This week, TJLP and partner organizations Young People’s Alliance (YPA) and Encode filed a Complaint and Petition for Investigation before the Federal Trade Commission (FTC) alleging that Luka, the company behind popular generative AI-powered chatbot app Replika, deploys deceptive marketing and product design in violation of the FTC Act. Time Magazine also covered the Complaint.
The Complaint first describes Luka’s advertising and marketing materials, which target vulnerable populations with promises that the Replika app will provide them therapeutic and emotional benefits, despite no clinical validation of these claims, oversight, or regulation. These advertisements not only claim to resolve emotional struggles like loneliness and relationship difficulties, but they also make unsubstantiated claims regarding Replika’s language teaching capacity and financial coaching outcomes. These ads often misstate scientific research and feature fake testimonials from nonexistent users, displaying information from real people like social media handles to make testimonials appear genuine.
Then, the Complaint describes how Replika’s design features induce emotional dependence in users, resulting in consumer harm. The app’s design blurs the line between machine and human behavior, replete with characteristics intended to make Replika chatbots appear as human-like as possible. These design choices deceive users into developing unhealthy attachments to a commercial software product masquerading as a mechanism for human-to-human relationship. The Complaint explains numerous risks this poses to consumers, including mental health, financial, and social harms, especially for vulnerable communities like young people and neurodivergent users. Despite the app’s age-gaiting process, Replika remains popular among teenagers and several of the ads described above are directed to teens specifically.
The Complaint also gathers several examples of Replika’s deceptive practices and asks the FTC to investigate the matter further.
This work builds off of TJLP’s groundbreaking lawsuit against another AI chatbot company, Character AI, spotlighting the industry’s reliance on deceptive, human-like designs that increase young peoples’ emotional dependency on chatbots in harmful ways. “Widespread youth loneliness is not a simple problem that tech companies can solve through data-extracting and profit-seeking products,” said Melodi Dinçer, TJLP Policy Counsel. “We deserve tech products that empower and uplift vulnerable communities, not further isolate and mislead them.” TJLP continues to advocate on behalf of all consumers against the harms of AI chatbots.
Read the Complaint here.