Google and two Disney companies recently settled lawsuits alleging that the companies violated children’s privacy laws, once again demonstrating a heightened interest in protecting children online and putting content creators and channel owners on notice that they will be subject to strict liability for violations of federal and state privacy laws. On August 18, 2025, Google and its subsidiary YouTube agreed to pay $30 million to settle a class action lawsuit claiming that YouTube collected personal information of children under age 13 for targeted advertising without parental consent, in violation of state privacy laws and the Children’s Online Privacy Protection Act (COPPA). A few weeks later, Disney agreed to pay $10 million to settle Department of Justice (DOJ) and Federal Trade Commission (FTC) allegations that videos the company uploaded to YouTube were not properly marked as “Made for Kids” and the company allowed personal information to be collected from children who viewed videos without notifying parents or obtaining consent, as required by the COPPA Rule. Disney now faces a separate class action lawsuit.

The Google Class Action Settlement

This is not the first time Google and YouTube entered into a multimillion dollar settlement for alleged children’s privacy violations; as we previously reported, the New York State Attorney General and the FTC sued the companies for privacy violations in 2019, alleging that YouTube collected children's personal information for targeted advertising without parental consent and failed to post a clear website privacy policy describing its practices, in violation of COPPA. That lawsuit resulted in a $170 million penalty – the largest COPPA settlement at the time. In addition, YouTube was ordered to require content creators to indicate if videos they upload to YouTube are “Made for Kids” or “Not Made for Kids.”

Following the 2019 settlement, the parents of 34 children filed a class action lawsuit against Google, YouTube, and several YouTube channel owners in California district court, claiming that the use of persistent identifiers to track and collect children’s personal information without parental consent violated multiple state laws and COPPA and amounted to an “unlawful invasion of the right to privacy and reasonable expectation of privacy of millions of children under the age of 13 from July 1, 2013 through September 4, 2019.” The defendants initially prevailed in district court, arguing that the state laws cited in the class action suit were preempted by COPPA and COPPA provides no private right of action. On appeal, however, in July of 2023, a three-judge panel of the Ninth Circuit reversed and remanded. The panel held that “COPPA’s preemption clause does not bar state-law causes of action that are parallel to, or proscribe the same conduct forbidden by, COPPA.” The FTC submitted an amicus brief in support of the Ninth Circuit’s interpretation of the COPPA preemption clause.

In January of 2025, the district court dismissed several child-directed YouTube channel owners from the suit but allowed the case to proceed against Google and YouTube. After mediation, Google and YouTube agreed to the $30 million settlement of the long-running legal battle. If approved by the district court judge, the settlement would apply to children under 13 who viewed YouTube content between July 1, 2013, and April 1, 2020.

The Disney Lawsuits

On September 2, 2025, DOJ filed a complaint upon notification and referral from the FTC alleging that Disney violated the COPPA Rule by failing to properly label some YouTube videos as “Made for Kids.” The complaint also alleges that Disney collected personal information from children under 13 who viewed the videos and used the information for targeted advertising to children. Under the proposed settlement, Disney will pay $10 million, notify parents, and obtain parental consent before collecting personal information from children under 13. Disney must also implement a program to review whether YouTube videos should be designated as “Made for Kids.”

Just days after the COPPA settlement was announced, on September 5, 2025, a class action lawsuit against the company was filed in California federal court.

Children’s privacy and COPPA compliance remain top priorities for regulators and private plaintiffs. Based on the trajectory of the Google litigation, COPPA’s preemption clause – even in instances where businesses pay a civil penalty to the government to settle allegations of violation – does not bar filing suit under state law.