Meta Platforms, Inc. v. Bonta

Issue: Whether social media platform defendants (Meta, TikTok, Snap, and Google/YouTube) are entitled to summary judgment on school districts' negligence, failure-to-warn, and public nuisance claims arising from the platforms' design features and algorithmic systems alleged to cause adolescent addiction and mental health harm.

This document is a declaration by California Deputy Attorney General Shiwon Choe filed in *Meta Platforms, Inc. v. Bonta* (N.D. Cal. No. 5:25-cv-09792), supporting the state's administrative motion for limited expedited discovery in connection with Meta's pending motion for a preliminary injunction. The declaration attaches, as exhibits, filings from the related MDL proceeding *In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation* (No. 4:22-md-03047-YGR), specifically the school districts' corrected omnibus opposition to defendants' motions for summary judgment. In that MDL opposition, plaintiffs argue that genuine disputes of material fact preclude summary judgment on failure-to-warn, negligence, and public nuisance theories, contending defendants had knowledge of harms to minors, targeted schools and children, and failed to exercise reasonable care, and that causation and damages questions are for the jury.

The California AG's use of the MDL summary judgment record as evidence in the *Bonta* preliminary injunction proceeding signals that state regulators are actively leveraging private litigation findings to resist platform efforts to enjoin state enforcement, potentially reinforcing the evidentiary foundation for state-level regulation of platform design and youth safety obligations.