All precedents

Settlement · 19 December 2022

FTC settlements with Epic Games (COPPA and dark patterns)

United States v. Epic Games, Inc. (E.D.N.C. 2022); In re Epic Games, FTC administrative order (2023) · Federal Trade Commission

What it means for your code

Default communication settings for minors must be off, and purchase buttons must require clear, deliberate confirmation.

What happened

Fortnite collected children's data without parental consent, enabled voice and text chat by default for children, and used button layouts that led players into unwanted purchases.

What was decided

Default-on live chat for children and collecting their data without parental consent violated COPPA; confusing purchase flows and blocking account access after chargebacks were unfair practices under the FTC Act.

⚖ USD 275 million COPPA civil penalty and USD 245 million consumer refunds

The legal test applied

  • COPPA requires verifiable parental consent before collecting children's personal information
  • Default-on voice and text communication for minors was an unfair practice
  • Interfaces that cause unintended purchases are unfair practices
Read the decision at the source

Summary and analysis by Lawpatch, checked by an editor against the source. Risk analysis, not legal advice; the law may have moved on since this decision.