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Ninth Circuit partially lifts injunction on California child online design law

Published
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11

Why it matters

The Ninth Circuit has partially vacated a preliminary injunction blocking California's Age-Appropriate Design Code Act, allowing some provisions to take effect while keeping others blocked. The panel found that a district court had gone too far in enjoining the statute wholesale, but upheld the injunction for data-use and dark-patterns restrictions. The court determined that key statutory terms—"materially detrimental," "best interests," and "well-being"—are unconstitutionally vague.

NetChoice, a tech industry trade group, brought the challenge against California Attorney General Rob Bonta. The CAADCA was enacted in 2022 and applies to businesses offering online services, products, or features likely to be accessed by children. It requires age estimation, high-default privacy settings, child-facing privacy notices, and reporting tools. The litigation has moved quickly: a district court blocked enforcement, the Ninth Circuit narrowed that injunction in 2024, the district court again enjoined enforcement in March 2025, and now the Ninth Circuit has split the difference once more. The practical compliance landscape for covered businesses remains unsettled and may shift again on remand.

The ruling immediately changes which provisions of a major children's privacy law can be enforced, creating fresh compliance obligations for platforms and online services while litigation continues. The panel's reasoning on vagueness and facial First Amendment challenges also carries weight beyond California, as similar design-code laws are emerging in other states. Attorneys representing digital platforms should monitor the remand proceedings and track parallel state legislation closely.

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