Wozniak

I. FACTUAL AND PROCEDURAL BACKGROUND

A. YouTube cryptocurrency scams YouTube, LLC (YouTube) is a video-sharing service that enables its users to view, post, and comment on video content hosted on its platform. 2 Users can create their own YouTube channels, thereby making it easy for other users to find a creator’s content in one place and be notified when new content is uploaded. The most popular YouTube channels have millions of subscribers. 1 “We derive our facts from those properly pleaded in the complaint and matters properly judicially noticed. [Citations.] We take as true properly pleaded material facts alleged in the pleadings, disregarding contentions, deductions, and conclusions of fact or law. [Citation.]” (County of Santa Clara v. Superior Court (2023) 87 Cal.App.5th 347, 355, fn. 2.) 2 YouTube is a wholly owned and controlled subsidiary of defendant Google, LLC (Google).

2 User-personalized video recommendations appear when a user first opens the YouTube website or mobile app, and then automatically play after a video ends. YouTube utilizes an algorithm that recommends videos to users based on their personal information and data that YouTube and Google have…