Section 230 Complaint

Doe v. Roblox Corporation

🏛 United States District Court for the Eastern District of Arkansas · 📅 2025-10-07

Issue

Whether Roblox Corporation and Discord, Inc. are liable under product liability (design defect), negligence, and fraud theories for injuries a minor suffered from sexual exploitation facilitated through their platforms, and whether those claims are barred by §230(c)(1) of the Communications Decency Act.

What Happened

Plaintiff, a 14-year-old Arkansas minor, filed suit through his mother as next friend in Arkansas Circuit Court (subsequently docketed in the Eastern District of Arkansas) against Roblox and Discord, alleging that a predator used Roblox to groom the minor and Discord to solicit sexually explicit images. The complaint alleges design defect, negligence, and fraudulent misrepresentation, contending that Defendants knowingly failed to implement age verification, identity screening, and effective parental controls while publicly representing their platforms as safe for children. Plaintiff affirmatively disavows any contractual relationship with Defendants, expressly disaffirming any terms of service, arbitration clause, or delegation clause on the ground that he is a minor who did not read or understand such terms.

Why It Matters

This complaint presents a direct test of whether product liability and fraud theories premised on platform design choices — rather than on Defendants' role as publishers of third-party content — can survive anticipated §230 preemption arguments, potentially advancing the circuit split over whether design-defect claims targeting a platform's own architectural decisions fall outside §230's immunity.

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