What changed in this filing

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Item 3. Legal Proceedings

2026-01-29 compared with 2025-01-30 · 101 added, 67 removed, 155 unchanged (52% of the section changed)

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Over the last several years, the number and potential significance of the litigation and investigations involving the company have increased, and there can be no assurance that this trend will not continue.

For example, we are facing numerous cases in the United States in which plaintiffs are attempting to avoid or limit the application of Section 230 of the Communications Decency Act to their claims and certain of those matters have survived motions to dismiss, including through the use of products liability theories.

Outside of the United States, we are subject to new regulatory regimes, including the Digital Services Act, Digital Markets Act, EU AI Act and similar statutes in non-EU countries such as the UK Digital Markets, Competition and Consumer Act, and new fining guidelines under existing regulatory regimes like the General Data Protection Regulation (GDPR).

Outside of the United States, we are subject to relatively new regulatory regimes, including the Digital Services Act, Digital Markets Act, EU AI Act and similar statutes in non-EU countries such as the UK Digital Markets, Competition and Consumer Act, and new fining guidelines under existing regulatory regimes like the General Data Protection Regulation (GDPR).

We are facing inquiries and investigations regarding various aspects of our regulatory compliance, as well as private litigation in Europe, including class and mass actions, claiming damages (including for loss of control of data without other damage) and/or injunctions in respect of alleged failings to comply with such regulatory requirements.

We are also responding to litigation and government investigations related to our alleged role in causing or contributing to various societal harms, including mental and physical health and safety impacts on users, particularly younger users, child and adult sexual exploitation, illegal activity with respect to drugs, fraud, unlawful discrimination, and other harms potentially impacting large numbers of people.

This is in addition to significant tax, competition and antitrust, stockholder, commercial, consumer, and privacy litigation and investigations.

Furthermore, as the number of our users and amount of our revenue have grown, our potential exposure to substantial damages awards and fines has increased.

This is in addition to significant tax, competition and antitrust, stockholder, commercial, consumer, intellectual property, and privacy litigation and investigations.

Furthermore, as the number of our users and amount of our revenue have grown, our potential exposure to substantial damages awards and fines has increased, including through class action litigations and other legal proceedings under statutory regimes permitting penalties or damages on a per-violation basis or based on a percentage of global revenue.

The maximum aggregate monetary damages or penalties sought across our various legal proceedings could amount to an aggregate of up to hundreds of billions of dollars and, as a result, could be material to the financial condition of the company.

In some instances, particularly with novel legal and factual claims, new regulatory regimes or statutes that have not previously been enforced, or where the nature or type of enforcement pursued against us is novel, it can be very difficult to assess the likelihood or extent of potential liabilities, including the nature and extent of injunctive or other non-monetary relief and the applicability and amount of any potential forfeitures, disgorgement, fines or penalties.

While we have identified below certain matters that we believe to be material, there can be no assurance that additional material losses or limitations on our activities will not result from claims that have not yet been asserted or are not yet determined to be material.

While we have identified

below certain matters that we believe to be material, there can be no assurance that additional material losses or limitations on our activities will not result from claims that have not yet been asserted or are not yet determined to be material.

Privacy and Related Matters

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District Court for the Northern District of California ( In re Facebook, Inc., Consumer Privacy User Profile Litigation ).

On September 9, 2019, the court granted, in part, and denied, in part, our motion to dismiss the consolidated putative consumer class action.

On December 22, 2022, the parties entered into a settlement agreement to resolve the lawsuit, which provides for a payment of $725 million by us.

The settlement was approved by the court on October 10, 2023, and the payment was made in November 2023.

Two objectors appealed final approval (one of which was voluntarily dismissed as of June 24, 2024).

The objection is fully briefed and will be heard on February 7, 2025.

On December 22, 2022, the parties entered into a settlement agreement to resolve the lawsuit, which provided for a payment of $725 million by us and became final on May 14, 2025.

In addition, our platform and user data practices, as well as the events surrounding the misuse of certain data by a developer, became the subject of U.S.

Federal Trade Commission (FTC), state

attorneys general, and other government inquiries in the United States, Europe, and other jurisdictions.

Federal Trade Commission (FTC), state attorneys general, and other government inquiries in the United States, Europe, and other jurisdictions.

We entered into a settlement and modified consent order to resolve the FTC inquiry, which took effect in April 2020 and required us to pay a penalty of $5.0 billion and to significantly enhance our practices and processes for privacy compliance and oversight.

The state attorneys general inquiries and litigation and certain government inquiries in other jurisdictions remain ongoing and could subject us to additional substantial fines and costs, require us to change our business practices, divert resources and the attention of management from our business, or adversely affect our business.

In addition, in December 2025, we entered into a settlement agreement with California to resolve its lawsuit alleging violations of consumer protection laws, which is subject to court approval.

Certain other state attorneys general inquiries and litigation and certain government inquiries in other jurisdictions remain ongoing and could subject us to additional substantial fines and costs, require us to change our business practices, divert resources and the attention of management from our business, or adversely affect our business.

On June 1, 2023, the court presiding over the lawsuit filed by the District of Columbia granted our motion for summary judgment, resolving the case in our favor.

On June 29, 2023, the District of Columbia filed a notice of appeal.

The appeal is fully briefed and will be heard on January 30, 2025.

Trial in the New Mexico Attorney General's case is scheduled to begin on December 1, 2025.

The appeal was heard on January 30, 2025 and on July 31, 2025, the District of Columbia Court of Appeals reversed the decision on procedural grounds and remanded the matter to the lower court.

Trial in the New Mexico Attorney General's case, which has expanded to include various claims related to content moderation issues, is scheduled to begin on September 8, 2026.

On July 16, 2021, a stockholder derivative action was filed in Delaware Court of Chancery against certain of our directors and officers asserting breach of fiduciary duty and related claims relating to our historical platform and user data practices, as well as our settlement with the FTC.

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The insider trading claim was dismissed as to all defendants except Mark Zuckerberg, and the motion was denied as to the breach of fiduciary duty claims.

Trial is scheduled to begin on April 2, 2025.

Trial began on July 16, 2025.

On July 17, 2025, the parties agreed to a settlement in principle to resolve all claims in the action, which is subject to court approval.

On May 3, 2023, the FTC filed a public administrative proceeding ( In the Matter of Facebook, Inc.

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On May 31, 2023, we filed a motion before the U.S.

District Court for the District of Columbia ( USA v.

Facebook, Inc.

) seeking to enjoin the FTC from further pursuing its agency process to modify the modified consent order.

District Court for the District of Columbia seeking to enjoin the FTC from further pursuing its agency process to modify the modified consent order.

On November 27, 2023, the district court denied our motion, and we then appealed to the U.S.

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Our motion for a stay pending appeal was denied in March 2024.

The underlying appeal was then briefed and oral argument was held on November 5, 2024.

Court of Appeals for the District of Columbia Circuit has yet to rule.

After the underlying appeal was briefed and oral argument was held on November 5, 2024, the U.S.

Court of Appeals for the District of Columbia Circuit issued its decision on May 16, 2025, reversing the district court's denial of our motion on jurisdictional grounds, and directed the district court to consider the merits of our arguments.

On July 10, 2025, the case was remanded to the district court to consider our claims in light of the Court of Appeals' determination that the district court retains jurisdiction over the entirety of the consent order.

On December 23, 2025, the district court ordered a schedule for supplemental briefing in light of the Court of Appeals decision, with briefing due to be complete by May 2026.

On November 29, 2023, we separately filed a complaint, also in the U.S.

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FTC ), asserting constitutional challenges to the structure of the FTC, and seeking to preliminarily enjoin the FTC proceeding during the pendency of the litigation.

On December 13, 2023, the FTC filed an opposition to our motion for preliminary injunction and a motion to dismiss the complaint.

On December 13, 2023, the FTC filed an opposition to our

motion for preliminary injunction and a motion to dismiss the complaint.

On March 14, 2024, the district court denied our motion to preliminarily enjoin the FTC proceeding during the pendency of the litigation, and also denied the FTC's motion to dismiss our complaint without prejudice, pending the U.S.

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Following the Supreme Court's ruling in Jarkesy on June 27, 2024, the government filed a renewed motion to dismiss, which was fully briefed as of October 18, 2024.

The district court has yet to rule.

The parties are required to report back to the circuit court within 30 days of the district court's disposition of the FTC's motion to dismiss.

On June 29, 2025, the district court granted our request for a stay in light of the Court of Appeals' May 16, 2025 decision in the jurisdictional case, and on January 20, 2026, the district court continued the stay and ordered the parties to file a status update by June 8, 2026.

On April 1, 2024, we filed our response to the FTC's Order to Show Cause, arguing, among other things, that the Order to Show Cause proceeding was legally improper.

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On January 10, 2025, the Commission issued a decision on certain threshold legal issues, including that the Commission has statutory authority to modify consent orders.

The Commission stated that its decision is subject to Meta’s jurisdictional challenges currently pending before the U.S.

The Commission stated that its decision is subject to Meta's jurisdictional challenges then pending before the U.S.

Court of Appeals for the District of Columbia Circuit in U.S.

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, and that the nature and scope of any further administrative proceedings would be addressed at a later date.

On July 30, 2025, the Commission issued an order staying the Order to Show Cause proceeding pending final resolution of the two judicial cases we filed challenging the proceeding.

Through the administrative process, the FTC could amend the order to impose the additional requirements set forth in the proposed order.

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It is unclear whether the appeal or the request for a stay would be successful.

other laws (such as UK GDPR and Member State implementations of the ePrivacy Directive), and are subject to inquiries and investigations by the IDPC and other European regulators regarding various aspects of our regulatory compliance.

We also notify the Irish Data Protection Commission (IDPC), our lead European Union privacy regulator under the GDPR, of certain other personal data breaches and privacy issues, issue similar notifications to European regulators under other laws (such as UK GDPR and Member State implementations of the ePrivacy Directive), and are subject to inquiries and investigations by the IDPC and other European regulators regarding various aspects of our regulatory compliance.

For example, the IDPC is continuing to assess the compliance of our "subscription for no ads" consent model with requirements under the GDPR.

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The IDPC issued an administrative fine of EUR €1.2 billion as well as corrective orders requiring Meta Platforms Ireland to suspend the relevant transfers and to bring its processing operations into compliance with Chapter V GDPR by ceasing the unlawful processing, including storage, of such data in the United States.

We are appealing this Final Decision and it is currently subject to an interim stay from the Irish High Court.

On October 7, 2022, President Biden signed the Executive Order on Enhancing Safeguards for United States Signals Intelligence Activities (E.O.), and on June 30, 2023, the European Union and the three additional countries making up the EEA were designated by the United States Attorney General as a "qualifying state" under Section 3(f) of the E.O.

On July 10, 2023, the European Commission adopted an adequacy decision in relation to the United States.

The adequacy decision concludes that the United States ensures an adequate level of protection for personal data transferred from the European Union to organizations in the United States that are included in the "Data Privacy Framework List," maintained and made publicly available by the United States Department of Commerce pursuant to the EU-U.S.

Data Privacy Framework (EU-U.S.

The implementation of the EU-U.S.

DPF and the adequacy decision are important and welcome milestones, and we have implemented steps to comply with the above corrective orders following engagement with the IDPC.

We are appealing this Final Decision and it is currently subject to a stay from the Irish High Court.

We have also implemented steps to comply with the above corrective orders and are pending the IDPC's confirmation that these address the corrective orders.

For additional information, see Part I, Item 1A, "Risk Factors—Our business is subject to complex and evolving U.S.

and foreign laws and regulations regarding privacy, data use, data combination, data protection, content, competition, youth, safety, consumer protection, advertising, e-commerce, and other matters" in this Annual Report on Form 10‑K.

Any such inquiries or investigations (including the IDPC proceedings) could subject us to substantial fines and costs, require us to change our business practices, divert resources and the attention of management from our business, or adversely affect our business.

In addition, we are subject to individual and class actions in Europe relating to matters that are or have been the subject of regulatory investigations.

Beginning on June 7, 2021, multiple putative class actions were filed against us alleging that we improperly received individuals' information from third-party websites or apps via our business tools in violation of our terms and various state and federal laws and seeking unspecified damages and injunctive relief (for example, In re Meta Pixel Healthcare Litigation;

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These cases are in different stages, but several of our motions to dismiss have been denied in whole or in part, while certain others have been granted in whole or in part.

We are currently in discovery and litigating class certification in the cases that are most advanced.

In Rickwalder , the Superior Court denied plaintiffs' motion for class certification and the plaintiffs have appealed that decision.

In Flo Health , on August 1, 2025, a jury returned a verdict on liability in favor of the plaintiffs and on behalf of a California subclass on the sole claim remaining against Meta under Section 632 of the California Invasion of Privacy Act.

Plaintiffs are seeking $5,000 in statutory damages per class member and have asserted that there are up to approximately 1.6 million class members.

The amount of potential damages is uncertain at this time.

In addition, we are subject to individual and class actions in Europe, as well as regulatory investigations in the United States, Europe, and elsewhere, relating to similar matters with regard to our business tools.

We are subject to various litigation and government inquiries and investigations, formal or informal, by competition authorities in the United States, Europe, and other jurisdictions.

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On November 13, 2024, the court granted in part and denied in part both our and the FTC's motions for summary judgment.

Trial is set to begin on April 14, 2025.

Trial began on April 14, 2025 and concluded on May 27, 2025.

On November 18, 2025, the court granted judgment in our favor.

On January 20, 2026, the FTC filed a notice of appeal of that ruling.

Multiple putative class actions have also been filed in state and federal courts in the United States and in the United Kingdom against us alleging violations of antitrust laws and other causes of action in connection with these acquisitions and/or other alleged anticompetitive conduct, and seeking damages and injunctive relief.

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Meta Platforms, Inc.

On January 14, 2022, the court granted, in part, and denied, in part, our motion to dismiss the consolidated actions.

On March 1, 2022, a first amended consolidated complaint was filed in the putative class action brought on behalf of certain advertisers.

On December 6, 2022, the court denied our

motion to dismiss the first amended consolidated complaint filed in the putative class action brought on behalf of certain advertisers.

On December 30, 2024, we filed our motion for summary judgment in the putative class action brought on behalf of certain advertisers.

On December 30, 2024, we filed our motion for summary judgment in the putative class action brought on behalf of certain advertisers, which is pending with the court.

On January 24, 2025, the court denied plaintiffs' motion for class certification in the action brought on behalf of users, permitting it to proceed only on an individual basis as to the named plaintiffs.

On September 29, 2025, in the user action, the court granted our motion, entering judgment in our favor.

On October 27, 2025, plaintiffs in the user action filed a notice of appeal.

On February 11, 2022, a putative class action was filed against us in the UK Competition Appeals Tribunal (CAT) under the UK collective proceedings regime ( Lovdahl-Gormsen v.

Meta Platforms, Inc.

On October 6, 2023, following the denial of class certification, the class representative submitted an amended claim alleging abuse of dominance relating to aspects of our data processing practices and seeking damages.

The CAT certified the amended claim on February 15, 2024.

Trial is scheduled to begin in September 2027.

We are also subject to litigation in Europe brought by news and media companies alleging anticompetitive conduct in relation to aspects of our historic data processing practices.

For example, on December 1, 2023, 87 news media companies filed a joint action against us in Spain in relation to our legal basis under the GDPR for behavioral advertising, alleging unfair competition and abuse of dominance ( Asociacion de Medios de Informacion (AMI) v.

Meta Ireland ).

On November 19, 2025, the court issued judgment against us, finding that AMI had failed to establish abuse of dominance but upholding its case on unfair competition and awarding damages of approximately EUR €542 million.

We have appealed the decision.

In addition, on October 24, 2024, ten radio and television publishers commenced a separate claim against us in Spain on the same basis ( Union de Televisiones Comerciales Asociadas (UTECA) v.

Meta Ireland ).

In addition, on April 29, 2025, a similar unfair competition claim was filed against us by 67 media companies in France ( Amaury et al.

Meta Platforms Ireland Limited ).

Trial is expected to take place in 2027.

In December 2022, the European Commission issued a Statement of Objections alleging that we tie Facebook Marketplace to Facebook and use data in a manner that infringes European Union competition rules.

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We appealed the European Commission's decision on January 28, 2025.

In March 2024, the European Commission opened an investigation into the compliance of our "subscription for no ads" consent model with requirements under Article 5(2) of the Digital Markets Act.

The European Commission issued preliminary findings on July 1, 2024 reflecting its preliminary view that our model does not comply with such requirements, and indicated that it will conclude its investigation by March 2025.

In March 2024, the European Commission opened an investigation into the compliance of our "subscription for no ads" consent model with requirements under Article 5(2) of the Digital Markets Act (DMA).

The European Commission issued preliminary findings on July 1, 2024 reflecting its preliminary view that our model does not comply with such requirements.

In April 2025, the European Commission issued a final decision that our "subscription for no ads" model does not comply with such requirements and imposed a fine of EUR €200 million.

Based on feedback from the European Commission in connection with the DMA, we launched less personalized ads (LPA) in November 2024 and made significant modifications to LPA since the European Commission issued its final decision.

We appealed the European Commission's decision on July 4, 2025, but further modifications to our model may be imposed during the appeal process, which could result in a materially worse user experience for European users and a significant impact to our European business and revenue.

The result of such litigation, investigations or inquiries could subject us to substantial monetary remedies and costs, interrupt or require us to change our business practices, divert resources and the attention of management from our business, or subject us to other structural or behavioral remedies that adversely affect our business.

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The Supreme Court granted in part our petition for writ of certiorari on June 10, 2024, and following oral argument issued an order on November 22, 2024 dismissing the grant of certiorari as improvidently granted.

On January 24, 2025, the U.S.

Court of Appeals for the Ninth Circuit returned the case to the district court.

On July 1, 2025, the plaintiffs filed a fourth amended complaint.

On September 2, 2025, we filed a motion to dismiss the fourth amended complaint.

We are also subject to other government inquiries and investigations relating to our business activities and disclosure practices.

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On September 18, 2023, the plaintiffs filed an amended complaint and on September 17, 2024, the court dismissed the claims with prejudice.

On October 14, 2024, plaintiffs filed their notice of appeal.

On October 14, 2024, plaintiffs filed their notice of appeal and oral argument was held on January 6, 2026.

Youth-Related Actions

Beginning in January 2022, we became subject to litigation and other proceedings that were filed in various federal and state courts alleging that Facebook and Instagram cause "social media addiction" in users, with most proceedings focused on those under 18 years old, resulting in various mental health and other harms.

Putative class actions have been filed in the United States, Brazil, and Canada on behalf of users in those jurisdictions, and numerous school districts, municipalities, and tribal nations have filed public nuisance claims in the United States, Brazil, and/or Canada based on similar allegations.

Beginning in January 2022, we became subject to litigation and other proceedings that were filed in various federal and state courts in the United States as well as other jurisdictions alleging that Facebook and Instagram cause "social media addiction" in users, with most proceedings focused on those under 18 years old, resulting in various mental health and other harms.

Putative class actions have been filed in the United States, Brazil, Canada, Europe, and elsewhere on behalf of users in those jurisdictions, and numerous school districts, municipalities, and tribal nations have filed public nuisance claims in the United States, Brazil, and/or Canada based on similar allegations.

On October 6, 2022, the U.S.

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These additional lawsuits include allegations regarding violations of the Children's Online Privacy Protection Act (COPPA), child sexual abuse material and other child safety concerns, as well as violations of state consumer protection laws, unfair business practices, public nuisance, and products liability, with proceedings focused on our alleged business practices (including the use of end-to-end encryption) and harms to users under 18 years old.

Certain of the lawsuits described above have since expanded to include various other claims relating to our services, including with respect to age verification, AI and AI chatbots, deceptive advertising, illicit or illegal activity with respect to drugs, fraud, and firearms, and privacy-related matters, among others.

These lawsuits seek damages and injunctive relief, and include cases filed by various state attorneys general in In re Social Media Adolescent Addiction Product Liability Personal Injury Litigation in the U.S.

District Court for the Northern District of California, as well as various state courts around the country.

Beginning in November 2024, counsel for thousands of individual claimants began sending mass arbitration demands relating to "social media addiction" and related harms allegedly caused by Instagram.

We are also subject to government investigations and requests from multiple regulators in various jurisdictions globally concerning the use of our products and services, and the alleged mental and physical health and safety impacts on users, particularly younger users.

Trial in the first of the personal injury cases began on January 27, 2026 in Judicial Council Coordination Proceeding No.

5255 pending in Los Angeles County California Superior Court.

Trial in the first of the state attorneys general cases is currently scheduled to begin on February 2, 2026 in the First Judicial District Court of New Mexico, in a case brought by the New Mexico Attorney General.

Trials in other state attorneys general cases are currently scheduled or expected to be scheduled in the second half of 2026 or in 2027.

The first trial in the multidistrict litigation ( In re Social Media Adolescent Addiction Product Liability Personal Injury Litigation ) is a school district bellwether case and is scheduled to begin on June 15, 2026.

Across the cases described above, the damages or penalties that plaintiffs have indicated they intend to seek range widely in amount, including in certain cases up to the high tens of billions of dollars.

In addition, beginning in November 2024, counsel for over one hundred thousand individual claimants have sent mass arbitration demands relating to "social media addiction" and related harms allegedly caused by Instagram.

On May 16, 2024, the European Commission opened formal proceedings assessing our compliance with certain requirements under Articles 28, 34, and 35 of the Digital Services Act (DSA), including the way in which we identified, assessed, and mitigated against certain systemic risks to minors and other vulnerable users that may stem from the design and functioning of Instagram and Facebook.

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Supreme Court on October 2, 2024, which was denied.

Beginning on July 7, 2023, multiple putative class actions were filed against us in the U.S.

We then moved to compel arbitration, which the district court denied.

We appealed the denial of our motion to compel arbitration to the Ninth Circuit on December 3, 2025.

The matter is stayed in district court pending resolution of our appeal.

Beginning on July 7, 2023, multiple cases, including putative class actions, were filed against us in the United States and elsewhere, alleging that we improperly acquired, distributed, and used various copyrighted materials and/or other types of data to train our artificial intelligence models and seeking unspecified damages and injunctive relief.

In the United States, statutory damages for copyright liability are calculated on a per work basis, which may result in substantial damages, particularly given the large volumes of data required to train AI models.

The cases in the United States, which were filed in

District Court for the Northern District of California ( Kadrey, et al.

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, which was subsequently transferred to the U.S.

District Court for the Northern District of California) alleging that we used various copyrighted books and materials to train our artificial intelligence models, and seeking unspecified damages and injunctive relief.

These cases have all been consolidated into Kadrey, et al.

District Court for the Northern District of California), have been consolidated into Kadrey, et al.

Meta Platforms, Inc .

In the first quarter of 2024, the U.S.

Supreme Court heard argument in Vivek H.

Murthy, Surgeon General, et al.

Missouri, et al.

, on the question of whether federal government officials violated the First Amendment in their communications with the company and others related to content moderation practices, and heard argument in Netchoice, et al.

Paxton and Moody, et al.

Netchoice et al.

, regarding the application of the First Amendment relating to content moderation on tech platforms.

As to Murthy , a majority of the Supreme Court decided the case on plaintiffs' standing, declining to rule on the First Amendment questions, and sending the case back down to the lower courts where the case continues.

As to NetChoice , the Supreme Court unanimously vacated the intermediate appellate court decisions, remanding the cases back to the lower courts.

Although we are not a party in these actions, the ultimate resolution of the lawsuits and similar others still pending in the federal courts could impact our business.

Motions for summary judgment were heard in this case on May 1, 2025, including on the issue of the applicability of the fair use defense to use of copyrighted books for generative AI model training.

On June 25, 2025, the court granted our motion for summary judgment on fair use as to the named plaintiffs in the case.

The parties will proceed to brief the remaining claim of copyright infringement due to alleged distribution of books to third parties during the downloading process.

The court is scheduled to hear summary judgment motions on July 16, 2026.

Beginning in November 2025, additional cases with similar claims were filed against us in the U.S.

District Court for the Northern District of California ( Entrepreneur Media v.

Meta Platforms, Inc., Carreyrou et al.

Anthropic PBC, et al.

and TED Entertainment, Inc.

Meta Platforms, Inc .).

We expect some of these cases will be set for trial beginning in mid-2027.

On April 30, 2024, the European Commission opened formal proceedings against us to assess Facebook and Instagram's compliance with certain requirements under Articles 14, 16, 17, 20, 24, 25, 34, 35, and 40 of the DSA, regarding a range of topics including elections, content reporting and appeals, third-party access to data, political content recommendations, potential deceptive advertising and disinformation, including the way in which we identified, assessed, and mitigated against certain systemic risks on Instagram and Facebook.

We are also responding to regulatory inquiries and litigation related to allegedly deceptive advertising, including but not limited to financial scams, in other parts of the world.

On September 18, 2024, staff of the Consumer Financial Protection Bureau (CFPB or Bureau) initiated a Notice and Opportunity to Respond and Advise (NORA) process related to its investigation of advertising for financial products and services on our platform, informing us that staff may recommend to the Director of the CFPB that the Bureau take legal action alleging violations of the Consumer Financial Protection Act, including based on our alleged receipt and use for advertising of financial information from third parties through certain advertising tools as well as our related user disclosures and controls, and provided us with an opportunity to respond.

We disagree with the claims staff is considering and believe an enforcement action is unwarranted, and have responded through the NORA process.

The result of the NORA process is uncertain at this time, but if the Director authorizes an action against us, the CFPB could file a lawsuit in the near-term and seek financial penalties and equitable relief.

The Commission issued preliminary findings with respect to some of these topics on October 24, 2025 reflecting its preliminary view that we have infringed DSA obligations related to notice and action mechanisms for illegal content reporting, content moderation decision appeals, and data access for researchers.

We have an opportunity to respond to the preliminary findings, and would also have an opportunity to appeal a final decision by the Commission.

We are also responding to regulatory inquiries and litigation related to allegedly deceptive advertising, including but not limited to financial scams and the use of our services to promote deceptive activity, in other parts of the world.

We are also subject to other litigation and government inquiries and investigations relating to advertising on our platform and our alleged role in causing or contributing to various societal harms, including illegal activity with respect to drugs, fraud, deceptive activity, unlawful discrimination, and other harms potentially impacting large numbers of people.

We have received additional requests relating to these and other topics including in connection with news outlet reporting regarding these issues in the fourth quarter of 2025.

In addition, we are subject to litigation and other proceedings involving law enforcement and other regulatory agencies, including in particular in Brazil, Russia, and other countries in Europe, in order to ascertain the precise scope of our legal obligations to comply with the requests of those agencies, including our obligation to disclose user information in particular circumstances.

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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 3. Legal Proceedings