Noel v. Roblox Corporation

CourtDistrict Court, N.D. California
DecidedAugust 8, 2024
Docket3:24-cv-00963
StatusUnknown

This text of Noel v. Roblox Corporation (Noel v. Roblox Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Noel v. Roblox Corporation, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RAYMOND NOEL, et al., Case No. 3:24-cv-00963-JSC

8 Plaintiffs, ORDER RE: DEFENDANT’S MOTION 9 v. TO COMPEL ARBITRATION AND MOTION TO DISMISS AND 10 ROBLOX CORPORATION, PLAINTIFFS’ MOTION TO AMEND 11 Defendant. Re: Dkt. Nos. 25, 26, 28, 39

12 13 Raymond and Laura Noel’s minor children are regular users of the Roblox gaming 14 platform. The Noels (the parents) bring a putative class action against Roblox Corporation 15 (“Roblox”), alleging Roblox’s conduct is deceptive and unfair. Now pending before the Court is 16 Roblox’s motion to compel Plaintiffs to arbitration (Dkt. No. 26)1, or, in the alternative, to dismiss 17 the complaint (Dkt. No. 28), along with a motion to seal certain documents. (Dkt. No. 25.) In 18 addition, a week before the oral hearing, Plaintiffs filed a motion for leave to file an amended 19 complaint (Dkt. No. 39), which also remains pending. Having carefully considered the briefing, 20 and with the benefit or oral argument on August 8, 2024, the Court DENIES Plaintiffs’ motion for 21 leave to amend, GRANTS Roblox’s motion to seal and DENIES Roblox’s motion to compel 22 arbitration and motion to dismiss without prejudice pending resolution of whether Roblox has an 23 enforceable arbitration agreement with Plaintiffs. On this record, Roblox has not shown as a 24 matter of undisputed fact the existence of an arbitration agreement between Plaintiffs and Roblox. 25 COMPLAINT ALLEGATIONS 26 “Roblox is an online game creation system and platform, where users can program their 27 1 own games or play games created by other users.” (Dkt. No. 1 ¶ 2.) “The Roblox platform 2 consists of two primary layers: Roblox Client and Roblox Studio.” (Id. ¶ 53.) “Roblox Client 3 functions more as a game and allows users to explore 3D digital worlds as an avatar, which each 4 user customizes with clothing, gear, animations, simulated gestures, emotes, and other objects.” 5 (Id. ¶ 54.) “Roblox Studio is a proprietary engine that functions as a toolkit for developers and 6 creators to build, publish, and operate the 3D games (called “experiences” by Roblox Corp.), and 7 content for Roblox Client.” (Id. ¶ 55.) Developers can also design “objects such as clothing, gear, 8 and gestures,” which they can then “sell in a user-to-user marketplace.” (Id. ¶ 56.) Roblox 9 “provides price floors for items.” (Id. ¶ 134.) Moreover, Roblox takes a commission from every 10 sale and charges users an “upload” or “selling” fee before they can upload any creation to the 11 marketplace. (Id. ¶¶ 136-37.) 12 Developers’ creations can earn them “Robux” which are “the Roblox digital currency” and 13 are “spendable only in the Roblox platform.” (Id. ¶¶ 14, 22.) Robux can either be “purchased” for 14 real money—for example, through an in-game purchase with a credit card or through the purchase 15 of a physical gift-card—or they can be “‘earned’ within the Roblox platform.” (Id. ¶ 19.) 16 Robux can be used to “make purchases of virtual items to be used in games or apps within 17 the Roblox ecosystem.” (Id. ¶ 15.) Robux can also be converted back to U.S. dollars, though at a 18 “significantly devalued rate”—one Robux is worth about $0.0035 dollars when cashing out. (Id. 19 ¶¶ 16, 25.) “However, in order to even convert Robux to USD, a user must first meet several . . . 20 requirements, including having a minimum of at least 30,000 earned Robux in their account and 21 paying a monthly subscription fee.” (Id. ¶ 26.) Moreover, “users must be at least 13 years of age 22 or older” to join the “Developer Exchange Program” which allows users to convert their earned 23 Robux to U.S. dollars. (Id. ¶¶ 103, 112.) “As a result, many child developers are unable to ever 24 cash out their Robux for real-world funds because they are unable to meet the requirements to do 25 so.” (Id. ¶ 27.) 26 Roblox also “allow[s] users to be ‘hired’ by other users to work on their experiences and 27 content.” (Id. ¶ 147.) Roblox’s “Talent Hub” “includes job postings for its users to earn Robux 1 on the Talent Hub “expressly state [the poster] will hire minors.” (Id. ¶ 152.) “Roblox attempts to 2 distance itself from taking any responsibility for exploitation on Talent Hub and instead tries to 3 put the onus on parents to monitor their child’s labor activities on Talent Hub.” (Id. ¶ 153.) 4 Most of Roblox’s users and developers are children. (Id. ¶ 23.) “The design of the Roblox 5 platform was specifically intended to addict users— especially children—and encourage play for 6 longer periods of time.” (Id. ¶ 57.) “Roblox conceals these dangerous addictive properties, while 7 at the same time holding the platform out as a safe and educational for its users.” (Id. ¶ 60.) 8 “Most of the currently popular games” on Roblox “are made by whole teams of users who 9 create games and continuously roll out updates to keep users playing.” (Id. ¶ 185.) “These 10 Roblox-associated teams are unregulated virtual communities that allow for the exploitation of 11 child members by making it easy to lie to children, making children work for free, making 12 children work for managers or bosses with zero experience in managing a team, and exposing 13 children to multiple types of abuse and harassment.” (Id. ¶ 187.) “Roblox also includes 14 communication features that enable teams to organize their work, and Roblox purports to 15 moderate these messages and check for abusive language.” (Id. ¶ 189.) “However, developers 16 can also use third-party chatrooms, such as Discord, to organize their Roblox projects,” because it 17 is “difficult to communicate” on Roblox’s platform. (Id. ¶¶ 190, 192.) Third-party chatrooms also 18 allow developers to avoid the Roblox moderation. (Id.) “[C]omplaints on the Roblox forums are 19 often flagged as harassment,” so users may have a difficult time lodging complaints about other 20 users. (Id. ¶ 188.) “Roblox is aware of the abuse allegations and exploitation of children on its 21 platform, yet it created an additional hurdle for young developers to seek recourse for any 22 exploitation and abuse by refusing to allow them to lodge any kind of complaint.” (Id. ¶ 206.) 23 “Roblox’s design, with its user generated content, overwhelming minor population, and 24 payment for experience creation, has created and fostered a system of child exploitation.” (Id. ¶ 25 156.) “Despite its promise for children to make serious cash, Roblox knows that few of its games 26 ever earn major income for developers.” (Id. ¶ 176.) “Thus, Roblox’s advertising that developing 27 games on its platform is a serious money-making opportunity is false and merely a way to drive 1 build experiences from which Roblox can profit.” (Id. ¶ 179.) “Roblox is aware of this fact and 2 knows that it is incredibly easy to take advantage of the minor developers on their platform.” (Id. 3 ¶ 183.) 4 Raymond and Laura Noel “are parents of three children” who “have been playing on 5 Roblox for at least the prior two years” and continue to play on Roblox. (Id. ¶¶ 217-18.) They 6 “have spent thousands of dollars on Robux currency for their children’s gameplay.” (Id. ¶ 39.) 7 “Plaintiffs would not have spent funds on Robux had they known that the Roblox platform was 8 founded on the exploitation of their children and other children, who make up the platform’s user 9 base.” (Id. ¶ 223.) “Instead, Plaintiffs believed, as Roblox advertised, that the platform was safe 10 and educational for their children.” (Id. ¶ 224.) “Now, Plaintiffs’ children continue playing 11 Roblox and requesting funds for Robux because they are addicted to the platform—just as Roblox 12 intended.” (Id.

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Bluebook (online)
Noel v. Roblox Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/noel-v-roblox-corporation-cand-2024.