On June 26, 2026, Florida Attorney General (AG) James Uthmeier and Roku, Inc. announced a negotiated resolution of Florida’s enforcement action filed under the Florida Digital Bill of Rights (FDBR). Under the agreement, Roku will enhance its child protection features by giving parents greater control over their children’s streaming experience. The resolution includes no finding of wrongdoing and no civil fine.

The state’s underlying complaint, filed in October 2025, alleged that Roku collected, sold, and enabled the reidentification of sensitive personal data, including viewing habits, voice recordings, and precise geolocation, from children, without adequate notice to families or the parental consent the FDBR requires. The state contended that Roku shared and sold this data to data brokers such as Kochava, which allegedly used it to build profiles of children and to track individuals’ physical movements. Florida also alleged that Roku misrepresented the effectiveness of its privacy controls and opt-out tools. Rather than litigate, the parties reached an early, voluntary agreement that both sides characterized as a good-faith effort to advance consumer and child protections while providing a clear compliance framework.

As part of the resolution, Roku agreed to invest in the engineering resources needed to implement the changes, estimated at $25 million, which the office described as a significant financial and operational commitment. Implementation is expected to begin immediately, with full nationwide deployment anticipated within 12 months. Uthmeier said the resolution ensures meaningful safeguards to protect the privacy and personal data of children, while Roku said protecting children’s privacy and empowering parents with choice over their family’s streaming experience are company priorities.

Why It Matters

This resolution carries implications that extend well beyond its child-safety framing, across at least three dimensions that privacy counsel and compliance teams should track closely.

One state can achieve national reach. The most structurally significant feature of this resolution may be the geographic scope of Roku’s commitments. Because Roku’s changes will roll out nationally, a single state attorney general effectively imposed a national product redesign. Companies that have treated California as the effective national standard for privacy compliance may need to reassess that strategy. The relevant benchmarks may now be set by the states that enforce their comprehensive state privacy regimes most proactively.

Remediation budgets may serve as litigation reference points. The structure of the resolution, an investment in product redesign rather than a penalty, offers a potential template for cooperative settlements, but it may also create a litigation risk that a conventional fine would not. Unlike a fine paid to the government, a self-described investment in “doing the right thing” may translate more readily into class action theories of harm, restitution, and disgorgement.

Children’s data may be an entry point for broader behavioral commitments. The AG’s resolution is framed around minors, but the operational changes Roku is committing to, parental controls, consent flows, restrictions on data broker sharing, and accuracy of opt-out tools, are not, in practice, limited to children’s data. Once a company has rebuilt these systems, the resulting standards tend to become the baseline for all users, and regulators and plaintiffs may cite them accordingly. Businesses should not assume that a children’s-data enforcement action has no implications for their adult-facing data practices. The compliance architecture required to protect children’s data is largely the same as that required for a more expansive privacy regime, and this resolution may accelerate that convergence.

Troutman Pepper Locke State Attorneys General Team

	Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation.
	Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.
	Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies.
	Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes.
	Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations involving state attorneys general and other state and federal governmental enforcement bodies including the CFPB and FTC. He regularly represents clients in highly regulated sectors such as financial services, emerging technologies, health care, insurance, and education.
	Michael Yaghi Mike handles high-profile investigations led by state attorneys general, the FTC, and other federal and state regulatory bodies. He assists clients through these complex government inquiries, assisting them throughout the entire life cycle of investigations, from regulatory enforcement through formal litigation.
	Matthew J. Berns Drawing on his experience in senior leadership roles in the New Jersey Attorney General’s and Governor’s Offices and as a trial attorney for the U.S. Department of Justice, Matt provides an insider’s perspective when guiding clients through complex government investigations, litigation, and other actions.
	Samuel E. “Gene” Fishel Gene is a former regulator with two decades of experience who has overseen state privacy and cybersecurity regulation enforcement, led national, multistate attorneys general privacy investigations, and prosecuted computer crimes at the state and federal levels. He has served at the forefront of state attorney general and federal enforcement and utilizes this experience to proficiently represent client interests in AI, cybersecurity, and privacy compliance and regulatory matters.
	Jeff Johnson Jeff helps clients navigate complex regulatory and litigation challenges with local, state, and federal authorities. His clients benefit from his decade of broad litigation experience, understanding of emerging state and federal regulatory issues, and strong relationships with attorneys general across the U.S. In addition to handling cases from trial through state or federal appeals, Jeff serves as amicus counsel in advancing legal rules to support his clients’ vital interests.
	Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs.
	Zoe Schloss Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.
	Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology.
	Sydney Goldberg Sydney is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She advises clients on regulatory compliance and state attorney general (AG) investigations in highly regulated industries, including health care and life sciences. She routinely helps clients navigate alcohol compliance and licensing issues, helping proactively manage regulatory risk.
	Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals.
	Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.
	Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general.
	William LaRosa Bill represents clients in complex regulatory investigations, state attorneys general matters, and enforcement proceedings. He draws on his experience as a former assistant U.S. attorney and as a private-sector litigator advising corporations in high-stakes litigation and regulatory investigations, including multistate AG investigations.
	Philip Nickerson Philip’s diverse practice includes representation of financial, tech, real estate, and energy companies in a range of government investigation and litigation matters. With experience obtaining favorable results for clients as a first and second-chair litigator in state and federal trial courts, arguing before federal courts of appeal, and representing clients in arbitration proceedings, he understands the importance of tailoring litigation strategy to align with clients’ goals.
	Lane Page Lane represents financial institutions and other clients in federal and state regulatory investigations and complex civil litigation. He is particularly focused on consumer protection and fair lending issues.
	Dascher Pasco Dascher provides strategic counsel and representation to clients navigating regulatory compliance, enforcement, and high-stakes litigation. She regularly represents clients in both single and multistate state attorney general (AG) investigations and enforcement actions, as well as before other state enforcement bodies and local government agencies.
	Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review.
	Timothy Shyu Timothy advises clients on regulatory compliance and enforcement in highly regulated industries, including health care and life sciences, data privacy and cybersecurity, and emerging technology. He assists companies in navigating complex investigations and enforcement actions, helping them mitigate regulatory risk proactively.
	Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues.
	Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals.
	Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department.