Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox.


Roblox, a multibillion-dollar public company based in California, says its mission is to “bring the world together through play.” The Roblox platform is an immersive virtual space consisting of 3D worlds in which users can play games, attend concerts and throw birthday parties, among a host of other activities. With more than 54 million daily users and over 40 million games and experiences, it’s not surprising that in 2021 alone, users from 180 different countries spent more than 40 billion hours in this closed platform metaverse.


But according to an investigation by, advertising is being surreptitiously pushed in front of millions of users on Roblox by a multitude of companies and avatar influencers. Such digital deception is possible because Roblox has failed to establish any meaningful guardrails to ensure compliance with truth in advertising laws. As a result, the brands Roblox has invited into its metaverse, including but not limited to DC Entertainment, Hasbro, Hyundai, Mattel, Netflix, NFL Enterprise, Nike and Paramount Game Studios, along with undisclosed avatar brand influencers and AI-controlled brand bots are running roughshod on the platform, manipulating and exploiting consumers, including its most vulnerable players – more than 25 million children.


Roblox community standards dictate that “[a]ds may not contain content intended for users under the age of 13,” presumably because this vulnerable age group, which makes up nearly half of Roblox’s daily users, can’t identify advertisements disguised as games (also known as advergames). In fact, even adults can have trouble accurately identifying advergames, which are found on Roblox in ever-increasing numbers. And as brands exploit unsuspecting consumers, tricking them into taking part in immersive advertising experiences, the companies, including Roblox, are taking users’ time, attention and money while extracting their personal data. And to make matters worse, Roblox lures consumers, including minors, to its platform with atypical earnings representations including claims that users can make millions of dollars as game developers, despite the fact that the vast majority of Roblox game developers will never make any money.



On April 19, filed a complaint with the FTC concerning Roblox and a multitude of other companies and sponsored avatar influencers on the platform urging the agency to open an investigation into the deceptive advertising on and by Roblox and take appropriate enforcement action. At a minimum, Roblox needs to stop breaching its own community standards and uphold its promise to parents that it will keep children as safe as possible online by enforcing its own rule prohibiting ads from containing contain intended for users under the age of 13.


In a world…


Advergames or branded worlds are everywhere on Roblox. Or maybe not. It is difficult to say exactly how many there are given the lack of clear and conspicuous disclosures on the platform. Take, for example, the following search results on Roblox for experiences based on the Netflix series “Stranger Things.” It is not at all clear, which, if any, of these experiences are sponsored.


Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox. - esenlerbocekilaclama
Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox. - esenlerbocekilaclama


The only indication that the second experience in the above search results – Stranger Things: Starcourt Mall – is an advergame is the small print under the name of the game that says “By Netflix,” which is not likely to be seen by most Roblox users (and even if they do notice this fine-print disclosure, they may not understand what it means).


And while the other experiences in the search results have the brand – Stranger Things – in their name, and brand imagery, none of those games are sponsored. So just because a brand is in the name of a game or experience doesn’t necessarily mean it is an advergame. Indeed, a search for “sports worlds” brings up more than a dozen Vans Worlds, only one of which is sponsored.


Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox. - esenlerbocekilaclama


Additional examples of undisclosed advergames in the Roblox metaverse include Nikeland, which has been visited more than 13 million times since Nike launched the branded world last fall. In Nike’s advertisement, users can “[e]xplore the world of sport, swim in Lake Nike, race your friends on the track [and] discover hidden secrets.” Then there’s Vans World (the sponsored one), which has been visited more than 63 million times since its launch last April, where users “[e]xplore different skate sites” and “[k]it out [their] Avatar in Vans Apparel.” Like with many worlds on Roblox, the apparel will cost you, as it must be purchased using Robux, Roblox’s virtual currency that powers its digital economy and has been crucial to the company’s success. (More on that later.)

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Venturing outside their own branded worlds

In addition to creating their own undisclosed advergames, brands have also deceptively infiltrated organic games. For example, in May 2020, to coincide with the release of the studio’s “Scoob!” movie that month, Warner Brothers’ Scooby-Doo brand made a limited promotional appearance in the organic pet-raising game, Adopt Me! which is the most popular game on Roblox of all time with more than 28 billion visits. During the promotional event in the family-friendly game, players could adopt Scooby as a pet and take a spin in the Mystery Machine. However, there was never any discernible disclosure to its audience that this was a sponsored event, nor did it comply with Roblox criteria that ads not be directed at children under the age of 13.



Perhaps even more insidious than the use of advergames and sponsored content within organic games is the use of undisclosed avatar influencer marketing. These avatars look and act like any other avatar you might run into on Roblox but these avatars, controlled by paid brand influencers, have a hidden agenda: to promote brands throughout the Roblox metaverse. And this means that there are potentially millions of players seeing, communicating with, and interacting with brand endorsers in the Roblox metaverse without ever knowing it.


For example, one (of at least a dozen) undisclosed Nike avatar influencers was complimented on his Nike gear by another player while in Nikeland, saying in the chat bar “how doyou get the gear,” “that nike hat is drippy,” while another player spotted the popular avatar in Nikeland and wrote, “TW dessi??? omgomg.”


Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox. - esenlerbocekilaclama


In addition to these avatar influencers (which, besides Nike, are used by numerous other brands including Vans, Hyundai and Forever 21) are Roblox’s army of more than 670 influencers, known as Roblox Video Stars. Roblox Video Stars are Roblox users who have large followings on social media and who Roblox has invited to participate in its influencer program in which the company rewards the Stars with a number of benefits, including free Roblox Premium memberships, early access to certain Roblox events and features, and the ability to earn commissions on Robux sales to users. And while Roblox requires the Stars to disclose their material connection to the platform in their social media posts, it does not require Stars to disclose their material connection to Roblox while on the platform itself even though the law requires such disclosure when brand influencers are interacting with users within the platform’s ecosystem.


Roblox Metaverse Playing Games with Consumers files complaint with the FTC concerning deceptive advertising on Roblox. - esenlerbocekilaclama


Brands are also using undisclosed AI-controlled avatars in advergames to promote consumer engagement and spending, among other things. In the Hot Wheels Open World (an undisclosed Mattel advergame), for example, AI bots urge players to upgrade their cars using virtual currency. While in the NASCAR showroom in Jailbreak, a popular organic game with a cops and robbers theme, which hosted an undisclosed sponsored event by NASCAR in February, AI bots let players know that NASCAR was giving away a car for free. In Nikeland, there were even AI bots modeled after real life NBA stars Giannis Antetokounmpo and LeBron James, each of which were giving away Nike gear to players. While Antetokounmpo tweeted to more than 2 million followers and posted to more than 12 million Instagram fans late last year that they should “[c]ome find me” in Nikeland because he was giving away “free gifts,” it appears that neither Antetokounmpo nor James ever controlled their avatars in Nikeland – rather, the look-a-like avatars interacting with other users were simply AI-controlled agents of Nike. In none of these examples did the brands inform users that they were seeing and interacting with AI-controlled brand avatars…. Continue Reading…


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