Brian Hall recently shared his perspective on the regulatory implications Roblox’s advertising strategy may face in the GamesBeat article, "Roblox is turning its product roadmap into advertising inventory." 

According to the piece, Roblox has been partnering with brands like e.l.f. Beauty and NYX Professional Makeup to sponsor new platform feature rollouts without being fully transparent with users about the advertorial nature of these brand campaigns. As Brian explains to GamesBeat, "There's not really a clear definition of what is an advertisement [on Roblox]; the FTC is the agency that regulates this, and they focus less on how you label it, or what Roblox is calling an ad versus not an ad, and more on how a user experiences it,"

Brian aptly questions the commercial purpose behind branded avatar items made available to users of all ages, including those under 13. "If you're going into the Roblox store, and it's saying, 'here's this branded makeup you can put on your avatar,' what really is the purpose, if not to drive outside sales?"

He believes this is the policy likely to tempt FTC scrutiny. "That's where Roblox is going to maybe find some risk, if they're taking this hard-line position that these things aren't advertisements, and [that] they're not showing ads to kids,” he observes. "If the FTC says, 'well, we think you actually are,' that's where they could get in trouble."

Read the full article in GamesBeat.

On Friday, February 1, the Federal Trade Commission (FTC) released guidelines for mobile privacy.  The guidelines target key players in the growing mobile device industry, including Apple, and Google, as well as mobile app developers, advertising networks and others.  Guideline recommendations included asking industry leaders to promote best practices and let consumers know immediately what apps will do with their personal information and let those consumers give their permission for that data to be collected and used.    It was also recommended that Privacy Policies set in place by App Developers should be easier to understand and give consumers a clear sense of how their information will be used.  A “do not track” system has also been recommended.

 “The mobile world is expanding and innovating at breathtaking speed, allowing consumers to do things that would have been hard to imagine only a few years ago,” said FTC Chairman Jon Leibowitz.  “These best practices will help to safeguard consumer privacy and build trust in the mobile marketplace, ensuring that the market can continue to thrive.”

 To access the full set of FTC recommendations, click here.

 For more information about our Internet, New Media & Entertainment Practice, please contact Greg Akselrud at (818) 444-4503 or