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The National Telecommunications and Information Administration has asked respondents forcomments in response to questions regarding the health, well being, safety, and privacy of minors online. In the following comment, Media Matters has specifically addressed the followingquestions:

1.

 What are the current and emerging risks of harm to minors associated with social media andother online platforms?

a.

 What harms or risks of harm do social media and other online platforms facilitate withrespect to, or impose upon, minors?

e.

 Are these harms evenly distributed? Or do they accrue disproportionately to certaindemographic or age groups or youths with accessibility requirements (for example, basedon gender, sexuality, age, race, or religion)?

Overview

Social media platforms, including TikTok, Facebook, Instagram, YouTube, and Rumble, are hosting— and in many cases profiting from — dangerous content that has the potential to cause physicalor psychological harm to minors. This harmful content proliferates on the platforms despitepre-existing policies that prohibit much of it.Media Matters and others have repeatedly identified harmful content on social media platformsthat targets minors, including content which promotes disordered eating, advances dangerousmedical misinformation and health scams, glamorizes extreme misogyny, and subjects LGBTQyouth to bullying, harassment, discrimination, and even violence.Social media companies must prioritize strengthening and adequately enforcing their communityguidelines, as well as adopting a more proactive approach to creating and maintaining safeonline spaces for young people.

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Minors are exposed to, and targeted with, TikTok content promoting disordered eating

Social media platforms hosting content that promotes or glorifies disordered eating isn’t new, butas the number of children and teens active online spikes and hyper-personalized algorithms favorengagement over user safety, young people are increasingly being exposed to this content.

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These factors, along with insufficient moderation practices, have created a toxic social medialandscape that children and teens are navigating with little to no protection from harmful content.

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TikTok Newsroom, “How TikTok recommends videos #ForYou,” June 18, 2020,https://newsroom.tiktok.com/en-us/how-tiktok-recommends-videos-for-you

2

Melinda Wenner Moyer, The New York Times, “Kids as Young as 8 Are Using Social Media More Than Ever, StudyFinds,” March 24, 2022, https://www.nytimes.com/2022/03/24/well/family/child-social-media-use.html

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Camden Carter, Media Matters for America, “Former Meta security expert details how executives ignored warningsthat the platform put teens in danger,” November 14, 2023,https://www.mediamatters.org/facebook/former-meta-security-expert-details-how-executives-ignored-warnings-platform-put-teens

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TikTok has become a favorite social media platform among young people. A 2023 Pew ResearchCenter report surveying digital habits of American teenagers found that two-thirds of teens useTikTok, with 58% reporting use every day.

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TikTok’s meteoric rise can be largely attributed to its “For You” page (FYP) algorithm, which feedsusers incredibly personalized content based on detected interests.

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While the FYP algorithm hasprovided users with entertainment and fostered positive community, it has also boosteddangerous pro-eating disorder content and trapped vulnerable users in isolated communities of struggling young people encouraging their peers to starve themselves.Although TikTok claims to prohibit content that displays or promotes disordered eating anddangerous weight loss behaviors, the company’s actions tell a different story.

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Much of TikTok’spro-eating disorder content aesthetically appeals to children and TikTok has repeatedly failed toprotect its young users from this content, often employing a reactive moderation strategy insteadof a proactive one.

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For example, Media Matters uncovered a series of starvation challenges circulating on TikTokwhere beloved Sanrio characters, such as Hello Kitty, were being co-opted to promote anorexia.

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Sanrio is a Japanese entertainment company that creates fictional characters for children and isbest known for its popular character Hello Kitty.

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These diets were named after and featuredSanrio characters instructing children to eat dangerously restrictive diets. TikTok reacted to thisreporting, seemingly restricting users’ ability to search for terms related to the starvationchallenges — after some of the search terms had already earned millions of views on theplatform.

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Sanrio, “About Sanrio,” https://www.sanrio.com/pages/about-sanrio

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Olivia Little, Media Matters, “TikTok is hosting pro-anorexia content that targets children,” February 1, 2023,https://www.mediamatters.org/tiktok/tiktok-hosting-pro-anorexia-content-targets-children

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Raymond Zhong and Sheera Frenkel, The New York Times, “A Third of TikTok’s U.S. Users May Be 14 or Under,Raising Safety Questions,” August 14, 2020,https://www.nytimes.com/2020/08/14/technology/tiktok-underage-users-ftc.html

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Olivia Little, Media Matters, “Pro-eating disorder content remains in heavy circulation on TikTok,” February 25, 2021,https://www.mediamatters.org/tiktok/pro-eating-disorder-content-remains-heavy-circulation-tiktok

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Rhea Bhatnagar and Olivia Little, Media Matters, “TikTok creators are promoting dangerous eating disorder tactics toyoung users -- and the company is letting them,” July 29, 2021,https://www.mediamatters.org/tiktok/tiktok-creators-are-promoting-dangerous-eating-disorder-tactics-young-users-and-company

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TikTok Community Guidelines, “Mental and Behavioral Health,” March 2023,https://www.tiktok.com/community-guidelines/en/mental-behavioral-health/

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Kari Paul, The Guardian, “From dance videos to global sensation: what you need to know about TikTok’s rise,”October 23, 2022, https://www.theguardian.com/technology/2022/oct/22/tiktok-history-rise-algorithm-misinformation

4

Emily A. Vogels and Risa Gelles-Watnick, Pew Research Center, “Teens and social media: Key findings from PewResearch Center surveys,” April 24, 2023,https://www.pewresearch.org/short-reads/2023/04/24/teens-and-social-media-key-findings-from-pew-research-center-surveys/

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TikTok is profiting from health scams and misinformation, some of which explicitly target youth

TikTok’s flagrant prioritization of profit over user safety has become strikingly apparent as thecompany continues its rapid, and often careless, expansion of advertisement and e-commercefeatures. This negligence directly and negatively impacts young people.Even though TikTok maintains that minors are served exclusively age appropriate ads and do nothave access to e-commerce features, the company’s lack of age verification enables children tocircumvent content restrictions and browse TikTok unprotected. And despite their experiencewith social media, multiple studies have found that young people are increasingly falling foronline scams.

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One study found that the number of individuals aged 20 or younger who reportedbeing the victims of cyber-fraud surged 156% between 2017 and 2020 — more than the 112%growth among people aged 60 or older.

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TikTok’s advertising and marketplace guidelines forbid potentially dangerous products, services,and scams, but the platform has failed to consistently enforce these rules, particularly when itcomes to wealthy advertising clients, leading users to be exposed to health scams andmisinformation.In early 2023, TikTok’s largest weight loss advertiser spent millions of dollars on ads that targetedusers with predatory scams promising unrealistic weight loss and extreme body transformations.

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Even though the content violated the platform’s advertising policies, which prohibit miracleweight loss claims and the exploitation of insecurities for profit, TikTok allowed the multi-milliondollar advertising campaign.

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In 2022, TikTok hosted a swarm of telehealth company advertisements, seemingly geared towardyoung users, that spread manipulative medical misinformation about attention deficithyperactivity disorder (ADHD), eventually resulting in multiple federal investigations for thealleged overprescription of stimulants.

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These companies placed over $14 million in ads that

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Olivia Little, Media Matters, “TikTok raked in over $14 million from a company under investigation for allegedlyoverprescribing stimulants,” May 26, 2022,https://www.mediamatters.org/tiktok/tiktok-raked-over-14-million-company-under-investigation-allegedly-overprescribing

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Olivia Little, Media Matters, “TikTok is enabling predatory ADHD advertisers to target young users,” February 8, 2022,https://www.mediamatters.org/tiktok/tiktok-enabling-predatory-adhd-advertisers-target-young-users

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Tara Wadhwa, TikTok Newsroom, “Coming together to support body positivity on TikTok,” September 23, 2020,https://newsroom.tiktok.com/en-us/coming-together-to-support-body-positivity-on-tiktok

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Olivia Little, Media Matters, “New year, new scam: TikTok’s largest weight loss advertiser is marketing predatoryscams to young users,” January 13, 2023,https://www.mediamatters.org/tiktok/new-year-new-scam-tiktoks-largest-weight-loss-advertiser-marketing-predatory-scams-young

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Sarah O’Brien, CNBC, “Tech-savvy teens falling prey to online scams faster than their grandparents,” August 10, 2021,https://www.cnbc.com/2021/08/10/tech-savvy-teens-falling-prey-to-online-scams-faster-than-their-grandparents.html

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Ron Lieber, The New York Times, “The Young Fall for Scams More Than Seniors Do. Time for a Warning.,” June 25,2021, https://www.nytimes.com/2021/06/25/your-money/young-seniors-scams-warning.html

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