47.  In the spring of 2018, B.M. downloaded the Musical.ly App onto  her iPad and her iPhone 6.  At this time, B.M. was 10 years old.  B.M.’s mother  was unaware that her daughter had downloaded the app.   48.  Thereafter, B.M. used the Musical.ly App on a daily basis, both for  viewing videos as well as creating and posting videos of her own.     49.  During the process of registering for the Musical.ly App, B.M. was  required to provide her email address, phone number, username, first and last  name, a short biography, and a profile picture.   50.  Defendants never asked Ms. Scott for her verifiable parental consent  – in any form or at any time – to collect, disclose, or use B.M.’s personal  information, as required by COPPA.   51.  Defendants never provided direct notice – as required by COPPA –  to Ms. Scott regarding Defendants’ practices with regard to collecting, using and  disclosing B.M.’s personal information, or regarding the rights of Ms. Scott or  B.M. under COPPA.   66.  Plaintiff repeats and realleges all preceding paragraphs contained  herein.   67.  Plaintiff and the Multi-StateClass members have reasonable  expectations of privacy in their use of mobile phones and online activity.  Additionally, Plaintiff and the Multi-State Classmembers have a reasonable  expectation that children’s information will not be improperly collected and  published or utilized without parental notification and consent. Plaintiff and the  Multi-State Class members expect that children’s online behavior and private  affairs will remain private and free of intrusion. The private affairs and concerns  of children under the age of 13 include their personal and contact information  that can be improperly collected and used without parental consent.   Intrusion Upon Seclusion  (Brought on Behalf of the Multi-State Class)  