See important disclosures including my related financial interests.
In response to my report of AppLovin installing apps onto users’ devices without consent, Bloomberg published AppLovin Axes Product Tied to Unwanted App Download Allegations.
I filed a complaint with the SEC about what I claim to be material false statements in AppLovin’s remarks to Bloomberg and elsewhere. Here:
RE: AppLovin false statements about permission to install apps on users’ devices, about reason for discontinuing “Array” installation business – Edelman Complaint to SEC – October 15, 2025The complaint has three parts. First, as to the nonconsensual installations. I proved AppLovin is installing without user consent. But AppLovin’s CEO wrote in February “Every download results from an explicit user choice.” And AppLovin told Bloomberg today: “Users never get downloads with any of our products without explicitly requesting it.” Both false. The difference is fundamental. If users actually agree to the installations, great, go ahead. But if, as I say I amply proved, the installations are without user consent, then they are way out of line — outside user expectations, contrary to Google’s security architecture for Android, maybe proper basis for litigation.
How could AppLovin be planning to argue that its installations entail “consent”? Their best argument — not a very good one — is that users at least tapped ads, and that showed some level of interest. Two reactions to that. One, that’s not what users reasonably expect. An ad tap is not an agreement to install. On Android, installations are the big blue Install button at Google Play Store, not just a random tap. Two, AppLovin takes steps to make ad taps extra frequent. Most ads have a long delay, then show a small arrow in one corner, which, when tapped, brings a user to a second screen, with a further delay, and then finally an X somewhere. If you’ve never had the pleasure of seeing this ad format, count yourself lucky. It is beyond annoying! The two waits, and the arrow and X in different corners, make it especially easily to tap accidentally. Ultimately, tapping an ad just is not consent to install. Whatever contortions AppLovin’s lawyers and publicists may attempt, users with the slimmest tech experience know the difference
Second, AppLovin today told Bloomberg not just that it had discontinued the Array installation business, but that it did so because that offering “was not economically viable for us.” But for seven adjacent quarters (latest in August 2025), AppLovin’s SEC filings touted Array as a source of “future growth.” AppLovin’s CFO in February 2024 cited Array installations for “contributions” to growth. I say the real reason AppLovin turned off Array isn’t because it’s unprofitable. It’s because they got caught.
Third, AppLovin told Bloomberg the Array installations were only a “test.” But Array was available as early as 2023. Jia-Hong Xu, previously Head of Product for Array, wrote on his LinkedIn page that he led this product beginning in July 2023. My tabulation of user complaints shows users reporting problems reasonably attributed to AppLovin as early as August 2023. A maxim remarks “always be testing”, and that much I agree with. On some level every decision is a test, always up for reevaluation. But in calling Array a test, AppLovin wants to say this is small. That claim should be supported with real evidence — exactly how many installs, starting on what date, ending on what date, and incidentally with what permission? The one-word label “test” won’t do it.
***
Publicly-traded firms owe their investors forthright statements about material information. I say AppLovin fell short, in fact was materially misleading in the statements both in February (on its web site) and today (to Bloomberg). I look forward to the SEC investigating.