Privacy & Cybersecurity Law Blog

On February 3, 2025, the Massachusetts Attorney General revealed information about internal TikTok documents as part of the AG’s lawsuit in Massachusetts state court alleging that TikTok designed its platform to maximize children’s engagement while downplaying associated risks through unfair and deceptive practices prohibited under Massachusetts law. The information, revealed in a less-redacted complaint, highlights internal discussions and strategic choices made by TikTok to increase the time young users spend on the app.

The complaint alleges that TikTok’s internal metrics prioritize children’s engagement, with teenagers offering the highest “Life Time Value” to the company. According to the complaint, internal data showed that in 2020, TikTok had achieved 95% market penetration among U.S. teens aged 13 to 17. A 2019 presentation allegedly stated that the platform’s “ideal user composition” would be for 82% of its users to be under the age of 18.

TikTok executives allegedly were aware of the potential negative effects of its algorithm on children, including sleep disruption and compulsive use. Internal communications cited in the lawsuit include a statement from TikTok’s Head of Child Safety Policy acknowledging that the app’s algorithm keeps children engaged at the expense of other essential activities.

TikTok’s leadership also allegedly blocked proposed changes aimed at reducing compulsive use among minors due to concerns about negative business impacts. One example cited in the complaint involves a proposed “non-personalized feed” that could have mitigated compulsive behaviors but was ultimately rejected.

The complaint also alleges that TikTok misrepresented the effectiveness of its content moderation policies. While the company has publicly claimed high proactive removal rates for harmful content, internal data allegedly shows significant leakage of inappropriate material, including content related to child safety violations.

The Massachusetts case is one of the first to publicly disclose internal TikTok documents related to its user engagement strategies. Its outcome could impact how social media companies design their platforms and address concerns regarding child safety.