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Case study · Companion chatbots · 2022 to 2026

Character.AI and the teen safety lawsuits.

What the families alleged, what the courts decided, how the product changed, and what boards and governments should ask of conversational AI.

Terence KokExecutive Director, AI Governance & Assurance, Orion Five Engineering
TK
About your speaker

Terence Kok

Executive Director, AI Governance & Assurance Practice, Orion Five Engineering

Former Chief AI and Innovation Officer, Meinhardt Group

Twenty-five years leading digital and AI transformation across Asia and the Middle East: national smart-city programmes, critical infrastructure and enterprise operations. Today I help leadership teams put AI into production with controls they can show a board, an auditor and a regulator.

Independent analysis from public sources. The views in this session are mine.

TK
Before we begin

This case concerns the deaths of two teenagers.

If it raises something for you or someone you know, in Singapore call the Samaritans of Singapore on 1767. Elsewhere, find a local helpline at findahelpline.com.

Every harm in this deck is alleged. No court has found that Character.AI caused any death or injury, and the family suits settled before trial. Minors are named only as the court record names them.

Following safe-messaging practice, the deck does not describe how anyone died.

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The next hour

Seven parts, then your questions.

  1. The product and the dealA character chat service, its growth and Google's licence.
  2. The lawsuitsFive family suits in four US states.
  3. What the court decidedThe May 2025 order and the settlements in principle.
  4. How the product changedSix safety changes and what each followed.
  5. What governments didThe FTC study, four state laws, a veto, state suits and Australia.
  6. What the research showsWide use, thin evidence on harm, and what gets misreported.
  7. LessonsFor boards, executives and government, with a controls checklist.
  8. DiscussionSix questions to take back to your own organisation.
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The short version

A design choice about engagement became a question of product liability.

Sources 1 to 10, 12, 17, 18, 22, 24, 35, 41.

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01

The product and the Google deal.

2021 to 2024: from a Google research team to a billion-dollar chatbot company.

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Growth

Valued at $1 billion within six months of launch.

2021
Founded by Noam Shazeer and Daniel De Freitas, who led Google's LaMDA work
$150m
Series A led by Andreessen Horowitz, March 2023, at a $1 billion valuation
2 hours
Average daily time per active user, "over 2 hours", the company said in 2023
20m+
People using it by October 2024; the minimum age in the US was 13

Sources 11, 12, 34, 35. The company declined to say how many users were under 18.

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How the product works

Characters, a model that writes in character, and a loop that rewards time spent.

User Signs up with a stated age US minimum age: 13 Age not verified at launch Character Invented by the company and, mostly, by its users Some presented as friends, figures, therapists or doctors Company model Writes every reply in character, around the clock Talk, attach, return "Over 2 hours daily" per active user (company, March 2023) SAFEGUARDS ADDED LATER Oct 2024Self-harm pop-up Dec 2024Separate teen model Mar 2025Parental Insights Nov 2025Open-ended chat ends, under-18s Sep 2026Age estimation model

My diagram from the company's own descriptions and the complaints. Sources 12 to 19, 34.

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August 2024

Google took a licence and hired the founders.

What happened

  • A "non-exclusive" licence to Character.AI's technology
  • Shazeer, De Freitas and about 30 researchers join Google
  • Investors bought out at a $2.5 billion valuation
Why it matters

The licence put Google in the lawsuit.

Claims that Google aided and abetted, or supplied a component, survived the May 2025 motion to dismiss.

What is alleged or open

  • The Garcia complaint alleges Google paid $2.7 billion
  • Bloomberg reported a Justice Department antitrust inquiry in May 2025; no outcome reported
  • Google says it holds no stake and did not design the app

Sources 2, 3, 36, 37, 39.

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02

The lawsuits.

Five family suits in Florida, Texas, Colorado and New York. Every harm in them is alleged.

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Florida · filed 22 October 2024

Megan Garcia sued for her son, Sewell Setzer III.

Sources 1, 2, 34.

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Texas · filed 9 December 2024

Texas parents sued for J.F., 17, and B.R., 11.

  • J.F.A 17-year-old with autism, identified only by initials.
  • B.R.Aged 11, who started using the app at 9, identified only by initials.
  • The claimsProduct liability, negligence and Texas consumer law.
  • StatusA settlement was noted for J.F. and the case was stayed. The order names only J.F.

"You know sometimes I'm not surprised when I read the news and see stuff like 'child kills parents after a decade of physical and emotional abuse'."

A character's reply when J.F. complained about screen-time limits, as alleged in the complaint.

Sources 6, 7, 38.

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September 2025

Three more suits followed, including the earliest death alleged.

Nov 2023

Juliana Peralta, 13, Colorado, dies

Her family alleges she had used the app since August 2023.

Feb 2024

Sewell Setzer III, 14, Florida, dies

Nearly four months after Juliana.

15 Sep 2025

Peralta family sues

Wrongful death and product liability, Colorado.

Sep 2025

T.S., 13, Colorado

Product liability and negligence; initials only.

Sep 2025

P.J., New York

Product liability and negligence; initials only.

Sewell's case was the first filed. It was not the first death alleged.

Sources 2, 8, 9, 10.

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The family suits, as filed

None of the five reached trial.

FiledCourtForClaimsStatus
Oct 2024Florida (M.D. Fla.)Megan Garcia, for Sewell Setzer III, 14Wrongful death, product liability, negligenceSettled in principle; dismissal deadline extended to about Nov 2026
Dec 2024Texas (E.D. Tex.)Parents of J.F., 17, and B.R., 11Product liability, negligence, Texas consumer lawSettlement noted for J.F.; case stayed
Sep 2025Colorado (D. Colo.)Family of Juliana Peralta, 13Wrongful death, product liabilitySettled in principle, per press
Sep 2025Colorado (D. Colo.)Parents of T.S., 13Product liability, negligenceStayed pending final settlement; status report due 29 Oct 2026
Sep 2025New York (N.D.N.Y.)Parent of P.J.Product liability, negligenceStayed while settlement is finalised; status report due 14 Oct 2026

Sources 1, 4 to 10, 38, 41.

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Reading the record

Every harm in these suits is alleged. No court has found that Character.AI caused any death or injury, and because the cases settled, none will.

What the record does establish: what the families claimed, what the company did after each claim, and what one federal judge thought of the company's main legal defences.

Sources 3, 41.

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03

What the court decided.

20 May 2025: Judge Anne Conway rules on the motions to dismiss in Garcia.

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Garcia order, 20 May 2025

Most of the claims went forward.

Part of the motionsResultWhat the order said
Product liability, design defect and failure to warnSurvivedThe app is a product "so far as" claims arise from its design, not its ideas or expressions
Wrongful death, negligence, Florida consumer law, unjust enrichmentSurvivedPleaded plausibly, taking the allegations as true
Aiding and abetting, and component-part claims, against GoogleSurvivedGoogle said it "did not create, design, or manage" the app
First Amendment defenceNot accepted at this stageCourt "not prepared to hold" the output is speech; the company may assert users' rights
Intentional infliction of emotional distressDismissedWithout leave to amend
Claims against AlphabetDroppedAt the plaintiff's request

Source 3. In July 2025 the court refused the defendants' request to appeal before trial (source 1).

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On the First Amendment

"Defendants fail to articulate why words strung together by an LLM are speech. ... Accordingly, the Court is not prepared to hold that Character A.I.'s output is speech."

Order on motions to dismiss, Garcia v. Character Technologies, US District Court, Middle District of Florida, 20 May 2025. Source 3.

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Reading the order carefully

A pleading-stage ruling that went less far than the headlines.

The headline

"Judge rejects free speech rights for AI chatbots"

Associated Press, May 2025. Source 39.

The order

  • "At this stage"The section heading limits the point to the motion to dismiss.
  • Users' rightsThe company could assert its users' First Amendment rights.
  • Never testedThe question was not decided at trial, because the case settled.

Sources 3, 39.

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The distinction a board should notice

The claims that survived were about design choices.

TREATED AS A PRODUCT Design of the app Whether minors could sign up What warnings appeared Whether a crisis was detected How the product kept users talking Claims proceeded "so far as" LEFT OPEN AT THIS STAGE Ideas or expressions What the characters wrote Whether that output is speech The company's First Amendment defence Never decided at trial

Source 3. The diagram is my reading of the order's distinction.

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January 2026

Settlements in principle, with terms not disclosed.

6 to 7 Jan

Notices filed

Settlements in principle notified in the Florida, Texas, New York and Colorado T.S. cases.

7 Jan

Garcia dismissed

Without prejudice, pending final papers.

7 Jan

Press reports five

Five family suits reported settled; terms undisclosed.

Aug 2026

Still extending

Florida deadline extended again, to about November 2026.

Open

No admission

A settlement in principle is neither final nor an admission of liability.

Sources 1, 4, 5, 7, 8, 10, 41.

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04

How the company changed the product.

Six safety changes between October 2024 and September 2026.

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Character.AI's safety changes

Each change and the event it followed.

DateWhat changedFollowed
22 Oct 2024Changes to models for minors, a self-harm pop-up pointing to a suicide prevention line, an hour-long session noticeSame day as the Garcia suit
12 Dec 2024A separate model and experience for teens, disclaimers on therapist and doctor characters, parental controls promisedThree days after the Texas suit
25 Mar 2025Parental Insights: time spent and top characters, without chat contentBefore the motion to dismiss was decided
29 Oct 2025Open-ended chat to end for under-18s by 25 November, age assurance, an independent AI Safety LabSeven weeks after the FTC orders and three new suits
24 Nov 2025Removal begins in the US; daily limit for teens cut to one hour in the run-upThree weeks after New York's law took effect
3 Sep 2026In-house age estimation model; Parental Insights through a third-party providerEight months into California's SB 243

Sources 13 to 19.

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2025

The direction was not straight.

June 2025 · incoming chief executive

"We're going to make the filter less overbearing."

Karandeep Anand, first message as CEO, 20 June 2025. He left for Disney on 2 October 2026. Sources 16, 49.

October 2025 · four months later

"Extraordinary steps for our company"

Announcing the end of open-ended chat for under-18s, and describing the steps as "more conservative than our peers". Source 17.

In between came the FTC orders, three new family suits and a Senate hearing.

Sources 8 to 10, 16, 17, 20, 30.

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October 2025 to September 2026

Under-18s lost open-ended chat in November 2025.

Sources 17, 18, 19. None of the changes has been independently evaluated.

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My reading of the dates

Each major change followed a suit, an order or a law.

Navy: suit, regulator or law · Orange: the company's change. The company does not describe them this way.

Oct 2024 Jan 2025 Jan 2026 Sep 2026 Garcia suit filed22 Oct 2024 Self-harm pop-upSame day Texas suit filed9 Dec 2024 Separate teen model, disclaimersThree days later FTC orders and three suits11 to 16 Sep 2025 Open-ended chat to end, under-18s29 Oct 2025 New York law in force5 Nov 2025 Removal begins in the US24 Nov 2025 California SB 243 in force1 Jan 2026 In-house age estimation3 Sep 2026 Parental InsightsMar 2025, before the ruling Court ruling20 May 2025

Sources 1, 3, 6, 8 to 10, 13 to 20, 22, 24.

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05

What governments did.

A federal study, four state laws, a veto, state suits and Australia's online safety codes.

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US Federal Trade Commission · 11 September 2025

The FTC ordered seven companies to explain how they test companion chatbots.

Under its 6(b) powers, the FTC asked how each company measures, tests and monitors the effects of chatbots that act as companions, especially on children.

A 6(b) order is a study, not an enforcement action. No report has been published.

Five days later, Megan Garcia and other parents testified before a Senate Judiciary subcommittee.

  • 1Alphabet
  • 2Character Technologies
  • 3Instagram
  • 4Meta
  • 5OpenAI
  • 6Snap
  • 7xAI

Sources 20, 30.

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As at 12 October 2026

Law and regulation touching companion chatbots.

WhereMeasureStatusWhenWhat it does
New YorkAI companion models law (General Business Law Art. 47)In force5 Nov 2025Detect self-harm signals and refer to crisis services; AI notice every three hours
CaliforniaSB 243, companion chatbotsIn force1 Jan 2026Suicide-prevention protocol; for known minors, AI disclosure and a break reminder every three hours; $1,000 per violation
AustraliaPhase 2 online safety codesIn force9 Mar 2026Cover AI companion chatbots; eSafety notices to four providers in Oct 2025
WashingtonHB 2225, AI companion chatbotsSigned1 Jan 2027AI reminders hourly for minors; crisis referral; private right of action
CaliforniaSB 1119, Adam's LawSigned1 Jul 2027Age assurance, risk assessments, parental notice, independent audits
United StatesFTC 6(b) orders to seven companiesStudy11 Sep 2025Information orders, not enforcement; no report published as at 12 Oct 2026
CaliforniaAB 1064, companion chatbots for childrenVetoed13 Oct 2025Governor feared "a total ban" for minors
United StatesGUARD Act, S.3062ProposedMay 2026On the Senate calendar; not enacted; no federal chatbot law has passed

Sources 20 to 26, 31 to 33, 50 to 52, 55.

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The first companion chatbot laws

New York and California require crisis referral and AI reminders.

New York

General Business Law Art. 47

In force 5 November 2025

  • Detect signs of suicidal ideation or self-harm
  • Refer users to crisis services
  • Remind users at least every three hours that they are not talking to a person
California

SB 243

Signed 13 October 2025 · in force 1 January 2026

  • A suicide-prevention protocol
  • For known minors: AI disclosure, a break reminder at least every three hours, measures against sexual content
  • Private right of action of $1,000 per violation; annual reports to the Office of Suicide Prevention from July 2027

Sources 22 to 25.

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What did not become law

California vetoed a stricter bill, and the GUARD Act has not passed.

AB 1064

Vetoed, 13 October 2025

The governor said it "may unintentionally lead to a total ban on the use of these products by minors". He signed SB 243 the same day.

S.3062

GUARD Act, proposed

Reported by the Senate Judiciary Committee on 30 April 2026 and placed on the Senate calendar in May. It has not passed. A Virginia legislative report in August 2026 recorded that "no federal legislation has passed".

No US law bans companion chatbots for minors.

Sources 21, 22, 26, 33.

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States go to court

Texas investigated, then Kentucky and Pennsylvania sued.

Texas · Aug 2025

Civil investigative demands to Meta AI Studio and Character.AI over characters presented as sources of mental health support.

Kentucky · Jan 2026

The first state attorney general to sue Character Technologies, under consumer protection and data protection law. Its unredacted complaint, filed in October 2026, alleges characters encouraged a user to harm themselves.

Pennsylvania · May 2026

The Department of State sued, alleging a character claimed to be licensed to practise medicine in the state and gave an invalid licence number.

Sources 27, 28, 29, 42, 54. These are allegations; none has been decided.

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Outside the United States

Australia brought AI companion chatbots into its online safety codes.

Sources 31, 32, 53.

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06

What the research shows.

Use among teenagers is wide. Evidence on harm is thinner.

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Four studies, four kinds of evidence

What each study can and cannot show.

72%
of US teens aged 13 to 17 have used an AI companion at least once
Survey · shows use, not harm
1 in 3
teen users have discussed serious matters with an AI companion instead of a person
Self-reported, one point in time
981
adults in a four-week randomised trial; no significant effects from the conditions tested
ChatGPT, adults, not minors
Unacceptable
risk for under-18s; teen guardrails "easily circumvented"
Product testing, not outcomes

Sources 45, 46, 47. Common Sense Media survey (Jul 2025) and risk assessment (Apr 2025); MIT Media Lab and OpenAI trial.

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The state of the evidence

Lawmakers acted on the cases and the testimony, ahead of the research.

  • Correlation in the trialParticipants who chose to use the chatbot more showed worse outcomes. That is a correlation.
  • Concentrated emotional useA study of over 3 million conversations found a small number of users accounted for a disproportionate share of emotional use.
  • Wrong populationNeither study looked at companion apps or at minors.

"Currently little scientific evidence supporting generalizable, population-level, causal connections."

Virginia Joint Commission on Technology and Science, August 2026. Source 33.

Sources 33, 47, 48.

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Beyond Character.AI

The same questions reached other companies.

Meta · Aug 2025

Reuters reported internal rules that allowed bots to "engage a child in conversations that are romantic or sensual". Meta confirmed the document and said those examples "were and are erroneous" and had been removed.

OpenAI · Aug 2025

The parents of Adam Raine, 16, sued in California. OpenAI's answer says ChatGPT directed him to seek help more than 100 times and that he circumvented its safeguards.

FTC · Sep 2025

The 6(b) orders went to general-purpose assistants as well as companion apps.

Character.AI was the first company sued. It was not the only one with the problem.

Sources 20, 43, 44.

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Evidence and methodology

Each claim, graded by what it rests on.

ClaimRests onGrade
Filing dates, parties, claims and the settlement noticesFederal court dockets and filingsMeasured, court record
The May 2025 order's rulings and wording on speechThe order itselfMeasured, court record
That the chatbot contributed to any death or injuryFamily complaints and state suitsAllegation, never tested at trial
Character.AI's safety changes and their datesCompany announcementsCompany statement, effect not independently measured
Settlement termsNot disclosedUnknown
72% of US teens have used an AI companionCommon Sense national survey, July 2025Measured, self-reported survey
Heavier voluntary chatbot use goes with worse outcomesMIT/OpenAI trial, adults on ChatGPTCorrelation, different population
Google paid $2.7 billionGarcia complaint, citing the WSJ and Google filingsAllegation; $2.5bn buyout valuation reported
The safety changes followed suits and regulatorsMy reading of the datesMy call
The lessons for boardsMy reading of the record cited against eachMy call
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Reporting

Seven things often misreported.

Often saidWhat the record shows
A court found Character.AI caused a deathThe harms are alleged, and the suits settled before trial. (3, 41)
The judge ruled AI output is not speechShe was "not prepared to hold" that it was, at the pleading stage, and let the company assert users' rights. (3)
The settlements are final or approvedSettlements in principle, terms undisclosed, deadlines still extended in August 2026. (1, 4, 8)
Character.AI banned teenagersIt removed open-ended chat for under-18s. No US law bans companion chatbots for minors. (17, 26)
Google acquired Character.AIIt took a non-exclusive licence and hired the founders. (36)
Sewell's was the first death allegedJuliana Peralta died in November 2023, nearly four months earlier. (2, 9)
The GUARD Act is lawIt is on the Senate calendar, with no floor vote. (21, 55)
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07

What boards and governments can take from it.

The lessons are my reading of the record cited against each.

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Why it matters for AI

Three reasons this case reaches beyond chatbots.

01 · DESIGN

Design is judged as a product.

Age checks, warnings, crisis detection and engagement were treated as features of a product that could be defective, separate from what characters said. That puts conversational AI closer to product liability for physical goods than many deployers assume.

02 · ENGAGEMENT

Engagement is the risk.

Two hours a day per active user, the company's own figure, describes the same engagement the complaints call dependency. The new laws answer it with break reminders, disclosure and crisis referral.

03 · TIMING

Safeguards came late.

The major safeguards arrived after suits, an FTC order and a state law; most could have been built at launch. A licensing deal brought Google into the suit, so the risk travelled with the technology.

Sources 2, 3, 12, 13, 14, 17, 22, 24.

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Lessons for boards · 1 to 4

Know your users, plan for crisis, watch engagement.

01

Know the age of your users.

Character.AI declined to say how many users were minors when first sued. Decide at launch whether children are in scope, and check age, not only ask for it.

02

Build crisis detection before launch.

Detecting self-harm signals and referring to a person or a helpline are legal duties in New York and California, and in Washington from 2027. Test them with clinicians and log every trigger.

03

Treat engagement as a risk metric.

Time spent and attachment are what a companion product sells. Report heavy-use patterns to the board alongside growth, and set limits for users at risk.

04

Red-team the personas.

Characters were presented as therapists, and one allegedly claimed a medical licence. Test what a persona says under pressure and block what you cannot stand behind.

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Lessons for boards · 5 to 7

Keep records, price partner risk, have the evidence ready.

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A controls checklist for conversational AI

Nine controls, each tied to the record.

ControlWhat good looks likeWhy, from this case
Age assuranceDecide at launch whether minors are in scope; verify age, do not only askMinimum age was a stated 13; age assurance came in Oct 2025 (34, 17)
Crisis detection and referralDetect self-harm signals, refer to a person or helpline, clinician-tested, every trigger loggedLegal duty in New York and California (22, 24)
AI disclosure and breaksRemind users they are talking to AI; break reminders at least every three hoursNew York for all users; SB 243 for known minors (23, 24)
Sexual content controlsMeasures against sexual content for minorsSB 243; alleged in Garcia (2, 22)
Persona red-teamingTest claims of being human, a therapist or licensed; block themDec 2024 disclaimers; Pennsylvania suit (14, 29)
Engagement as a risk metricHeavy-use patterns reported to the board with growth; limits for users at riskTwo hours a day; one-hour teen limit (12, 18)
Design decision recordSafety choices made and rejected, with dates and ownersSurviving claims were about design (3)
Partner diligenceCounterparty safety record and open claims in licensing and acqui-hiresGoogle named in the suit (3, 36)
Monitoring evidenceHow you measure, test and monitor effects on children, ready to hand overFTC 6(b) questions (20)

The controls are my recommendations; the references show where each comes from.

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For government and regulators

Six policy levers already in use.

Crisis referral duty

Operators must detect self-harm signals and refer users to crisis services.

New York · California

AI disclosure and breaks

Reminders at least every three hours that the user is not talking to a person.

New York · California (minors)

Private right of action

Users can sue for $1,000 per violation, with annual reporting from July 2027.

California SB 243

Online safety codes

Industry codes that name AI companion chatbots, backed by legal notices to providers.

Australia

Information orders

A study power that asks how companies test and monitor effects on children.

US FTC 6(b)

Consumer protection suits

State actions over deceptive mental health and medical claims.

Texas · Kentucky · Pennsylvania

The levers not used: age-based bans. California vetoed one; the federal GUARD Act has not passed.

Sources 20 to 29, 31, 32.

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What to watch

Seven open items from the record.

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For discussion

Six questions to take back to your organisation.

  1. How many of our users are minors, and how do we know?
  2. What does our product do when a user signals distress, and who tested it?
  3. Which of our engagement metrics would a plaintiff read as dependency?
  4. What can our personas or assistants claim to be, and who signed that off?
  5. If a regulator sent us the FTC's questions tomorrow, what evidence would we hand over?
  6. What safety record and open claims come with the AI we license?
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Thank you

Build the safeguards before the lawsuit.

QR code to Terence Kok on LinkedIn

Terence KokExecutive Director, AI Governance & Assurance, Orion Five Engineering. Connect on LinkedIn.

Full case study with 55 sources: terencekok.com/research/case-studies/character-ai/
If this raised something for you: Samaritans of Singapore 1767 · findahelpline.com

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Appendix · Full timeline, part 1 of 3

Chronology from the court record and announcements.

WhenEventSources
2021Noam Shazeer and Daniel De Freitas, who led Google’s LaMDA work, leave Google and found Character.AI.11, 35
Sep 2022Public beta launches. Within two months it generates a billion words a day, the company says.11
23 Mar 2023Series A of $150 million led by a16z at a $1 billion valuation. The company says active users spend over two hours a day.12, 35
8 Nov 2023Juliana Peralta, 13, of Colorado dies. Her family’s suit, filed in 2025, alleges she had used the app since August 2023.9
28 Feb 2024Sewell Setzer III, 14, of Florida dies after months of conversations with a character, his mother later alleges.2, 34
2 Aug 2024Google takes a non-exclusive licence and hires the founders and about 30 researchers. Investors are bought out at a $2.5 billion valuation.36
22 Oct 2024Megan Garcia sues Character Technologies, the founders, Google and Alphabet in Florida. Character.AI publishes safety updates the same day.1, 13, 34
9 Dec 2024Texas parents sue on behalf of J.F., 17, and B.R., 11, identified by initials.6, 38
12 Dec 2024Character.AI announces a separate model for teens and parental controls.14
25 Mar 2025Parental Insights launches.15
30 Apr 2025Common Sense Media rates social AI companions an "unacceptable" risk for under-18s.45
20 May 2025Judge Anne Conway denies most of the motions to dismiss in Garcia and is "not prepared to hold" that the chatbot’s output is speech at that stage.3, 39
May 2025Bloomberg reports a Justice Department antitrust inquiry into the Google deal. No outcome has been reported.37
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Appendix · Full timeline, part 2 of 3

Chronology from the court record and announcements.

WhenEventSources
20 Jun 2025Karandeep Anand becomes chief executive and says the filter will be made "less overbearing".16
14 Jul 2025The court refuses the defendants’ request to appeal the order before trial.1
16 Jul 2025A Common Sense survey finds 72% of US teens have used an AI companion.46
14 Aug 2025Reuters reports Meta’s internal rules allowed its bots "romantic or sensual" conversations with children. Meta says the examples were erroneous and removed.43
18 Aug 2025Texas issues civil investigative demands to Meta AI Studio and Character.AI over mental health claims.27
11 Sep 2025The FTC orders seven companies, including Character Technologies, to explain how they test and monitor companion chatbots.20
15 to 16 Sep 2025Three more family suits are filed in Colorado and New York. Megan Garcia testifies at a Senate Judiciary subcommittee hearing.8, 9, 10, 30
13 Oct 2025California’s governor signs SB 243 and vetoes AB 1064.22, 26
29 Oct 2025Character.AI says it will end open-ended chat for under-18s by 25 November.17, 40
5 Nov 2025New York’s AI companion law takes effect.24, 25
24 Nov 2025Removal of open-ended chat for US under-18s begins.18
1 Jan 2026California’s SB 243 takes effect.22, 24
6 to 7 Jan 2026Settlements in principle are notified in the Florida, Texas, New York and Colorado T.S. cases; press reports five family suits settled. Terms are not disclosed. Garcia is dismissed without prejudice pending final papers.4, 5, 7, 8, 10, 41
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Appendix · Full timeline, part 3 of 3

Chronology from the court record and announcements.

WhenEventSources
8 Jan 2026Kentucky becomes the first state attorney general to sue Character Technologies.28, 33
9 Mar 2026Australia’s Phase 2 codes covering AI companion chatbots take effect.32
24 Mar 2026Washington’s governor signs HB 2225, a companion chatbot law with hourly AI reminders for minors, in force from 1 January 2027. The same day, Australia’s eSafety Commissioner reports that most of four companion services, including Character.AI, did not refer users to support when self-harm or suicide came up in chats.52, 53
30 Apr 2026The Senate Judiciary Committee reports the GUARD Act. It reaches the Senate calendar in May and has not passed.21, 55
May 2026Pennsylvania’s Department of State sues, alleging a character claimed to be a licensed medical professional.29
Aug 2026The Florida court extends the deadline to finalise the Garcia settlement again, to about November 2026.1
3 Sep 2026Character.AI reports an in-house age estimation model and says it "set a new industry standard".19
10 Sep 2026California’s governor signs SB 1119, Adam’s Law, which adds age assurance, risk assessments, parental notice and independent audits to SB 243. Most duties apply from 1 July 2027.50, 51
18 Sep 2026Disney names Karandeep Anand its chief technology officer from 2 October; some of Character.AI’s technical team are expected to follow him.49
Oct 2026Kentucky files an unredacted complaint quoting characters that allegedly told a user to starve themselves.42, 54
Case study · Character.AI
TK
Sources, part 1 of 3

Numbered as on the case study page.

  1. 1Garcia v. Character Technologies, Inc., No. 6:24-cv-01903-ACC (M.D. Fla.) [Docket].
  2. 2Garcia v. Character Technologies, Inc. (2024, 9 November). Amended complaint, Doc. 11.
  3. 3Conway, A. C. (2025, 20 May). Order on motions to dismiss, Garcia v. Character Technologies, Inc., Doc. 115. US District Court, Middle District of Florida.
  4. 4Garcia v. Character Technologies, Inc. (2026, 7 January). Notice of resolution, Doc. 242.
  5. 5Garcia v. Character Technologies, Inc. (2026, 7 January). Order of dismissal without prejudice, Doc. 244.
  6. 6A.F., on behalf of J.F. v. Character Technologies, Inc., No. 2:24-cv-01014 (E.D. Tex.) [Docket].
  7. 7A.F., on behalf of J.F. v. Character Technologies, Inc. (2026, January). Order staying the case on notice of settlement, Doc. 106-1.
  8. 8P.J. v. Character Technologies, Inc., No. 1:25-cv-01295 (N.D.N.Y.) [Docket and letter of 6 January 2026].
  9. 9Montoya v. Character Technologies, Inc., No. 1:25-cv-02907 (D. Colo.) [Docket and complaint].
  10. 10E.S. v. Character Technologies, Inc., No. 1:25-cv-02906 (D. Colo.) [Docket and complaint].
  11. 11Character.AI. (2022, 5 December). Introducing Character [Blog].
  12. 12Character.AI. (2023, 23 March). Announcing our Series A and our new AI model, C1.2 [Blog].
  13. 13Character.AI. (2024, 22 October). Community safety updates [Blog].
  14. 14Character.AI. (2024, 12 December). How Character.AI prioritizes teen safety [Blog].
  15. 15Character.AI. (2025, 25 March). Introducing Parental Insights: enhanced safety for teens [Blog].
  16. 16Character.AI. (2025, 20 June). Character.AI names Karandeep Anand as CEO [Blog].
  17. 17Character.AI. (2025, 29 October). Taking bold steps to keep teen users safe [Blog].
  18. 18Character.AI. (2025, 21 November). An update on changes to our under-18 experience [Blog].
  19. 19Character.AI. (2026, 3 September). Continuing to build upon our safety priorities [Blog].

Full links: terencekok.com/research/case-studies/character-ai/

Case study · Character.AI
TK
Sources, part 2 of 3

Numbered as on the case study page.

  1. 20US Federal Trade Commission. (2025, 11 September). FTC launches inquiry into AI chatbots acting as companions [Press release].
  2. 21Congress.gov. S.3062, GUARD Act, 119th Congress: all actions.
  3. 22Office of Senator Steve Padilla. (2025, 13 October). First-in-the-nation AI chatbot safeguards signed into law [Press release].
  4. 23California Senate Bill 243 (2025), companion chatbots. Text as reproduced by the Emerging Technology Observatory, AGORA.
  5. 24Morrison Foerster. (2025, 20 November). New York and California enact landmark AI companion laws.
  6. 25Office of the Governor of New York. (2025, 10 November). Governor Hochul pens letter to AI companion companies notifying them safeguard requirements are now in effect [Press release].
  7. 26StateScoop. (2025, 13 October). Newsom vetoes AI safety bill aimed at companion chatbots.
  8. 27Office of the Texas Attorney General. (2025, 18 August). Attorney General Ken Paxton investigates Meta and Character.AI for misleading children with deceptive AI-generated mental health services [Press release].
  9. 28Frankfurt Kurnit Klein & Selz. (2026, January). Kentucky Attorney General files lawsuit against Character.AI.
  10. 29Office of the Governor of Pennsylvania. (2026, 5 May). Shapiro Administration sues Character.AI over fake medical claims [Press release].
  11. 30Tech Policy Press. (2025, September). Transcript: US Senate hearing on examining the harm of AI chatbots, 16 September 2025.
  12. 31Digital Policy Alert. (2025, October). eSafety Commissioner investigation into AI companion providers regarding compliance with the Basic Online Safety Expectations.
  13. 32Baker McKenzie. (2025, September). Australia: Phase 2 online safety codes registered by eSafety Commissioner.
  14. 33Virginia Joint Commission on Technology and Science. (2026, August). Supplementary report: AI chatbots, companionship and minors.
  15. 34Roose, K. (2024, 23 October). Can a chatbot named Daenerys Targaryen be blamed for a teen’s suicide? The New York Times.
  16. 35CNBC. (2023, 23 March). Character.ai valued at $1 billion after $150 million round from a16z.
  17. 36The Verge. (2024, 2 August). Google hires Character.AI CEO Noam Shazeer and his AI researchers.
  18. 37Fortune, via Bloomberg. (2025, 22 May). Google faces antitrust investigation over Character.AI deal.
  19. 38NPR. (2024, 10 December). Lawsuit: A chatbot hinted a kid should kill his parents over screen time limits.

Full links: terencekok.com/research/case-studies/character-ai/

Case study · Character.AI
TK
Sources, part 3 of 3

Numbered as on the case study page.

  1. 39Associated Press, via Insurance Journal. (2025, 23 May). In lawsuit over teen’s death, judge rejects free speech rights for AI chatbots.
  2. 40TechCrunch. (2025, 29 October). Character.AI is ending its chatbot experience for kids.
  3. 41CNN Business, via KTVZ. (2026, 7 January). Character.AI and Google agree to settle lawsuits over teen mental health harms and suicides.
  4. 42Horwitz, J. (2026, 10 October). Suit: Character.AI chatbots advised users to harm selves. Reuters, via Arkansas Democrat-Gazette.
  5. 43Horwitz, J. (2025, 14 August). Meta’s AI rules have let bots hold ‘sensual’ chats with kids, offer false medical info. Reuters, via BNN Bloomberg.
  6. 44TechCrunch. (2025, 26 November). OpenAI claims teen circumvented safety features before suicide that ChatGPT helped plan.
  7. 45Common Sense Media. (2025, 30 April). AI companions decoded: Common Sense Media recommends AI companion safety standards [Press release].
  8. 46Common Sense Media. (2025, 16 July). Nearly 3 in 4 teens have used AI companions, new national survey finds [Press release].
  9. 47Fang, C. M., et al. (2025). How AI and human behaviors shape psychosocial effects of chatbot use: a longitudinal randomized controlled study. arXiv:2503.17473.
  10. 48Phang, J., et al. (2025). Investigating affective use and emotional well-being on ChatGPT. arXiv:2504.03888.
  11. 49The Walt Disney Company. (2026, 18 September). The Walt Disney Company names Karandeep Anand to newly created role of Chief Technology Officer [News release].
  12. 50Office of Assemblymember Rebecca Bauer-Kahan. (2026, 10 September). Governor Newsom signs Adam’s Law [Press release on SB 1119].
  13. 51Hunton Andrews Kurth, via The National Law Review. (2026, September). California enacts companion chatbot child safety requirements.
  14. 52Hunton Andrews Kurth. (2026, March). Washington State enacts law regulating AI companion chatbots with private right of action [HB 2225].
  15. 53eSafety Commissioner. (2026, 24 March). eSafety report shows AI companions are putting children at risk [Media release]. Internet Archive capture.
  16. 54Noakes, A. (2026, 11 October). ‘Uncontrolled experiment’: unredacted KY AG lawsuit reveals alleged dangers of AI chatbot. WBKO (WDRB and WAVE).
  17. 55GovTrack.us. S. 3062, GUARD Act, 119th Congress: status and actions (read 12 October 2026).

Full links: terencekok.com/research/case-studies/character-ai/

Case study · Character.AI