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Walmart Deceptively Marketing to Kids on Roblox

Consumer Advocates Urge Action

Walmart Deceptively Marketing to Kids on Roblox

Consumer Advocates Urge Action

MADISON, CONN. January 23, 2023 – A coalition of advocacy groups led by ad watchdog truthinadvertising.org (TINA.org) is urging the Children’s Advertising Review Unit (CARU) – a BBB National Program – to immediately audit the Walmart Universe of Play advergame, a recent addition to the self-regulatory group’s COPPA Safe Harbor Program and bearer of one of the Program’s certification seals. According to a letter from TINA.org, Fairplay, Center for Digital Democracy and the National Association of Consumer Advocates, a copy of which was sent to Walmart, Roblox and the FTC, the retail giant is exposing children to deceptive marketing on Roblox, the online gaming and creation platform used by millions of kids on a daily basis.

Walmart’s first foray into the Roblox metaverse came last September, when it premiered two experiences, Walmart Universe of Play and Walmart Land, which collectively have been visited more than 12 million times. Targeted at – and accessible to – young children on Roblox, Universe of Play features virtual products and characters from L.O.L. Surprise!, Jurassic World, Paw Patrol, and more and is advertised to allow kids to play with the “year’s best toys” and make a “wish list” of toys that can then be purchased at Walmart.

As the consumer groups warn, Walmart completely blurs the distinction between advertising content and organic content, and simultaneously fails to provide clear or conspicuous disclosures that Universe of Play (or content within the virtual world) are ads. In addition, as kids’ avatars walk through the game, they are manipulated into opening additional undisclosed advertisements disguised as surprise wrapped gifts.

To make matters worse, Walmart is using the CARU COPPA Safe Harbor Program seal to convey the false message that its children’s advergame is not only in compliance with COPPA (Children’s Online Privacy Protection Act), but CARU's Advertising Guidelines and truth-in-advertising laws, as well as a shield against enforcement action.

“Walmart’s brazen use of stealth marketing directed at young children who are developmentally unable to recognize the promotional content is not only appalling, it’s deceptive and against truth-in-advertising laws. We urge CARU to take swift action to protect the millions of children being manipulated by Walmart on a daily basis.” Laura Smith, TINA.org Legal Director

“Walmart's egregious and rampant manipulation of children on Roblox — a platform visited by millions of children every day — demands immediate action. The rise of the metaverse has enabled a new category of deceptive marketing practices that are harmful to children. CARU must act now to ensure that children are not collateral damage in Walmart's digital drive for profit.” Josh Golin, Executive Director, Fairplay

“Walmart’s and Roblox’s practices demonstrate that self-regulation is woefully insufficient to protect children and teens online. Today, young people are targeted by a powerful set of online marketing tactics that are manipulative, unfair, and harmful to their mental and physical health. Digital advertising operates in a ‘wild west’ world where anything goes in terms of reaching and influencing the behaviors of kids and teens. Congress and the Federal Trade Commission must enact safeguards to protect the privacy and well-being of a generation of young people.” Katharina Kopp, Director of Policy, Center for Digital Democracy

To read more about Walmart’s deceptive marketing on Roblox see: /articles/tina-org-urges-action-against-walmarts-undisclosed-advergame-on-roblox

About TINA.org (truthinadvertising.org) 

TINA.org is a nonprofit organization that uses investigative journalism, education, and advocacy to empower consumers to protect themselves against false advertising and deceptive marketing.

About Fairplay 

Fairplay is the leading nonprofit organization committed to helping children thrive in an increasingly commercialized, screen-obsessed culture, and the only organization dedicated to ending marketing to children.

About Center for Digital Democracy

The Center for Digital Democracy is a nonprofit organization using education, advocacy, and research into commercial data practices to ensure that digital technologies serve and strengthen democratic values, institutions, and processes.

About National Association of Consumer Advocates

The National Association of Consumer Advocates is a nonprofit association of more than 1,500 attorneys and consumer advocates committed to representing consumers’ interests.

For press inquiries contact: Shana Mueller at 203.421.6210 or press@truthinadvertising.org.

walmart_caru_press_release_final.pdf