In A.A. et al. v. Roku, Inc., six minor children, through their guardians, sued Roku for allegedly collecting their personal data, including voice recordings, geolocation data, and browsing histories, and using that data to target them with advertisements, in violation of federal and state privacy laws. A.A. et al. v. Roku, Inc., Case No. 25-cv-06284-NW, 2026 WL 1349064 (N.D. Cal. May 14, 2026),
The United States District Court for the Northern District of California granted Roku’s motion to compel arbitration, ruling that the minor plaintiffs were bound by the arbitration clause their parents accepted in Roku’s terms of service, even though the children never signed anything themselves.
Roku makes internet-connected devices used to stream video content. To activate and use the streaming function of any Roku product, customers must create a Roku account. Since at least February 2015, Roku has required individuals creating an account to check a box confirming their agreement to Roku’s terms. Those terms require accountholders to be at least 18 years old or the legal age of majority. Roku updated its terms most recently in February 2024, and existing customers were required to affirmatively consent to the updated terms to continue using Roku’s streaming services. Roku also notified customers by email of the update.
Accepting Roku’s terms means accepting its dispute resolution terms, which include a mandatory arbitration clause and a class action waiver. The clause covers any dispute arising from a Roku account, any Roku product, software, or service, any advertising or promotions conducted by or for Roku, or any use or disclosure of a user’s personal information. Customers have 30 days after accepting the terms to opt out of arbitration by sending written notice to Roku. None of the plaintiffs’ guardians did so.
All six plaintiffs were under 13 years old when they used Roku streaming sticks and Roku-enabled TVs to view child-directed content. Their parents and legal guardians had purchased the Roku devices, created the accounts, and accepted Roku’s updated terms. The children themselves never accepted any terms. The families brought 14 claims alleging that Roku violated the Video Privacy Protection Act, 18 U.S.C. § 2710, and various state laws by targeting advertisements at children and collecting, sharing, and profiting from their personal information.
Roku moved to compel arbitration. The central dispute was not whether a valid arbitration agreement existed; the parties agreed that it did, between Roku and the guardians. The question was whether the children, who were nonsignatories, could be compelled to arbitrate claims involving their own personal data.
The court analyzed Roku’s argument under the doctrine of equitable estoppel, which provides that a nonsignatory can be bound to an arbitration agreement where a preexisting relationship exists between the nonsignatory and one of the parties to that agreement, making it equitable to compel arbitration. Under California law, the parent-child relationship is one such preexisting relationship.
The families argued that the preexisting relationship doctrine applies only in narrow contexts, such as contracts for medical care or school activities, relying on In re Ring LLC Privacy Litigation, No. CV-1910899 (C.D. Cal. 2021), which had drawn a distinction between those limited contexts and ordinary consumer goods. The court rejected that argument and joined a growing number of courts that have found In re Ring goes too far. Citing E.A.R.R. et al. v. Roku, Inc., No. EDCV 25-2474 JGB (DTBx), 2026 WL 369238 (C.D. Cal. Feb. 6, 2026), a case involving the same defendant and the same doctrine, as well as S.G. v. Epic Games, Inc., 796 F. Supp. 3d 614 (N.D. Cal. 2025), and Yeh v. Tesla, Inc., No. 23-CV-01704-JCS, 2023 WL 6795414 (N.D. Cal. Oct. 12, 2023), the court found that children can be bound by arbitration agreements signed by their parents in the context of consumer goods, not just medical or educational contracts.
The record supported the inference that the guardians accepted Roku’s updated terms in February 2024 with knowledge that their children were using the service. The children benefited directly from that account access: they watched child-directed content on Roku’s platform through accounts their guardians maintained. As the court put it, “[i]f the law were otherwise, individuals could avoid contractual obligations governing the use of online accounts ‘simply by having third parties create accounts and then using them.’” A.A., 2026 WL 1349064, at *4 (quoting Motise v. America Online, Inc., 346 F. Supp. 2d 563, 566 (S.D.N.Y. 2004)). The court found it equitable to bind the children to the arbitration obligation their guardians accepted, compelled all six plaintiffs to arbitration, and stayed the case pending the outcome.
Here is why this case matters: a parent’s acceptance of a platform’s terms of service can have direct consequences for their children’s legal rights, including the right to bring privacy claims in court as a class. For companies offering account-based services that minors use, this decision reinforces that a well-drafted arbitration clause, properly disclosed and accepted by a parent or guardian, can reach claims brought on behalf of the children themselves. And for families, it is a reminder that the opt-out window in an arbitration clause is not just fine print: it is a meaningful choice with lasting consequences.
