Original Research · Settlement Insight Research
TikTok's $400M Settlement Is 41% of Every COPPA Penalty Ever Collected
We compiled every U.S. enforcement action under the Children's Online Privacy Protection Act since the rule took effect in 2000 — 52 actions, verified one by one against FTC and DOJ primary sources. The dataset shows a law that spent two decades as a five-figure nuisance and became a nine-figure weapon: 98.2% of all COPPA dollars ever collected date from 2019 or later, and TikTok's August 2026 settlement is 70.2× the penalty the same company paid in 2019.
Published 2026-08-22 · Dataset CC-BY 4.0 · Every case linked to its government primary source
52
Enforcement actions since 2000
$964M
Total penalties collected
98.2%
Of all COPPA dollars date from 2019+
70.2×
TikTok 2026 vs. its own 2019 penalty
Eleven record-breaks in 26 years — each one bigger by an order of magnitude
COPPA's first civil penalties in 2001 were $30,000–$35,000. It took five years to reach $1 million (Xanga, 2006), thirteen more to reach nine figures (YouTube, 2019). Since then the record has fallen twice — Epic Games' $275M in 2022 and TikTok's $400M now. The defendant that set today's record also held it in 2019, at $5.7M, under its former name Musical.ly.
| Year | New record | Case |
|---|---|---|
| 2001 | $30K | United States v. Monarch Services, Inc. and Girls Life, Inc. |
| 2001 | $35K | United States v. Bigmailbox.com, Inc. and Nolan Quan |
| 2003 | $100K | United States v. Mrs. Fields Famous Brands, Inc. and Mrs. Fields' Holding Company, Inc. |
| 2004 | $400K | United States v. UMG Recordings, Inc. |
| 2006 | $1.0M | United States v. Xanga.com, Inc., John Hiler, and Marc Ginsburg |
| 2011 | $3.0M | United States v. Playdom, Inc. (a Disney subsidiary) and Howard Marks |
| 2018 | $5.0M | People of the State of New York v. Oath Inc. (f/k/a AOL Inc.) |
| 2019 | $5.7M | United States v. Musical.ly, Inc. (n/k/a TikTok Inc.) |
| 2019 | $170M | United States v. Google LLC and YouTube, LLC |
| 2022 | $275M | United States v. Epic Games, Inc. (COPPA-Anteil) |
| 2026 | $400M | United States v. TikTok Inc., TikTok Pty. Ltd., and ByteDance Ltd. |
Annual COPPA penalties, 2011–2026: the Big-Tech era changed the unit of account
Total penalties collected per year. Before 2019 the busiest COPPA year produced $4.2M across all cases; 2026 has produced $400M from a single one — with four months still to go.
The ten largest COPPA penalties in history
Nine of the ten largest COPPA penalties were announced in 2019 or later. The lone exception — New York's $4.95M Oath/AOL settlement — came in December 2018 and was itself the record at the time.
| # | Amount | Year | Defendants | Enforcer |
|---|---|---|---|---|
| 1 | $400M | 2026 | TikTok Inc., TikTok Pty. Ltd., ByteDance Ltd. (successor to Musical.ly) | DOJ (on behalf of FTC) |
| 2 | $275M | 2022 | Epic Games, Inc. (Fortnite) | DOJ (on behalf of FTC) |
| 3 | $170M | 2019 | Google LLC; YouTube, LLC | DOJ (on behalf of FTC) + State AG (New York) |
| 4 | $25M | 2023 | Amazon.com, Inc.; Amazon.com Services LLC | DOJ (on behalf of FTC) |
| 5 | $20M | 2023 | Microsoft Corporation | FTC / DOJ |
| 6 | $20M | 2025 | Cognosphere Pte. Ltd.; COGNOSPHERE, LLC (HoYoverse, Genshin Impact) | DOJ (on behalf of FTC) |
| 7 | $10M | 2025 | Disney Worldwide Services, Inc. (and affiliated companies) | DOJ (on behalf of FTC) |
| 8 | $6.0M | 2023 | Edmodo, LLC | DOJ (on behalf of FTC) |
| 9 | $5.7M | 2019 | Musical.ly, Inc. and Musical.ly (now operating as TikTok Inc.) | DOJ (on behalf of FTC) |
| 10 | $5.5M | 2021 | Google LLC; Tiny Lab Productions (Litauen); ursprünglich auch Twitter/MoPub, AppLovin, InMobi als Ad-Network-Beklagte | State AG (New Mexico) |
TikTok 2026: announced August 21, 2026; the consent order remains subject to court approval. Amounts are the COPPA-specific civil penalty where a larger package existed (Epic Games: $275M of a $520M total; YouTube: $136M federal + $34M New York).
Every COPPA enforcement action, 2000–2026
All 52 actions, including 9 brought by state attorneys general (who may enforce COPPA directly) and three resolved without a monetary penalty. Suspended judgments are listed at the amount actually payable, with the full judgment in the notes column of the CSV.
| Year | Penalty | Case | Enforcer |
|---|---|---|---|
| 2000 | — | FTC v. Toysmart.com, LLC and Toysmart.com, Inc. | FTC/DOJ |
| 2001 | $30K | United States v. Monarch Services, Inc. and Girls Life, Inc. | FTC/DOJ |
| 2001 | $35K | United States v. Bigmailbox.com, Inc. and Nolan Quan | FTC/DOJ |
| 2001 | $35K | United States v. Looksmart Ltd. | FTC/DOJ |
| 2001 | $30K | United States v. Lisa Frank, Inc. | FTC/DOJ |
| 2002 | $10K | United States v. American Pop Corn Company | FTC/DOJ |
| 2002 | $35K | United States v. The Ohio Art Company | FTC/DOJ |
| 2003 | $100K | United States v. Mrs. Fields Famous Brands, Inc. and Mrs. Fields' Holding Company, Inc. | FTC/DOJ |
| 2003 | $85K | United States v. Hershey Foods Corporation | FTC/DOJ |
| 2004 | $400K | United States v. UMG Recordings, Inc. | FTC/DOJ |
| 2004 | $75K | United States v. Bonzi Software, Inc. | FTC/DOJ |
| 2006 | $1.0M | United States v. Xanga.com, Inc., John Hiler, and Marc Ginsburg | FTC/DOJ |
| 2008 | $130K | United States v. Industrious Kid, Inc. and Jeanette Symons | FTC/DOJ |
| 2008 | $1.0M | United States v. Sony BMG Music Entertainment | FTC/DOJ |
| 2009 | $250K | United States v. Iconix Brand Group, Inc. | FTC/DOJ |
| 2011 | $3.0M | United States v. Playdom, Inc. (a Disney subsidiary) and Howard Marks | FTC/DOJ |
| 2011 | $50K | United States v. W3 Innovations, LLC (d/b/a Broken Thumb Apps) and Justin Maples | FTC/DOJ |
| 2011 | $100K | United States v. Jones O. Godwin (d/b/a Skid-e-kids) | FTC/DOJ |
| 2012 | $250K | United States v. RockYou, Inc. | FTC/DOJ |
| 2012 | $1.0M | United States v. Artist Arena LLC | FTC/DOJ |
| 2013 | $800K | United States v. Path, Inc. | FTC/DOJ |
| 2014 | $450K | United States v. Yelp, Inc. | FTC/DOJ |
| 2014 | $300K | United States v. TinyCo, Inc. | FTC/DOJ |
| 2015 | $60K | United States v. LAI Systems, LLC | FTC/DOJ |
| 2015 | $300K | United States v. Retro Dreamer et al. | FTC/DOJ |
| 2016 | $500K | In re Viacom Inc. (Operation Child Tracker) | State |
| 2016 | $250K | In re Mattel, Inc. (Operation Child Tracker) | State |
| 2016 | $85K | In re JumpStart Games, Inc. (Operation Child Tracker) | State |
| 2016 | — | In re Hasbro, Inc. (Operation Child Tracker) | State |
| 2016 | $950K | United States v. InMobi Pte Ltd. | FTC/DOJ |
| 2018 | $650K | United States v. VTech Electronics Limited | FTC/DOJ |
| 2018 | $235K | United States v. Prime Sites, Inc. (d/b/a Explore Talent) | FTC/DOJ |
| 2018 | $5.0M | People of the State of New York v. Oath Inc. (f/k/a AOL Inc.) | State |
| 2019 | $5.7M | United States v. Musical.ly, Inc. (n/k/a TikTok Inc.) | FTC/DOJ |
| 2019 | $35K | United States v. Unixiz, Inc., d/b/a i-Dressup.com | FTC/DOJ |
| 2019 | $170M | United States v. Google LLC and YouTube, LLC | State |
| 2020 | — | In the Matter of Miniclip S.A. | FTC/DOJ |
| 2020 | $150K | United States v. HyperBeard, Inc. | FTC/DOJ |
| 2021 | $100K | United States v. Kuuhuub Inc., Kuu Huub Oy, and Recolor Oy | FTC/DOJ |
| 2021 | $5.5M | New Mexico ex rel. Balderas v. Google LLC / Tiny Lab Productions (COPPA-Anteil) | State |
| 2021 | $2.0M | United States v. OpenX Technologies, Inc. | FTC/DOJ |
| 2022 | $1.5M | United States v. WW International, Inc. and Kurbo, Inc. | FTC/DOJ |
| 2022 | $275M | United States v. Epic Games, Inc. (COPPA-Anteil) | FTC/DOJ |
| 2023 | $6.0M | FTC v. Edmodo, LLC | FTC/DOJ |
| 2023 | $25M | United States v. Amazon.com, Inc. and Amazon.com Services LLC (Alexa) | FTC/DOJ |
| 2023 | $20M | United States v. Microsoft Corporation | FTC/DOJ |
| 2024 | $500K | People of the State of California and City of Los Angeles v. Tilting Point Media, LLC | State |
| 2024 | $5.0M | FTC and People of the State of California v. NGL Labs, LLC et al. | State |
| 2025 | $20M | FTC and DOJ v. Cognosphere Pte. Ltd. and COGNOSPHERE, LLC d/b/a HoYoverse | FTC/DOJ |
| 2025 | $10M | United States v. Disney Worldwide Services, Inc. et al. | FTC/DOJ |
| 2025 | $500K | United States v. Apitor Technology Co., Ltd. | FTC/DOJ |
| 2026 | $400M | United States v. TikTok Inc., TikTok Pty. Ltd., and ByteDance Ltd. | FTC/DOJ |
Methodology
We compiled every enforcement action brought under the Children's Online Privacy Protection Act and the FTC's COPPA Rule from the rule's effective date (April 2000) through August 22, 2026, from FTC and DOJ press releases, case filings, and state attorney-general announcements. Every action with a penalty of $1 million or more was independently re-verified against its government primary source. Amounts reflect the COPPA-specific civil penalty; where courts suspended judgments for inability to pay, the payable amount is used and the full judgment noted. Cases enforcing only the FTC Act (e.g., misrepresented safe-harbor membership) are included and flagged where they carry no COPPA penalty. Pending litigation without a resolution (e.g., Texas v. TikTok) is excluded.
The raw collection file, including per-case verification notes and source URLs, is published alongside the dataset. Errors or missing cases: l.goldberg@settlementinsight.com.
Cite this research
This analysis is released as an open, citable dataset. Researchers and journalists are welcome to use it with attribution.
Permanent identifier
10.5281/zenodo.22051424APA
Goldberg, L. (2026). COPPA Enforcement Database: Every Children's-Privacy Penalty, 2000–2026 [Data set]. Settlement Insight. https://settlementinsight.com/research/coppa-penalties
BibTeX
@dataset{goldberg_2026_coppa,
author = {Goldberg, Leonard},
title = {{COPPA Enforcement Database: Every Children's-Privacy Penalty, 2000--2026}},
year = 2026,
publisher = {Settlement Insight},
url = {https://settlementinsight.com/research/coppa-penalties}
}Download the data
Aggregated CSV files — CC BY 4.0. Free to use with attribution.