VII. TRADE AND COMMERCE IN THE FILING STATES
45. As described in this Complaint, Meta has engaged and continues to engage in conduct that constitutes, is in connection with, or affects “trade,” “commerce,” “advertising,” “business,” “merchandise,” “occupation,” “sale,” “vocation,” “consumer acts or practices,” and/or “consumer transactions,” as those terms are defined in the Filing States’ UDAP Statutes.
We agree to provide you with the Instagram Service. . . . Instead of paying to use Instagram, by using the Service covered by these Terms, you acknowledge that we can show you ads that businesses and organizations pay us to promote on and off the Meta Company Products. We use your personal data, such as information about your activity and interests, to show you ads that are more relevant to you.
48. Meta provides tools for businesses to advertise on its Platforms. Meta’s “Campaign Ideas Generator” provides “campaign ideas, pre-made assets, and resources that are specific to your small business needs.”
49. Meta provides other features and tools so that it and its users can generate revenue and engage in commerce. For example, the Instagram Shopping feature allows small businesses and global brands alike to advertise and sell goods, which users can purchase directly through the Instagram Platform.
50. Meta encourages and provides tools for users to engage in commerce themselves. Meta’s creator monetization tools, for example, allow users to make money through Instagram and Facebook. Meta has also signaled that it is testing creator monetization tools on its Horizon Worlds Platform. 51. Meta also allows direct advertising by users on its Instagram Platform. In November 2013, Meta created “Sponsored Posts,” where Instagram users could use posts in their “Feed” to promote a specific product. As a result, many Instagram users (including young users) became “influencers,” compensated by advertisers for promoting a product through their posts.
52. In addition, in approximately June 2023, Meta began offering Meta Verified to Instagram and Facebook account holders within the United States. Account holders can purchase a Meta Verified subscription bundle that includes account verification with impersonation protections and access to increased visibility and support. Meta Verified is available on Instagram and Facebook for a monthly fee of $11.99 when a user subscribes from the web (Facebook account holders only) and $14.99 when a user subscribes in the Instagram or Meta apps.
 Cal. Bus. & Prof. Code § 17200; Colo. Rev. Stat. §§ 6-1-106, 6-1-105; Conn. Gen. Stat. § 42-110b(a); 6 Del. Code Ann. § 2511(6); O.C.G.A. § 10-1-392(7), (10), (28); Haw. Rev. Stat. § 480-1; 815 ILCS 505/1(f); Ind. Code § 24-5-0.5-2(a)(1); K.S.A. § 50-624; Ky. Rev. Stat. § 367.110; LA. REV. STAT. ANN. § 51:1402(10); ME. REV. STAT. ANN. tit. 5, § 206(3); Mo. Rev. Stat. §407.020 as defined in §407.010(7); Neb. Rev. Stat. § 59-1602; N.J. STAT. ANN. §. 56:8-1; N.C.G.S. § 75-1.1(a); N.D. Cent. Code § 51-15-02; Ohio Rev. Code § 1345.01; O.R.S. § 646.605(8); 73 P.S. § 201-2(3); R.I. Gen. Laws § 6-13.1-1(5); S.D.C.L. ch. 37-24; Va. Code § 59.1-198; Wash. Rev. Code § 19.86.010(2).
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