For companies seeking a roadmap to bind minors and other users to a mobile application’s arbitration agreement, the U.S. Central District of California’s recent decision in Garcia v. Roblox Corp., Case 2:25-cv-03476-WLH-AJR (C.D. Cal. Feb. 11, 2026), provides a useful guide.
In Garcia, two parents and their minor daughter, R.G., sued Roblox Corporation (“Roblox”), alleging that Roblox secretly recorded R.G.’s online interactions. Roblox moved to compel arbitration of the dispute, citing arbitration agreements with the Garcias from 2023 and 2025. The questions before the court were whether (1) the Garcias agreed to arbitration, (2) R.G. could, as a minor, disaffirm her agreement to arbitration, and (3) the arbitration provision was unconscionable.
On the first question, the court relied on Keebaugh v. Warner Bros. Ent. Inc., 100 F.4th 1005 (9th Cir. 2024), in which the Ninth Circuit upheld an arbitration agreement based on the plaintiff’s affirmative agreement to conspicuous arbitration terms. Similarly, in Garcia, the court concluded that the Garcias agreed to arbitrate when they created customer accounts with Roblox. To sign up for an account, the Garcias had to click a “Sign Up” button, which was immediately above the following language: “By clicking Sign Up, you are agreeing to the Terms of Use including the arbitration clause . . . .” A link to the terms of use was directly below this language. A later version of the application adopted substantially the same process (substituting “Continue” for “Sign Up”).
On the second question, although the court recognized that minors can normally disaffirm their contracts for lack of capacity, “equitable considerations weigh[ed] in favor of binding R.G.” to the arbitration agreement. Relying on the principle that non-signatories to an arbitration agreement can be bound to arbitrate through a principal-agent relationship with another, the court held that parents’ assent to arbitration was sufficient to bind a minor child. Additionally, the court relied on the fact that R.G. had continued to use the application in 2025, requiring renewed assent to the arbitration terms. Having continued to enjoy the benefits of the application, the minor could not disaffirm the arbitration agreement. According to the court, a contrary holding would allow users to avoid arbitration by having third parties create accounts on their behalf.
On the third question, the Garcias argued that the contract was both substantively and procedurally unconscionable. The court disagreed. While there was some risk of procedural unconscionability due to the adhesive nature of the contract, the risk was low because the Garcias affirmatively agreed to conspicuous terms. As to substantive unconscionability, the Garcias could not point to any oppressive provision. Therefore, the court compelled arbitration.
The Garcia decision provides additional guidance to developers who seek to compel minors and other users of their mobile applications to participate in arbitration. It also provides a useful reminder that minors will not always be permitted to disaffirm an arbitration agreement based on lack of capacity to contract.
