Roblox Says FTC, Pennsylvania and Utah Are Considering Children’s Privacy Claims

Roblox Corp. says the Federal Trade Commission and two states have told it they are considering legal claims over children’s privacy and consumer protection.

In its quarterly report filed with the Securities and Exchange Commission on October 29, 2026, Roblox says the FTC and the states of Pennsylvania and Utah notified it in October 2026 that, “as part of an ongoing investigation,” they “are considering filing claims.”

According to the filing, the possible claims would allege violations of the FTC Act, the Children’s Online Privacy Protection Act (COPPA) and certain state consumer protection laws, and would seek money damages along with declaratory and injunctive relief.

That is a notice, not a lawsuit. The filing does not describe any case filed by the FTC, Pennsylvania or Utah, and Roblox says it is “unable to reasonably estimate the loss or range of loss, if any.” The company also says it intends to defend itself “vigorously” in all of its legal matters.

The FTC enters Roblox’s legal notes

Putting Roblox’s three 2026 quarterly reports side by side shows what is new. The second-quarter report, filed July 30, mentions the FTC only once, in a general passage about advertising rules. It does not describe an FTC investigation of Roblox, and neither does the annual report Roblox filed on February 11, 2026. The July report said “various state attorneys general” had sued, announced plans to sue or opened investigations.

The October report changes that to “numerous regulators,” cites “state, federal, or local laws” and adds privacy to the issues. It also adds two allegations to its summary of what Roblox faces: that the company violated child privacy laws and misrepresented its compliance with them, and that it failed to comply with consumer protection laws.

The first-quarter report said the first three settlements were signed in April 2026. In the latest report, the notice and the settlement figures sit in Note 8, “Commitments and Contingencies,” on page 20.

What COPPA covers, and what the filing leaves out

COPPA is the federal law on collecting data from young children. In Roblox’s own summary, it requires online services aimed at children under 13 to get verifiable parental consent before collecting those children’s personal information, with some exceptions. Elsewhere in the same report, Roblox writes that “the FTC and certain states are currently investigating our compliance with COPPA and may consider filing claims.”

For a sense of scale, in December 2022 Epic Games agreed to pay a $275 million penalty to settle FTC allegations that it violated the COPPA Rule. That was a different company and a different case, and it does not indicate how Roblox’s matter will end.

The 10-Q is short on detail. It does not say what conduct the regulators are examining, what started the investigation or when, how much money they might seek, or whether Roblox is negotiating with them.

Two earlier items are separate from the notice. On October 9, MLex, a subscription regulatory news service, published a report headlined “Roblox facing investigation by US FTC on child safety issues.” Separately, on May 20, 2026, the advocacy groups Fairplay and the National Center on Sexual Exploitation asked the FTC to investigate Roblox, including whether it complies with COPPA. Roblox’s filing mentions neither.

$140 million set aside, with more costs still off the books

Roblox says it booked $49 million in the third quarter and $140 million in the first nine months of 2026 as general and administrative expense, tied to settlement agreements and settlement talks with states and territories. The amounts are cash payments owed to them, the filing says, and it does not break the total down by state. For the lawsuits and the October notice, Roblox says it cannot estimate a possible loss.

Some settlement terms are not in that figure. Roblox has not accrued commitments for public service campaigns, staff to work with law enforcement, certain platform and policy changes, or penalties if it breaches settlement terms. It says it will record those costs as they are incurred, and breach penalties only if a breach becomes probable.

General and administrative expenses rose $58 million, or 40%, in the third quarter from a year earlier, mainly because of the $49 million accrual, the company says. Over nine months, professional services rose $37 million, mostly from legal fees for litigation and investigations.

Where the state cases stand

Roblox describes the regulators’ claims as relating mainly to youth-related consumer protection, digital safety and privacy. The Texas complaint, for example, alleges that Roblox failed to adequately protect children on its platform, the filing says. These are allegations, not findings. Roblox calls the cases “still in the early stages,” and the rulings it lists decide which claims can go forward. None is a verdict.

• Texas, March 6, 2026: the Travis County court dismissed the state’s nuisance claim but let its Deceptive Trade Practices Act claim proceed.
• Iowa, May 13, 2026: the Polk County court granted Roblox’s motion to dismiss in part, throwing out certain factual allegations.
• Louisiana, August 31, 2026: the Livingston Parish court dismissed the negligence and unjust enrichment claims but kept the unfair trade practices claim. Roblox asked the state’s First Circuit appeals court to step in on October 2; that request was pending when it filed the report.
• Tennessee, September 17, 2026: the Williamson County Chancery Court denied Roblox’s motion to dismiss.
• Los Angeles County, September 23, 2026: the Superior Court overruled Roblox’s demurrer, a request to throw out the complaint, and denied its anti-SLAPP motion, though it narrowed the time period for the false-advertising claim.

Roblox says it has filed, or expects to file, motions to dismiss in the other cases. Our Gaming Law Tracker lists case numbers for several of the state suits. Many private child-safety lawsuits sit on a separate track in federal court in San Francisco, where we counted at least 13 new Roblox lawsuits in two weeks in October.

Neither Pennsylvania nor Utah appears on Roblox’s list of states that had sued it as of October 29. The 10-Q gives no date for any next step by them or the FTC. The next regular filing that would carry an update is Roblox’s annual report; the company filed its last one on February 11, 2026.

Featured image: Roblox logo from the company’s press kit. Image: Roblox