Walmart removes ‘Universe of Play’ advergame from Roblox

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Retailer corporation Walmart has withdrawn its “Universe of Play” advergame from the Roblox platform following pressure from a group of advocacy organizations led by non-profit ad watchdog (

The advocacy groups raised concerns that the game, which had a certification seal from CARU’s Children’s Online Privacy Protection Act (COPPA) Safe Harbor Program, exposed children to misleading marketing and failed to differentiate between advertising and organic content, manipulating children into engaging with stealth ads.

Walmart released the advergame in September last year, aiming to attract younger consumers on the Roblox platform. The game — dubbed the “ultimate virtual toy destination” — featured products and characters from popular children’s franchises, including Paw Patrol, Jurassic World and L.O.L. Surprise!

In January, a coalition of advocacy groups —, Fairplay, Center for Digital Democracy and the National Association of Consumer Advocates — raised concerns with Walmart and the Children’s Advertising Review Unit (CARU) about Universe of Play.

Concerns over COPPA Safe Harbor Program

In a recent letter to CARU, advocacy groups — joined by Common Sense Media — have expressed concerns about the COPPA compliance program. They argued that CARU has inappropriately expanded its advertising safe harbor, as demonstrated by the Universe of Play game.

The program is only authorized to provide safe harbors for privacy, not advertising, so by claiming that Universe of Play complied with both, CARU exceeded its authority. This matter is significant since products that gain approval from safe harbor programs are entitled to protections from FTC actions.

This could lead to the false impression that company advertising misconduct is protected from FTC review.

“ is always pleased when deceptive marketing is removed or corrected, particularly when it impacts a vulnerable population such as young children,” legal director Laura Smith said.

“It is unfortunate, however, the deception ever existed in the first place and we urge CARU to do everything it can to prevent this type of wrongdoing from happening again in the future.”

Laura Smith, legal director

Fairplay campaign director David Monahan expressed concerns about the safety of children online and the role of CARU in ensuring that gaming sites are free from deceptive marketing.

“Parents have a hard enough time making sure their kids are on sites that are safe and not targeting them for purchases or sensitive data.”

David Monahan, Fairplay campaign director

Monahan added that parents do not expect their children to be exposed to deceptive marketing tailored to the interests of young children on a gaming site that has received a seal of approval from CARU.

“We’re glad to see this advergame was removed from Roblox,” Monahan said.

In a separate complaint to the FTC in 2022, targeted Roblox for failing to establish effective guardrails to ensure compliance with truth in advertising laws on its platform. Roblox has since made significant changes to its advertising guidelines.

The new advertising policy requires developers to disclose clearly to users when content is an advertisement, using simple and easy-to-understand language. Simply mentioning the name of an advertiser is not sufficient. The disclosure should be located in or near the advertising content and be noticeable and easily understood by users.


Roblox () is an online game platform and game creation system developed by Roblox Corporation that allows users to program games and play games created by other users. (wikipedia)


Walmart Inc. is an American multinational retail corporation that operates a chain of hypermarkets , discount department stores, and grocery stores in the United States, (wikipedia)


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