1. Cause of Action Theory
Strict Liability § 2(b)
2. Alleged Algorithmic Defect Mechanisms
Select Active Features
3. Target Adolescent Symptom Cohorts
Circadian / Severe Sleep Loss
Clinical Depression Trajectory
Adolescent Anxiety Escalation
Body Dysmorphia / Disordered Eating
Self-Harm Ideation
⚖️ Plaintiff Contentions
🛡️ Defense Contentions
Statutory & Burden Analytics
Burden Score: 0.78
Evidentiary Burden Index (Plaintiff Causation)
78%
CDA Section 230 Preemption Vulnerability (Defense Shield)
24%
Low CDA preemption risk: Non-speech structural design defect outside 230(c)(1) protections.
Doctrine: Restatement (Third) of Torts § 2(b)
Requires proof that foreseeable risks of harm could have been reduced or avoided by adoption of a reasonable alternative design (e.g. chronological feed, mandatory sleep-time killswitch).
Relevant Case: Lemmon v. Snap, Inc., 995 F.3d 1085 (9th Cir. 2021)
Internal Company Notice & Research Record
Internal teen research slide deck: "32% of teen girls said that when they felt bad about their bodies, Instagram made them feel worse."
Evidentiary Exhibit: Bates PLTF-META-004921