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All popular social media platforms, including those used heavily by minors such as TikTok, <br /> Snapchat, Instagram, and Facebook, feature endless scroll feeds strategically designed to <br /> intermittently surface content that users are algorithmically predicted to engage with. An <br /> internal TikTok document said that the app maximizes for two metrics: user retention and time <br /> spent.81 Similarly, a product manager for YouTube's recommendation system explained that the <br /> platform's recommendation algorithm "is designed to do two things: match users with videos <br /> they're most likely to watch and enjoy, and . . . recommend videos that make them happy. . . . <br /> [S]o our viewers keep coming back to YouTube, because they know that they'll find videos that <br /> they like there."82 And Adam Mosseri of Instagram said, "[W]e make a set of predictions. These <br /> are educated guesses at how likely you are to interact with a post in different ways.... The more <br /> likely you are to take an action, and the more heavily we weigh that action, the higher up you'll <br /> see the post."" <br /> Tech companies know that variable rewards are a valuable tool to increase users' activity and <br /> time spent online and ultimately, to maximize profits. But they are similarly aware of the risks <br /> associated with these types of rewards. For example, in 2020, responding to internal research <br /> indicating that teen users had difficulty controlling their use of Facebook and Instagram, a Meta <br /> employee wrote to a colleague: "I worry that the driving [users to engage in more frequent] <br /> sessions incentivizes us to make our product more addictive, without providing much more <br /> value... Intermittent rewards are the most effective (think slot machines), reinforcing behaviors <br /> that become especially hard to extinguish."84 Ultimately, these sophisticated variable reward <br /> techniques prey upon minors' developmental sensitivity to rewards. <br /> Algorithmic content recommendation systems <br /> Algorithms designed to maximize engagement fill young people's feeds with the content that is <br /> most likely to keep them online, even when that means exposing them to a post, image, or <br /> video that is dangerous or abusive. Platforms such as YouTube, TikTok, and Instagram serve <br /> users content based on automated suggestions. Algorithms choose which content to suggest to <br /> children and teens based on the vast amount of data they collect on users, such as likes, shares, <br /> comments, interests, geolocation, and information about the videos a user watches and for <br /> how long. As described above, these algorithms are designed to extend engagement by <br /> discerning which pieces of content a user is most likely to engage with — not whether the <br /> content or overall online experience is beneficial to the user.81 <br /> 81 Ben Smith,How TikTok Reads Your Mind, New York Times, (Dec.5,2021), <br /> I�L� s. www.i� tii �:s.coi f) '. '. CS Ir�u.�.Fin.ss rnedi �i1 t..I< a1 o[ith n.htrn1. <br /> I.............././............................................y. <br /> .........................................................../............................./................./................./....................................................................................../................................................g.................................................................... <br /> 82 Creator Insider,Behind the Algorithms-How Search and Discovery Works on YouTube,YouTube(Apr. 16,2021), <br /> https:Hyoutu.be/9Fn79gJa2Fc. <br /> 83 Adam Mosseri,Shedding More Light on How Instagram Works, Instagram(June 8,2021), <br /> https:Habout.instagram.com/blog/announcements/shedding-more-light-on-how-instagram-works. <br /> 84 Spence v. Meta Platforms, N.D.Cal.Case No.3:22-cv-03294 at 82 (June 6,2022) (citing Facebook Papers: "Teen <br /> Girls Body Image and Social Comparison on Instagram—An Exploratory Study in the US" (March 2020),at p. 8). <br /> 85 A former YouTube engineer observed: "recommendations are designed to optimize watch time,there is no <br /> reason that it shows content that is actually good for kids. It might sometimes, but if it does, it is coincidence." <br /> Orphanides, K.G. "Children's YouTube is still churning out blood,suicide and cannibalism." Wired, (March 23, <br /> 2018), 17,:G;G,as: www.wired.co.u.sl< article ou.sGu.slae for Iaids videos arolalerris al oriGl7rri recornrriend <br /> Testimony of Josh Galin, Fairplay, February 14, 2023 13 <br />