Key Notes
- San Diego County alleges AppLovin delivered age-inappropriate advertising in games played by children, including on a device with parental controls enabled.
- The complaint challenges alleged device fingerprinting despite tracking opt-outs and seeks changes to how AppLovin identifies and protects child users.
- The county is seeking an injunction, restitution and civil penalties in a separate case from AppLovin's advertising-data dispute with Unity.
San Diego County has sued AppLovin over allegations that its advertising technology exposed children playing mobile games to sexually explicit and other age-inappropriate ads, while collecting sensitive information despite parental controls and tracking opt-outs. The case puts the advertising systems behind free-to-play games under scrutiny, rather than just the content of the games themselves.
The county announced the action on October 5 as part of the launch of its Consumer Fairness and Public Protection Division. Filed in San Diego Superior Court on behalf of the People of California, the lawsuit alleges violations of the state’s False Advertising Law and Unfair Competition Law. These are allegations in a civil complaint, not findings by a court.
Adult Ads Inside Games Rated for Children
The complaint describes tests conducted by the county’s lawyers on a Samsung tablet belonging to a six-year-old, with Google Family Link parental controls enabled. It says Street Dude displayed sexually explicit ads during a January 2025 investigation. The filing also identifies Rope Savior 3D, rated E for Everyone, as showing ads for the adult-themed chatbot app PolyBuzz and a real-money competition game.
The county’s argument is that the age rating of a downloaded game did not prevent adult material from arriving through its advertising inventory. Its examples extend beyond sexual content to promotions for products and services unsuitable for children. That distinction matters for parents choosing games by their store ratings: the complaint challenges what appears during play, not simply what is shown on an app’s installation page.
AppLovin supplies technology that helps mobile developers monetize their apps and advertisers acquire users. Players can therefore encounter its ads without deliberately downloading an AppLovin-branded product. The lawsuit focuses on this layer of the mobile gaming business, where an otherwise simple puzzle or casual game can become the delivery channel for third-party advertising.
Tracking Opt-Outs and Device Fingerprinting
A second part of the case concerns data collection. The county alleges that AppLovin combined technical details from devices into persistent identifiers, a practice known as fingerprinting, even when operating-system privacy settings or parental controls were supposed to restrict tracking. It claims that the combined information could reveal details about a child’s home, school and daily routines.
The filing also alleges that AppLovin removed a technical feature called COPPA Support from its software development kit in September 2024. According to the county, developers had used that mechanism to identify users under 13. The complaint presents its removal as part of a wider failure to distinguish children from adult users, rather than an isolated instance of an unsuitable ad slipping through.
AppLovin has previously given a different account of its data practices. In a company explanation, CEO Adam Foroughi said that when iOS users opt out of tracking, AppLovin does not create persistent alternative device identifiers. He described its advertising predictions as using temporary, non-identifying signals in that situation. Those statements predate this lawsuit and are not a response to the county’s specific evidence.
Bloomberg reported that AppLovin did not immediately respond to its request for comment on the new case.
What the County Wants AppLovin to Change
The county is seeking an injunction, restitution and civil penalties. Among the requested changes are effective identification of child users, respect for tracking restrictions on children’s devices and reasonable age-assurance measures. The filing also challenges allegedly deceptive ad interfaces, including interactions that it says turn attempts to close an ad into billable engagement. None of those remedies has been awarded by the filing itself.
This is separate from AppLovin’s dispute with Unity. As we detailed in our Unity lawsuit coverage, AppLovin accused its rival of collecting advertising data through Ad Quality SDK. A court subsequently rejected AppLovin’s injunction request, while that litigation continued. The San Diego action instead makes AppLovin the defendant and concerns consumer protection, children’s data and advertising content.
For mobile developers, the issues raised are concrete: whether child-user signals reach their advertising partners, whether privacy choices are respected and whether ads match the audience of the game carrying them. The county’s requested injunction would address those parts of ad delivery if granted; the complaint does not itself establish a ban on AppLovin’s services.
