TikTok Pays $400 Million to Settle DOJ COPPA Suit on Under-13 Data Collection

The settlement resolves a 2024 complaint that documented TikTok's failure to honor verified parental deletion requests and its retention of accounts known to belong to minors. Court filings reference internal ByteDance metrics showing persistent under-13 traffic despite age gates. The payment splits into $300 million immediate and $100 million contingent on vacating the prior Musical.ly consent decree.

Ownership restructuring announced in January 2025 involving Oracle, Silver Lake, and MGX does not alter data flows to ByteDance servers in China. Procurement records and prior FTC COPPA enforcement actions against Musical.ly indicate repeated compliance shortfalls rather than isolated incidents. Technical evidence from the case includes server logs showing continued collection after flagged accounts.

This pattern aligns with documented cases where platforms treat COPPA as a settlement cost rather than an engineering constraint. No independent audit of recommendation algorithm training data was required, leaving open whether under-13 profiles continue feeding models.

Next enforcement actions will likely target the new U.S. entity structure once data-sharing agreements are filed with CFIUS. Regulators have signaled interest in subpoenaing algorithm training sets in parallel Meta COPPA proceedings.