During the Class Period Plaintiff Nichole Hubbard’s child, C.H., watched videos on the  YouTube Platform using via YouTube.com, the YouTube mobile app, and the YouTube Kids App.   C.H. viewed several monetized YouTube channels owned by Channel Owner Defendants  during the Class Period, including, inter alia, the following channels: ChuChuTV Nursery Rhymes &  Kids Songs, Ryan ToysReview, My Little Pony Office, and CookieSwirlC.  Defendants collected C.H.’s Personal Information for the purposes of tracking, profiling,  and targeting C.H. with advertisements as she watched Channel Owner Defendants’ YouTube videos.  Defendants did not obtain verifiable parental consent prior to the collection of C.H.’s  Personal Information.  Defendants actively and fraudulently concealed their unlawful acts described herein and  further deceptively misled parents and the public about Defendants’ intentional design and employment  of the You Tube Platform and the monetized channels thereon to attract and provide video viewing to  minors under the age of thirteen and to exploit such minors’ Personal Information for Defendants’  enormous financial gain.  Plaintiff could not have reasonably discovered Defendants’ conduct earlier through  investigation.  Defendants’ tracking, profiling, and targeting of C.H. without parental consent is highly  offensive and constitutes an invasion of C.H.’s privacy. 