel people are constantly focused on them, examining them, and judging them
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`about everything they say and do. They struggle with the inexorable desire to be accepted and
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`admired by their teen peers, and their biggest fear is to not fit in. This myopic desire to fit in
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`predispositions teenagers to frequently engage in upward social comparison processes, that is,
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`identifying and observing others that appear to be experiencing more positive outcomes, and
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`consequently feeling worse about themselves and their own perceived shortcomings.
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`34.
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`Today’s adolescents are part of Generation Z (which is loosely defined as people
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`born between 1997 and 2012)—they are the first generation of consumers to have grown up in an
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`entirely post‐digital era, and thus are “digitally native.” The oldest members of this demographic
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`cohort are just turning 24 this year; however, the substantial majority are believed to be still going
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`through adolescence. Members of Generation Z spend upwards of 3 hours per day on the internet,
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`and another 3 hours per day using social media. According to a 2018 survey by Pew Research
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`Center, 45 percent of high school students said they used a social-media platform daily, and 24
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`percent said that they were online “almost constantly.”1
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`35.
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`One way that Meta’s platforms addict minors is as follows: When minors use design
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`features such as “likes” it causes their brains to release euphoria-causing dopamine. However, as
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`soon as dopamine is released, their euphoria is countered by dejection: minor users’ brains adapt
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`by reducing or “downregulating” the number of dopamine receptors that are stimulated. In
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`normal stimulatory environments, neutrality is restored after this dejection abates. However,
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`Defendants’ algorithms are designed to exploit users’ natural tendency to counteract dejection by
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`going back to the source of pleasure for another dose of euphoria.
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`36.
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`Eventually, as this pattern continues over a period of days, weeks, and months, the
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`neurological baseline to trigger minor users’ dopamine responses increases. Minors then continue
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`to use Facebook and Instagram, not for enjoyment, but simply to feel normal. When minor users
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`1 Monica Anderson and JingJing Jiang, Teens, Social Media and Technology (February 3, 2022, last visited at 11:20
`AM CST) https://www.pewresearch.org/internet/2018/05/31/teens-social-media-technology-2018/.
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`attempt to stop using Defendants’ social media products, they experience the universal symptoms
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`of withdrawal from any addictive substance including anxiety, irritability, insomnia, and craving.
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`37.
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`Addictive use of social media by minors is psychologically and neurologically
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`analogous to addiction to internet gaming disorder. Gaming addiction is a recognized in the
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`American Psychiatric Association's 2013 Diagnostic and Statistical Manual of Mental Disorders
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`(DSM-5) (used by mental health professionals to diagnose mental disorders) and is a recognized
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`mental health disorder by the World Health Organization and International Classification of
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`Diseases. The diagnostic symptoms of social media addiction among minors are the same as the
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`symptoms of addictive gaming promulgated in DSM 5 and include:
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`g.
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`Preoccupation with social media and withdrawal symptoms (sadness,
`anxiety, irritability) when device is taken away or use is not possible
`(sadness, anxiety, irritability).
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`Tolerance, the need to spend more time using social media to satisfy the
`urge.
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`Inability to reduce social media usages, unsuccessful attempts to quit
`gaming.
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`Giving up other activities, loss of interest in previously enjoyed activities
`due to social media usage.
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`Continuing to use social media despite problems.
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`Deceiving family members or others about the amount of time spent on
`social media.
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`The use of social media to relieve negative moods, such as guilt or
`hopelessness; and
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`h.
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`Jeopardizing school or work performance or relationships due to social
`media usage.
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`Defendants’ advertising profits are directly tied to the amount of time that its users
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`38.
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`spend online. Thus, Defendants enhance advertising revenue by maximizing users’ time online
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`through a product design that addicts them to the platform, in part by directing them to content that
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`is progressively more stimulating. However, reasonable minor users and their parents do not expect
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`that online social media platforms are psychologically and neurologically addictive.
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`39.
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`Defendants’ products could feasibly report the frequency and duration of their
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`minor users’ screen time to their parents at negligible cost. This would enable parents to track the
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`frequency, time, and duration of their minor child’s social media, identify and address problems
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`arising from such use, and better exercise their rights and responsibilities as parents.
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`40.
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`Social comparisons on social media are frequent and are especially likely to be
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`upward, as social media provides a continuous stream of information about other people’s
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`accomplishments.2 Past research suggests that social comparisons occur automatically; when
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`individuals encounter information about another person, their own self-perceptions will be
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`affected. The sheer number of posts in a News Feed, each offering a thumbnail sketch of each
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`person’s carefully curated and predominantly ostentatious content, yields numerous opportunities
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`for social comparison. Although people do not typically post false information about themselves
`
`online, they do engage in selective self-presentation and are more likely to post eye-catching
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`content. As a result, individuals browsing their News Feeds are more likely to see posts about
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`friends’ exciting social activities rather than dull days at the office, affording numerous
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`opportunities for comparisons to seemingly better-off others. Individuals with vacillating levels of
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`self-esteem and certitude, characteristics notoriously endemic to the teenage cohort, are
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`particularly oriented to making frequent and extreme upward social comparisons on social media,
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`which in turn threatens their mental health. Social-media-induced social comparison often results
`
`in a discrepancy between the ideal self and the real self, thus evoking a sense of depression,
`
`
`2 Jin Kyun Lee, The Effects of Social Comparison Orientation on Psychological Well-Being in Social Networking
`Self-Esteem
`(2020),
`Sites:
`Serial
`Mediation
`of
`Perceived
`Social
`Support
`and
`https://link.springer.com/content/pdf/10.1007/s12144-020-01114-3.pdf
`
`
`
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`12
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`

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`Case: 1:22-cv-02968 Document #: 1 Filed: 06/07/22 Page 15 of 96 PageID #:15
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`deprivation, and distress, resulting in an overall aggravation of one’s mental state.3 Since the early
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`2000s, studies have shown that frequent upward social comparison results in lower self-esteem
`
`and reduced overall mental health.4 It has also long been known that individuals who are more
`
`likely to engage in self-comparison are likewise more likely to have negative outcomes when using
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`social media. To cope with wavering self-esteem, digitally native adolescents often become
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`envious of others and resort to cyberbullying to deconstruct the point of comparison’s perceived
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`superiority and preserve an increasingly delicate ego. These natural dynamics in youth are
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`exacerbated to psychologically injurious levels by Meta’s platforms’ progressively toxic
`
`environment worsened by its 2018 shift to engagement-based ranking, which is discussed in
`
`further detail below.
`
`41.
`
`The dangers associated with teenager’s proclivity to engage in protracted upward
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`social comparison while on social media is compounded by Meta’s deft and discreet construction
`
`of an atmosphere capable of exploiting the impulse control issues of even the most mature adults,
`
`thereby unleashing upon the public a product that is predictably highly addictive. Some of Meta’s
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`key features that make the platforms highly addictive include the use of intermittent variable
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`rewards (“IVR”) and its Facial Recognition System (“FRS”).
`
`42.
`
`IVR is a method used to addict a user to an activity by spacing out dopamine
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`triggering stimuli with dopamine gaps—a method that allows for anticipation and craving to
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`develop and strengthens the addiction with each payout. The easiest way to understand this term
`
`is by imagining a slot machine. You pull the lever (intermittent action) with the hope of winning
`
`
`3 This schism between the ideal self and the real self, and the attendant dissatisfaction with reality, is further
`exacerbated by Meta’s use of physical-augmentation technology, which allows users to utilize photo and video filters
`to make remove blemishes, make the face appear thinner, and lighten the skin-tone, all to make themselves appear
`more “attractive.”
`
` Claire Midgley, When Every Day is a High School Reunion: Social Media Comparisons and Self-Esteem (2020),
`https://www.researchgate.net/publication/342490065_When_Every_Day_is_a_High_School_Reunion_S