Building responsibly

Source/event record · 12 December 2024 event · prepared 16 September 2026

Texas opened an inquiry into a companion app under its minors law

Paxton's December 2024 announcement invokes the SCOPE Act's minor-data duties against Character.AI and others.

Prepared for local review · Site publication: not set · 463 words

What happened

On 12 December 2024, Texas Attorney General Ken Paxton announced investigations into Character.AI and fourteen other companies, including Reddit, Instagram and Discord, over their privacy and safety practices toward minors. The press release states the inquiries proceed under two state laws: the Securing Children Online through Parental Empowerment Act, generally called the SCOPE Act, and the Texas Data Privacy and Security Act. The announcement is a statement of investigative intent, not a finding of wrongdoing or a filed lawsuit.

What the documents show

The press release states plainly that 'the protections of these laws extend to how minors interact with AI products,' the clearest indication of the theory behind including a companion app among mostly social-media targets. The statute itself, Chapter 509 of the Texas Business and Commerce Code, was added by House Bill 18 in the 2023 legislative session and took effect on 1 September 2024, only months before this announcement. It defines a 'known minor' as anyone who registers as, or is otherwise identified as, under eighteen, and requires digital service providers to limit data collection and sharing, and to block targeted advertising and precise geolocation tracking, once a user is known to be a minor.

The mechanism

The legal mechanism is a state consumer-protection investigation, which in Texas gives the Attorney General's office power to demand documents and information before deciding whether to pursue enforcement; it is a fact-finding step, not a lawsuit. The SCOPE Act itself works through an age-registration duty: rather than requiring every provider to verify every user's age, it turns on whether a provider has actual or constructive knowledge a user is a minor, at which point specific data-handling limits attach. That structure means a companion app's obligations under the law can depend heavily on what the app asked about age at signup and how it responded to any dispute over it.

What it leaves open

The press release does not identify which specific SCOPE Act or TDPSA provisions Character.AI may have violated, only that an investigation was opened; nothing in the record establishes that any violation occurred. It is also silent on a timeline for the investigation's conclusion, and does not say whether the inquiry was prompted by a specific complaint, a broader policy priority, or both.

  • Does an announced investigation state that a law was broken, or only that an inquiry has opened?
  • Under the cited statute, what specifically triggers a company's minor-specific data duties?
  • Has the investigation since produced a settlement, a lawsuit, or no public action at all?

Filed a few months after the SCOPE Act's data provisions took effect, the announcement shows a state regulator treating a companion chatbot the same as a social network for statutory purposes, before any court has tested that reading of the law.

Sources & reading trail