Last month, the Campaign for a Commercial-Free Childhood, an international coalition of 35 children’s and consumer groups, called on Instagram to stop its plans to create a version of the app for users under the age of 13. Now, dozens of state prosecutors are doing the same.

In a letter (via NYT) addressed to Facebook CEO Mark Zuckerberg, attorneys general for 44 states and jurisdictions called on Facebook to stop its plans to create a version of Instagram for young children, citing concerns over mental and emotional well-being, exposure to online predators, and cyberbullying.

This letter quotes three main reasons why children under 13 shouldn’t be able to have an Instagram account:

  • Social media can be harmful to the physical, emotional, and mental well-being of the children, studies find;
  • Young children are not prepared to handle the range of challenges that come with having an Instagram account;
  • Facebook’s record of failing to protect the safety and privacy of children on its platform.

“Young children are not equipped to handle the range of challenges that come with having an Instagram account. Children do not have a developed understanding of privacy. Specifically, they may not fully appreciate what content is appropriate for them to share with others, the permanency of content they post on an online platform, and who has access to what they share online.

Facebook still defends its plans to create an Instagram for kids under 13. It was first reported in March that the social network was working on a new version of Instagram targeted at this audience.

Speaking to the New York Times, a Facebook spokesman said in an statement today:

“As every parent knows, kids are already online. We want to improve this situation by delivering experiences that give parents visibility and control over what their kids are doing.”

In April, Facebook expressed a similar sentiment, saying that “the reality is that kids are online, they want to connect with their friends and family” and confirming that “Instagram was in the early stages of developing a service for children,” and it “would not show ads in any Instagram product developed for children younger than 13.”

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