4
additional in-game content (such as missions or Cosmetics), or in the premium version of the
game, obtain piñatas shaped like llamas that are filled with various items (“Llamas”).
17. To obtain Cosmetics, Battle Passes, and Llamas, kids use “V-Bucks.” For more
than a year after Epic began offering in-app purchases, kids could acquire V-Bucks simply by
pressing buttons with no parental or card holder action or consent. At that point, Epic
automatically billed the parents’ stored payment information for the V-Bucks. Epic did not
require parents to enter a PIN or password to authorize V-bucks purchases, or even allow them to
enable such a control.
18. Epic began and persisted engaging in these practices despite prior public law
enforcement actions against Amazon, Apple, and Google for failing to obtain parents’ consent to
charges in kids’ gaming apps. See, e.g., Complaint at 7-8, FTC v. Amazon.com, Inc., No. 2:14-
cv-01038 (W.D. Wash. July 10, 2014); FTC v. Amazon.com, Inc., No. C14-1038-JCC, 2016 WL
10654030, at *11 (W.D. Wash. July 22, 2016) (finding Amazon liable under Section 5 of the
FTC Act); Complaint at 4-5, In re Apple, Inc., No. C-4444 (Mar. 25, 2014); Complaint at 6-7, In
re Google, Inc., No. C-4499 (Dec. 2, 2014).
19. Many parents have been surprised to learn that Epic charged them hundreds of
dollars for kids’ in-app activities that they did not authorize. For example, one parent complained
to Epic:
Hello Epic Games, The charges associated with this account were made without
my authorization. This account is associated with my 10 year old son’s account and
I am really disappointed that there is no check and balances that alerted me of these
charges, and a 10 year old can purchase coins worth almost $500 so easily.
20. Another parent complained about authorizing a one-time purchase, but then
being billed by Epic for additional charges without consent:
Epic Games is swindling parents with unauthorized game purchases, tricking young
consumers & using shady practices for billing. I authorized a 1-time Epic Games
purchase for my 11 yr-old son, only to discover EG did NOT erase my credit card
info, & thus my son has been making unauthorized purchases, racking up $140 in
less than 8 days after the initial authorized purchase.
21. In fact, according to company documents, “Unrecognized and Fraudulent
Charges” – a category that includes unapproved kid charges – was among the top five reasons
consumers complained to Epic.
22. Epic employees also raised concerns about unauthorized kid charges and
recommended measures to address them. For example, in June 2018, Epic employees discussed
plans to give account holders the option not to save their credit card information. As an Epic